Privacy Policy

Privacy Policy

Privacy is very important to us. We also understand that privacy is very important to you. This Privacy Statement tells you how we protect and use information that we gather through our website. Aletheia Capital (Hong Kong) Limited and its affiliates also operate other websites. This Privacy Statement does not apply to other websites. You should review the privacy statement posted on these websites when you visit them.

This Privacy Statement was last revised on June 8 2018. We may change this Privacy Statement at any time and for any reason. We encourage you to review this Privacy Statement each time you visit the website.

By using this website, you agree to the terms of the most recent version of this Privacy Statement. Please read our Terms of Use to understand the general rules about your use of this website and its content. Except as written in any other disclaimers, policies, terms of use, or other notices on this website, this Privacy Statement and the Terms of Use are the complete agreement between you and Aletheia Capital (Hong Kong) Limited with respect to your use of this website. You may be subject to additional terms that may apply when you access particular services or materials on certain areas in this website, or by following a link from this website.

The information we receive, and how we use it, depends on what you do when visiting our website. We collect and use your non-personal information (information that is not identifiable to you personally) differently than your personal information.

When we use the words we, our and/or,,,, Asianomics Group Ltd,  we mean Aletheia Capital (Hong Kong) Limited.

Your Personal Information

Your personal information (i.e. information that directly or indirectly identifies you or can be used to identify you, such as your name and contact details) is protected by the Personal Data (Privacy) Ordinance (the “PDPO”). From time to time, it is necessary for customers of Aletheia Capital (Hong Kong) Limited to supply us with personal information in connection with the provision of research reports, investment advisory services and/or any other services that you may require us to provide from time to time or for us to comply with the laws or guidelines issued by regulatory or other authorities. Failure to supply such personal information may result in us being unable to provide such services or comply with any laws or guidelines issued by regulatory or other authorities.

How we use your personal information

We may keep and use personal information we collect from you through this website to provide you with access to this website. In addition, we may keep and use your personal information for the following purposes, subject to your consent to the use / provision for use of your personal information for direct marketing (if applicable):

- to respond to your requests

- to personalise your access to our website, for example, by telling you about new developments that may be of interest to you

- to develop records, including records of your personal information

- to contact you with information that might be of interest to you, including information about new reports/publications, products and services of ours and of others (see further details regarding direct marketing below)

- for analytical purposes and to research, develop and improve products, services and content

- to enforce this Privacy Statement and other rules about your use of this website

- to protect our rights or property

- to comply with a law or regulation, court order or other legal process

Aletheia Capital (Hong Kong) Limited will keep your personal information confidential and will not share your personal information collected from this website with an unrelated third party without your permission, except as otherwise provided in this Privacy Statement.

We may disclose your personal information to the following parties for the purposes set out above:

- any of our group companies, affiliates, office or branches;

- persons or companies that we hire to perform services or functions on our behalf (for example, we may use different vendors, information technology providers or suppliers to ship products to you that you ordered/requested for on our website)

- any actual or proposed assignee or a transferee of our rights and/or obligations or in respect of all or any part of our assets or businesses;

- any institution, court, agency or authority (including law enforcement authorities) to whom we are required to disclose your personal information by law (see “Disclosure of your personal information” below).

In all cases in which we share your personal information with a third party and to the extent permitted by law, we will not authorise them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.

Aletheia Capital (Hong Kong) Limited may transfer your personal information outside Hong Kong to other countries, including countries which may not have equivalent data protection laws to those in Hong Kong. We are responsible for making sure that any such transfer is made in compliance with the PDPO.

Use and provision for use of personal information in direct marketing

We intend, from time to time, to use some of your personal information (including your name, contact details (such as your addresses, phone numbers and, email address), products and services portfolio information, transaction patterns and behaviour, financial background and account history) for the purposes of direct marketing to you the following classes of services and products: advisory, investment and related services and products. We cannot use your personal information for any of these purposes unless you consent to the intended use.

We may provide your personal information as mentioned above, as appropriate, to any affiliates of Aletheia Capital (Hong Kong) Limited for use by them in direct marketing to you the classes of services and products listed above. We cannot provide your personal information to any of those parties unless you consent to that provision of personal information.

You may exercise your right to opt-out or withdraw your consent by notifying Aletheia Capital (Hong Kong) Limited at [email protected] if you do not wish or no longer wish to consent to the use or provision to other person of your personal information for use in direct marketing as mentioned above. If you choose to exercise such right, we shall cease to use and/or disclose your personal information for direct marketing purposes.

Data access and correction requests

Under the PDPO, you have the right:

(a) to ascertain whether we hold your personal information and request access to such information within a reasonable time;

(b) to require us to correct any personal information about you which may be inaccurate; and

(c) to ascertain our policies and practices in relation to personal information and to be informed of the kind of personal information held by us.

We have the right to charge a reasonable fee for the processing of any data access request. If we do not provide you with such access, we will provide you with reasons for the refusal. You have the right to object to such refusal.

The person to whom requests for access to personal information or correction of personal information held by Aletheia Capital (Hong Kong) Limited, or for information regarding data policies and practices and the kinds of personal information held by us are to be addressed to the General Manager, [email protected]

Disclosure of your personal information

We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting website visitors who violate our rules or engage in behavior which is harmful to other visitors (or illegal).

To the extent permitted by law, we may disclose your personal information to third parties if we feel that the disclosure is necessary to:

- enforce this Privacy Statement and the other rules about your use of this website

- protect our rights or property

- protect someone's health, safety or welfare

- comply with a law or regulation, court order or other legal process in Hong Kong

- for the purpose of a due diligence exercise in connection with a business transfer or a corporate sale, merger or acquisition.

Linked websites

This website may contain links to other websites not operated by Aletheia Capital (Hong Kong) Limited. We provide the links for your convenience, but we do not review, control, or monitor the privacy practices of websites operated by others. This Privacy Statement does not apply to any other websites. We are not responsible for the contents of or the consequences of accessing any such linked websites and do not assume responsibility for the accuracy or appropriateness of the information contained at such websites. Therefore, whenever you leave this website we recommend that you review each website's privacy practices and make your own conclusions regarding the adequacy of these practices.

We take reasonable steps to protect your personal information from loss, misuse, and unauthorised access, disclosure, alteration, or destruction.


If you have questions or comments about this Privacy Statement, please feel free to contact us at: [email protected]

Aletheia Capital (Hong Kong) Limited

Tel: (852) 3470 0011