Privacy Policy

PRIVACY STATEMENT

1. INTRODUCTION

Enhanced Investment Management Limited (“EIML,” “we,” “us,” or “our”) is a financial/brokerage firm based in Hong Kong, providing investment management, brokerage services, financial advisory, and securities trading to clients globally.

This Privacy Policy describes how EIML collects, uses, processes, stores, and protects your personal information when you access, browse, or use our services (collectively, “Services”). We are committed to protecting your privacy and ensuring transparency in our data practices, in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”), and by considering principles from international data protection regimes such as the General Data Protection Regulation (“GDPR”) for clients in the European Union/European Economic Area (EU/EEA), the California Consumer Privacy Act (“CCPA”) for certain circumstances in the USA, the Australian Privacy Principles, and other relevant privacy acts in jurisdictions where we actively solicit or provide services.

As a regulated financial institution, we are also subject to stringent Know Your Customer (“KYC”), Anti-Money Laundering (“AML”), and Counter-Terrorist Financing (“CTF”) regulations. This policy outlines our obligations under these international frameworks, which require us to collect and verify certain information to prevent financial crime.

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the terms of this Privacy Policy and our Terms & Conditions. If you do not agree with the terms of this policy, please do not use our Services.

2. INFORMATION WE COLLECT

We collect various types of information from and about you to provide our Services, fulfill our legal and regulatory obligations, and improve your experience.

2.1. Personal Information You Provide to Us (KYC/AML Data):
This is information you directly provide when you apply to open an account, use our Services, communicate with us, or participate in surveys and promotions. This may include:

• Identity Data: Full legal name, previous names, date of birth, gender, nationality, place of birth, passport number, national identification number, driver’s license number.
• Contact Data: Residential address, mailing address, email address, phone number.
• Financial Data: Bank account details, payment card details, income, source of wealth, source of funds, transaction history, investment objectives, risk tolerance, and investment experience.
• Occupational Data: Profession, employer, job title.
• Biometric Data: (Only if necessary for identity verification and with explicit consent where required by law) Facial scans from identity documents, live facial images for liveness detection.
• Politically Exposed Person (PEP) and Sanctions Status: Information related to your potential designation as a PEP or inclusion on international sanctions lists.
• Communication Data: Records of your communications with us, including customer support inquiries, emails, and call recordings.
• Due Diligence Information: Any other information required for us to perform enhanced due diligence (EDD) where deemed necessary by our risk assessment.

2.2. Information We Collect Automatically:
When you access or use our Services, we may automatically collect certain information about your device and usage patterns, which helps us to improve our services, ensure security, and comply with technical standards. This includes Technical Data, Usage Data, Location Data, and information via Cookies and Tracking Technologies.

2.3. Information from Third Parties:
We may obtain information about you from third-party sources to comply with our legal and regulatory obligations, enhance security, and for legitimate business purposes (e.g., identity verification services, sanctions/PEP screening, anti-fraud, publicly available sources, affiliates, and partners).

3. HOW WE USE YOUR INFORMATION

We use the information we collect to provide and maintain our Services, comply with legal and regulatory requirements (including KYC/AML/CTF), ensure security and risk management, support business operations and improvement, and for marketing/communications with consent where required.

4. LEGAL BASES FOR PROCESSING

We rely on performance of a contract, legal obligations, legitimate interests, and consent (where required) as legal bases for processing your personal information.

5. HOW WE SHARE YOUR INFORMATION

We may share your information with EIML affiliates, service providers (e.g., identity verification, payment processors, custodians, IT/cloud, analytics, customer support, professional advisors, marketing partners), regulators and law enforcement, in business transfers, with your consent, or as required by law.

6. INTERNATIONAL DATA TRANSFER

Your personal data may be transferred internationally where necessary for our Services, subject to appropriate safeguards such as SCCs, adequacy decisions, intra-group agreements, and vendor contractual protections.

7. DATA RETENTION

We retain your personal information as required to meet regulatory requirements (including KYC/AML records), support dispute resolution, and for legitimate business purposes. We may anonymize data for research/statistical purposes.

8. YOUR DATA PROTECTION RIGHTS

Subject to law, you may have rights to access, rectification, erasure, restriction, portability, objection, consent withdrawal, and to lodge complaints with supervisory authorities.

9. SECURITY MEASURES

We implement technical and organizational measures such as encryption, access controls, physical and network security, audits, training, and incident response. While robust, no method is 100% secure.

10. THIRD-PARTY WEBSITES

Our Services may include links to third-party sites not operated by us. We are not responsible for their content or practices. Review their privacy policies.

11. CHILDREN’S PRIVACY

Our Services are not directed to individuals under 18. We do not knowingly collect data from children. If collected inadvertently, we will delete it.

12. CHANGES TO THIS PRIVACY POLICY

We may update this policy from time to time. Material changes will be posted with an updated Effective Date. Continued use constitutes acceptance.

13. CONTACT US

If you have questions or wish to exercise your rights, contact us: