1. Handling Your Personal Data
Blue Zone Capital Management Limited (“BZCM”, “we”, “us” or “our”) is a company incorporated in Hong Kong. We respect the privacy of every individual whose personal data we handle, and we comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”), including its six Data Protection Principles, and with other applicable laws.
This Privacy Policy explains how we collect, use, store, disclose and protect personal data in connection with this website, investor enquiries, and our fund management and co-investment activities. It also serves as our Personal Information Collection Statement.
2. What “Personal Data” Means
“Personal data” has the meaning given in the PDPO: any data relating directly or indirectly to a living individual, from which it is practicable to ascertain the identity of that individual, and which is in a form in which access to or processing of the data is practicable.
3. Personal Data We Collect
Website visitors
- IP address, browser and device type, and pages viewed
- Your language choice
- Cookies and similar technologies (see section 12)
Investor enquiries
- Name and company email address
- Type of investing entity and indicative allocation size
- Your confirmation that you are a professional or accredited investor
- Any further information you choose to share in correspondence with us
Prospective and existing investors
- Identity details: name, date of birth, nationality, residential address, and passport or identity card details
- Evidence of professional investor status, as required under the Securities and Futures Ordinance (Cap. 571) and its subsidiary legislation
- Due diligence information: source of funds and wealth, beneficial ownership and control of investing entities, and politically exposed person and sanctions screening results
- Tax residence and taxpayer identification numbers, including self-certifications for CRS and FATCA reporting
- Bank account details for subscriptions, distributions and redemptions
- Holdings, transaction history and investor communications
Business contacts
- Name, job title, organisation and contact details of representatives of our partners, service providers and advisers
4. Why We Use Your Personal Data
We use personal data only for purposes directly related to our business, namely:
- To respond to your enquiries and assess whether you are eligible to invest
- To carry out identity verification, customer due diligence and anti-money laundering and counter-terrorist financing checks, including under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
- To prepare, execute and administer subscription documents and investment records
- To process subscriptions, distributions and redemptions, and to provide investor reporting
- To meet our legal, regulatory and tax obligations, including automatic exchange of financial account information (CRS) and FATCA, and to respond to lawful requests from regulators, courts and law enforcement agencies
- To manage risk, prevent fraud and keep our systems secure
- To operate, maintain and improve this website
- With your consent only, to send you information about our funds, investment opportunities and events (see section 9)
Providing personal data to us is voluntary. However, if you do not provide the information needed for due diligence and regulatory purposes, we may be unable to respond to your request or to accept your investment.
We will not use your personal data for a new purpose without your prior voluntary and express consent, unless an exemption under the PDPO applies.
5. How We Collect Personal Data
We collect personal data by lawful and fair means, including:
- Directly from you, through the enquiry form on this website, by email, in meetings, and in subscription documents
- From your authorised representatives, advisers or introducing intermediaries
- From screening databases and publicly available sources, for due diligence purposes
- Automatically, when you use this website
6. Disclosure to Third Parties
We do not sell personal data. We may disclose personal data, on a need-to-know basis, to:
- Our affiliated companies, including Blue Zone K.K. in Japan, which sources and manages the investments of our funds
- Fund administrators, custodians, banks, auditors, and legal, tax and compliance advisers
- Service providers that operate on our behalf, such as website hosting, website translation, form delivery, email and screening providers
- Regulators, tax authorities, courts and law enforcement agencies, where required or permitted by law
- A prospective buyer or successor of our business, under a duty of confidentiality
Where we engage a data processor, we use contractual or other means to prevent the personal data from being kept longer than necessary and to protect it against unauthorised or accidental access, processing, erasure, loss or use.
7. Transfers Outside Hong Kong
Our affiliates and service providers operate in several jurisdictions, including Japan, so your personal data may be transferred to, stored in, or processed outside Hong Kong. Where this happens, we take reasonable steps, including contractual safeguards, to ensure that your personal data receives a level of protection comparable to that required under the PDPO. Affiliates in Japan handle personal data in accordance with the Act on the Protection of Personal Information of Japan.
8. Joint Use Within Our Group
Where we use personal data jointly with Blue Zone K.K., we do so only for the purposes set out in section 4, and BZCM remains responsible for the personal data it collects.
9. Direct Marketing
We will not use your personal data for direct marketing, such as information about our funds, new investment opportunities or events, unless you have given us your consent in accordance with Part 6A of the PDPO. We do not provide your personal data to any third party for its own direct marketing.
You may withdraw your consent at any time, free of charge, by contacting us using the details in section 15.
10. Security
We take all practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use. These measures include:
- Encrypted connections (HTTPS) for this website and its forms
- Access restricted to staff and service providers who need it
- Confidentiality obligations for our staff
- Supervision of the service providers who handle personal data for us
11. How Long We Keep Personal Data
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. For example, customer due diligence and transaction records are kept for at least five years after a business relationship ends, as required by the Anti-Money Laundering and Counter-Terrorist Financing Ordinance. Enquiries that do not lead to an investment relationship are deleted once they are no longer needed.
12. Cookies and Similar Technologies
This website and the platform that hosts it use cookies and similar technologies to:
- Keep the website secure and working properly
- Remember your language choice
- Produce anonymous, aggregated statistics about how the website is used
We do not use advertising cookies. You can block or delete cookies in your browser settings, but some parts of the website may then not work properly.
13. Your Rights
Under the PDPO, you have the right to:
- Ask whether we hold your personal data, and request a copy of it
- Ask us to correct personal data that is inaccurate
- Withdraw your consent to direct marketing at any time
We will respond to data access and correction requests within 40 days, as required by the PDPO. We may charge a fee for complying with a data access request, which will not be excessive. If you are not satisfied with how we have handled your personal data, you may also contact the Office of the Privacy Commissioner for Personal Data, Hong Kong.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in law or in our business. The current version will always be posted on this page with its date.
15. Contact Us
Please send any questions, data access or correction requests, or requests to stop direct marketing, to our Data Protection Officer:
Data Protection Officer
Blue Zone Capital Management Limited
12F, Elite Centre, 22 Hung To Road, Kwun Tong, Kowloon, Hong Kong
Email: info@bluezoneokinawa.com