Privacy Policy

PERSONAL INFORMATION

When you apply for and/or maintain a live or demo account with CPM Financial Group or contact CPM Financial Group for any inquiries, CPM Financial Group collects personal information, including your name, contact details and other personal particulars for the following purposes, such as evaluating your financial needs, processing your requests and transactions, informing you about investment products and services and providing customer service. The types of personal information may include:

• Application information. Information you provide to us on applications and other forms, such as your name, address, birth date, identification card number, occupation, assets, and financials.
• Transaction information. Information about your transactions as well as information about our communications with you. Examples include your account balances, trading activity, your inquiries, and our responses.
• Verification information. Information necessary to verify your identity, such as a passport or driving license. Additional examples also include background information we receive from public records or from other entities not affiliated with CPM Financial Group. CPM Financial Group may also be required to collect your information and take actions necessary to verify your identity in accordance with regulatory requirements.

CPM Financial Group intends to use your name, telephone number and email address for direct marketing investment products and services and CPM Financial Group requires your consent for that purpose. By applying for and/or opening a Trading or demo CPM Financial Group account, you acknowledge and agree that your consent is voluntarily provided to CPM Financial Group. If you do not wish CPM Financial Group to use your data for use in direct marketing as described in this policy, you may exercise your right to opt-out by notifying CPM Financial Group.

In compliance with the Personal Data (Privacy) Ordinance, CPM Financial Group would like to inform you that your personal information may be used for the following purposes:

• Sharing, cross-checking and transferring that personal data with CPM Financial Group or any of CPM Financial Group's affiliated or associated companies whether in relation to new or existing client verification procedures, ongoing account administration or direct or indirect marketing of any investment, dealing or related services or products;
• The comparison and or transfer to third party service providers of such personal data for the purposes of credit checking and or data verification;
• Any purpose relating to or in connection with the compliance of any law, regulation, court order or order of a regulatory authority, including the provision of any such data to any such regulatory authority as required by law or regulation;
• Any other purpose relating to or in connection with CPM Financial Group's business or dealings or the business or dealing of any member of CPM Financial Group or CPM Financial Group's affiliated or associated company

Your personal data held by CPM Financial Group will be kept confidential but CPM Financial Group Companies may provide information to 1) any agent or third party services provider who provides services to CPM Financial Group Companies in connection with the operation of its business 2) any regulatory or governmental authorities which relates to or govern any business of CPM Financial Group and 3) any person that CPM Financial Group consider as appropriate or fit including a member of CPM Financial Group and its employees under a duty of confidentiality. Such information may be transferred to a place outside Hong Kong.

In accordance with the terms of the Personal Data (Privacy) Ordinance, any client has the right:

• To determine whether CPM Financial Group holds data about that client and of access to such data;
• To request CPM Financial Group correct any inaccurate data relating to the client;
• To ascertain CPM Financial Group's policies and practices in relation to data and be informed of the kind of personal data held by CPM Financial Group;
• To request CPM Financial Group cease from using his/her personal data for direct or indirect marketing purpose by writing.

You are not required to supply any of the personal information that we may request. However, failure to provide all required information may prevent us from opening and/or maintaining your account or providing services to you. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

ABOUT COOKIES

Cookies are small files containing information that a Web site uses to track its visitors. CPM Financial Group may set and access CPM Financial Group cookies on your computer, enabling us to learn which advertisements and promotions bring users to our Web site. CPM Financial Group or any of its divisions may use cookies in connection with CPM Financial Group's products and services to track your activities on our Web sites. Such information that we collect and share would be anonymous and not personally identifiable.

SECURITY TECHNOLOGY

CPM Financial Group uses Secure Socket Layer (SSL) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone other than CPM Financial Group while it is being transmitted to us. We work hard to ensure that our Web sites are secure and that they meet industry standards. CPM Financial Group also uses other safeguards such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data.

SHARING INFORMATION WITH OUR AFFILIATES

CPM Financial Group may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing customer accounts and informing customers about new investment products and services, or to aid in the trading activity of the company, its affiliates, or employees, and as permitted by applicable law. Our affiliates may include companies controlled or owned by us as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address, transaction and account information. Our affiliates maintain the privacy of your information to the same extent CPM Financial Group does in accordance with this Policy.

If you do not wish to have your personal information disclosed to our affiliates or other third parties as described in this Policy, please contact us via e-mail at: cs_cpm@cpmfinancialgroup.com.

SHARING INFORMATION WITH THIRD PARTIES

CPM Financial Group does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with CPM Financial Group, including those that provide professional, legal, or accounting advice to CPM Financial Group. Non-affiliated companies that assist CPM Financial Group in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services and only for the purposes that CPM Financial Group describes in this policy.

We may also disclose your personal information to third parties to fulfill your instructions or pursuant to your expressed consent.

We want you to know that CPM Financial Group will not sell your personal information.

REGULATORY DISCLOSURE

Under limited circumstances, CPM Financial Group may disclose your personal information to third parties as permitted by, or to comply with, applicable laws and regulations. For example, we may disclose personal information to cooperate with regulatory authorities and law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose, unless we describe how such information will be used at the time you disclose it to us or we obtain your permission.