Information regarding personal data protection in the EU (or EEA)

In compliance with the Personal Data (Privacy) Ordinance ("the Ordinance"), this Personal Information Collection Statement serves as a notice to you, whether you are an individual client or a director, officer, employee, agent or other representative of a client ("Client") to whom services and products may be provided by GMO-Z.com Forex HK Limited ("Z.com Forex"), so that you are informed of the purposes for which your personal data will be used and to whom your personal data may be transferred and other matters as prescribed in the Ordinance:

1. From time to time, it is necessary for you to supply Z.com Forex with data for the Client to open or continue accounts with Z.com Forex, or to establish or continue financial accommodation or credit facilities or obtain other services and products from Z.com Forex.
2. Failure to supply such data may result in Z.com Forex being unable to open or continue accounts or establish or continue financial accommodation or credit facilities for or provide other services and products to the Client.
3. Your data are also collected in the ordinary course of continuation of the business relationship between the Client and Z.com Forex, for example, when the Client effects transactions.
4. Z.com Forex may use your data for the following purposes:
   • 4.1.processing the Client's applications for opening accounts, financial accommodation or credit facilities or other services or products;
   • 4.2.daily administering and operation of the accounts, services and facilities provided to Client;
   • 4.3.conducting client identification and verification procedures and credit checks at the time of application and from time to time during the continuation of the business relationship between the Client and Z.com Forex whether at special or regular reviews;
   • 4.4.meeting the disclosure requirements under any law, regulations, guidelines, codes of practice or court orders binding on, or applicable to, Z.com Forex or any of its group companies, including but not limited to disclosure requirements relating to prevention of money laundering, terrorist financing;
   • 4.5.complying with the obligations, requirements or arrangements for disclosing and using data that apply to Z.com Forex or any of its group companies or that it is expected to comply according to:
     • a) any law binding or applying to it within or outside the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future (e.g. the Inland Revenue Ordinance and its provisions including those concerning automatic exchange of financial account information);
     • b) any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future (e.g. guidelines, guidance or requests given or issued by the Inland Revenue Department including those concerning automatic exchange of financial account information) and any international guidance, internal policies or procedures;
     • c) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers (together the "Authorities" ) that is assumed by or imposed on Z.com Forex or its group company by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
     • d) any agreement or treaty between Authorities;
   • 4.6.assisting other financial institutions to conduct credit checks and collect debts;
   • 4.7.designing services and products for the Client's use;
   • 4.8.your name and contact details may be used for marketing Leveraged Foreign Exchange trading, financial or related services and products of Z.com Forex and/or its group companies;
   • 4.9.ensuring ongoing credit worthiness of the Client;
   • 4.10.determining amounts owed to or by the Client from time to time;
   • 4.11.collecting amounts outstanding from the Client and/or other persons providing security for the Client's obligations;
   • 4.12.provision of reference (status enquiries) relating to the Client;
   • 4.13.conducting matching procedures by comparing data for producing or verifying data that may be used for or against the Client;
   • 4.14.enabling an actual or proposed assignee of Z.com Forex or an actual or proposed participant, sub-participant or transferee of Z.com Forex's rights in respect of the Client to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer;
   • 4.15.customer segmentation conducted by data analytical firms, such as Google Analytics Inc; and
   • 4.16.purposes relating to the above.
5. Data held by Z.com Forex relating to you will be kept confidential but Z.com Forex may provide such data to the following parties for the purposes set out in paragraph 4 above:
   • 5.1.any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to Z.com Forex in connection with the operation of its business;
   • 5.2.any other person under a duty of confidentiality to Z.com Forex including a group company of Z.com Forex which has undertaken to keep such data confidential;
   • 5.3.any financial institution with which the Client has or propose to have dealings;
   • 5.4.any actual or proposed assignee of Z.com Forex or any actual or proposed participant, sub-participant or transferee of Z.com Forex's rights in respect of the Client; and
   • 5.5.any person to whom Z.com Forex or any of its group companies is under an obligation or is expected to make disclosure under any law, regulations, guidelines, codes of practice or court orders binding on, or applicable to, Z.com Forex or any of their group companies.
6. Z.com Forex may from time to time transfer your data outside Hong Kong for the above purposes and for the purposes of data processing and storage.
7. Under and in accordance with the terms of the Ordinance and guidelines issued pursuant thereto, you have the right:
   • 7.1.to check whether Z.com Forex holds data about you and to access your data;
   • 7.2.to require Z.com Forex to correct any of your data which is inaccurate; and
   • 7.3.to be informed of Z.com Forex's policies and practices in relation to personal data and to be informed of the kind of personal data held by Z.com Forex and the main purposes for which data will be used.
8. You may, at any time, request Z.com Forex to cease using your personal data for direct marketing purposes by writing to Z.com Forex's Compliance Officer as prescribed in paragraph 10 below.
9. In accordance with the terms of the Ordinance, Z.com Forex has the right to charge a reasonable fee for the processing of any data access request.
10. Please address your requests for access to data or correction of data or for information described in paragraph 7.3 above in writing to:

    Compliance Officer
    GMO-Z.com Forex HK Limited
    Suites 2308-09, 23/F, Tower 1, The Gateway, Harbour City, Kowloon, Hong Kong

    E-mail: compliance.trade.hk@z.com

11. Nothing in this Statement shall limit your rights under the Ordinance. Should there be any inconsistencies between the English version and the Chinese version of this Statement, the English version shall prevail.