This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how Airscend Family Wealth Management uses your data; for example we will explain things such as our credit checking procedure, and how we combine data across Airscend Family Wealth Management to build a picture of you.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

Scope

This policy applies to the following businesses:

  • Airscend Family Wealth Management, both online and in-store.
  • Business Registration number 56408044. Registered office: 6F CRASON COMMERCIAL CENTRE, 333 NATHAN ROAD, TSIM SHA TSUI, KL

The privacy policy explains how we use any personal information we collect about you when you use this website and our wider services. Further information in relation to job applicant privacy can be found here.

Glossary of Terms

What is personal data?

Personal data relates to any information about a natural person that makes you identifiable which may include (but is not limited to):

  • Names and contact information i.e. emails and telephone numbers.
  • National Insurance Numbers
  • Employment history
  • Employee numbers
  • Credit History
  • Personal tax
  • Payroll and accounting data

What is sensitive personal data?

Sensitive personal data refers to the above but includes genetic data and biometric data. For example:

  • Medical conditions
  • Religious or philosophical beliefs and political opinions
  • Racial or ethnic origin
  • Convictions
  • Biometric data (eg photo in an electronic passport)

What is a Data Controller?

For general data protection regulation purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed.

The data controller is Airscend Family Wealth Management, 6F CRASON COMMERCIAL CENTRE, 333 NATHAN ROAD, TSIM SHA TSUI, KL

What is a Data Processor?

A “data processor” is a person or organisation which processes personal data for the controller.

What is Data Processing?

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What do we mean by Business to Business?

PLC, LTD, LLP incorporated partnerships, trusts and foundations, local authorities and government institutions.

What do we mean by Business to Consumer?

Private clients, and sole traders etc.

What information do we collect about you and how?

Airscend Family Wealth Management as a Data Controller, is bound by the requirements of the General Data Protection Regulations (GDPR).

You agree that we are entitled to obtain, use and process the information you provide to us to enable us to provide services and the sale of goods and for other related purposes including:

  • Updating and enhancing customer records
  • Carrying out credit checks in relation to you
  • Statutory returns
  • Legal and regulatory compliance
  • Crime prevention

We collect information about you when you place an order through our website or sending an enquiry, signing up for newsletters, giving feedback etc.

Website usage information is collected using cookies.

When submitting forms on our website we use a third-party software provider for automated data collection and processing purposes, they will not use your data for any purposes and will only hold the data in line with our policy on data retention.

Cookies are text files put on your computer to collect standard internet log information and visitor behaviour information. This information is then used to track visitor use of the website and to create statistical reports on website activity.

You can set your browser not to accept cookies or remove cookies from your browser. Please note in a few cases some of our website features may not function because of this.

Analytics – eg how visitors use our website.

We use Google Analytics to store information about how visitors use our website so that we may make improvements and give visitors a better user experience.

Google Analytics is a third-party information storage system that records information about the pages you visit, the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you eg name, address etc and we do not share the data. You can view their privacy policy below:

Google – https://www.google.com/intl/en/policies/privacy/

IP addresses

An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet. Airscend Family Wealth Management do not have access to any personal identifiable information and have no need to seek this information. Your IP address is logged when visiting our site, but our analytic software only uses this information to track how many visitors we have from particular regions.

Internet Based Advertising

We use Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.

How will we use the information about you and why?

Airscend Family Wealth Management takes your privacy seriously and will only use your personal information to provide the Services you have requested from us and as we have identified above. We will only use this information subject to your instructions, data protection regulations.

For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual” eg to supply goods and services you have requested, or to fulfil obligations under an employment contract.

There may be times when we need to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf ie. delivery couriers. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and goods.

We collect information on our website to process your enquiry, complete a transaction, give advice and improve our services. If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you (however this will be a clear opt in process) We will never share or sell your information for marketing purposes with other companies so that they may offer you their products and services.

Transferring your information outside of Europe

As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU. Where this is the case we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. Where our third-party supplies are in the US we have ensured that their services fall under the “Privacy Shield” whereby participating companies are deemed to have adequate protection and therefore facilitate the transfer of information from the EU to the US.

Security precautions in place about data collected

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology. Access to your personal data is password-protected, and sensitive data such as payment card information) is secured and tokenised to ensure it is protected.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

Marketing

If you have consented to receive marketing we would like to send you information about our services which may be of interest to you. We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. If you have consented to receive marketing, you may opt out at any point time.

We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.

How long will we hold your data for?

  • Marketing: We will hold your data for a period of 36 months with a review every 12 months. You will have the opportunity to opt out, update or delete data at any point should you need to do so and details are set out in this policy as to how to do that.
  • Contracted Services/ sales: We will hold your data for 6 years in line with our regulatory requirements.

Access to your information, correction, portability and deletion

What is a Subject Access Request?

This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please email info@fwmhk.com The organisation will normally respond to a request within a period of one month from the date it is received. In some cases, such as where the organisation processes large amounts of the individual’s data, we may respond within three months of the date the request is received. The organisation will write to the individual within one month of receiving the original request to tell him/her if this is the case.

We also like to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by emailing info@fwmhk.com

Objections to processing of personal data

It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of any legal claims.

Data Portability

It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

(a) The processing is based on consent or on a contract.

(b) The processing is carried out by automated means.

Your Right to be Forgotten

Should you wish for us to completely delete all information that we hold about you please email info@fwmhk.com.

Other websites

Our website may contain links to other websites. This privacy policy only applies to our website and we recommend that when you link to other websites you should read their own privacy policies.

Complaints

If you feel that your personal data has been processed in a way that does not meet GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint. The supervisory authority in the UK is the Office of the Privacy Commissioner for Personal Data (PCPD).

Changes to our Privacy Policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 21st Sep 2020 and the Version number is 1.0 in line with the new GDPR guidelines.

Please contact us if you have any questions about our privacy policy or information we hold about you: info@fwmhk.com