Dimensional does not sell Personal Data to anyone. Dimensional’s aim is not to disclose any Personal Data to non-affiliated third parties, except with consent of the relevant individual, as necessary or advisable to service a client account in providing Services or as otherwise permitted by law as described below in “Disclosure of Personal Data.”
Commitment to Privacy
The provision, by you or your representatives, of the Personal Data you share with us online, or in connection with obtaining Services, is voluntary. However, if you do not provide us with your Personal Data, we may not be able to provide you with Services and/or respond to your queries.
We consider privacy to be fundamental to our business and our relationship with our clients. We seek to maintain the confidentiality, integrity, and security of the Personal Data entrusted to us. Internal processes have been developed that aim to protect this confidentiality while allowing client needs to be served. These processes address how we handle confidential information within our administrative, technical, and physical systems. Naturally, we strive to protect the confidentiality of information maintained for all accounts, but we may not have access to the Personal Data of individual investors, including those who invest through omnibus accounts.
Personal Data Collected
The Personal Data that we may collect from individuals includes:
1. Identifying information that individuals may provide to Dimensional, such as:
• Telephone number
• Email address
• Passport or Hong Kong Identity Card number
• Information on income, assets, or liabilities
2. Information that Dimensional may obtain while handling transactions for clients, such as account balance information, investment activity, and securities held on behalf of the client that is personally identifiable to such client.
3. The fact that an individual is or has been our client or has obtained Services from Dimensional.
4. Information captured on our websites that is maintained in a personally identifiable form.
In addition to Personal Data you provide to us, Dimensional or its affiliates may receive information about you from third parties in connection with providing Services, including information used to verify your identity, to prevent fraud, or to help us identify Services that may benefit you. For example, funds advised by Dimensional’s affiliates use a third-party transfer agent and third-party providers of systems that use your information to process or analyze transactions you have requested.
We seek to implement controls to maintain the security of Personal Data and information systems and to protect client files with appropriate safeguards, according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) may also be placed on our computer systems. Physical access to areas where Personal Data is gathered, processed, or stored is limited to authorized employees.
Use of Personal Data
Dimensional uses Personal Data for the following purposes:
- To assess an application for Services
- To manage and track investments, and to analyze and improve Services
- To provide Services, such as pertinent communications, including account statements, or the results of our surveys in which you participate
- For the management and administration of our business
- To comply with and assess compliance with applicable laws, rules, and regulations, and internal policies and procedures (including but not limited to tax or other business reporting purposes)
- For the administration and maintenance of databases storing Personal Data
- To provide you with general information about Dimensional, its affiliates, and/or their services
- To process instructions from you or persons acting on your behalf
- Any other purpose directly related to those described above
The Information We Collect Through Your Use of Our Website
One way that information is collected on our websites is by using cookies. A cookie is a small file of letters and numbers that is stored on your computer or other device. Most web browsers are initially set up to accept cookies. You may be able to block cookies by activating settings on your browser that allow you to refuse all or some cookies. It may also be possible to delete cookies that have been installed in the past. However, if you set your browser settings to block cookies, you may not be able to access all or parts of our websites.
The information we collect and store through cookies during normal website usage includes anonymized analytics data, such as the name and version of your internet browser, the website that referred you to us, the pages you request, and the date and time of those requests. We use this information to generate aggregate statistics and measure site activity to improve the usefulness of user visits. Because this information is maintained on an anonymized basis, it should not be considered Personal Data by itself. However, if you provide us with any of your Personal Data through our websites, such as your name or contact information, the anonymized information we have collected about you through cookies may be paired with your identifiable Personal Data.
We may collect data from third-party analytics tools, such as Google Analytics and Hotjar. Please review the privacy information on each company’s website for more information on how they collect and process data.
There are instances where we request Personal Data, such as name and address, on our websites, such as for registration on our password-protected client website or through the Contact Us page. The information you provide is used by us and our affiliates to understand who our website users are and to contact you regarding our and our affiliates’ Services. The Personal Data we collect in this manner is not provided to any other company for that company’s independent use.
Disclosure of Personal Data
Dimensional’s aim is not to disclose any Personal Data to non-affiliated third parties, except with consent of the relevant individual, as necessary or advisable to service a client account in providing Services or as otherwise permitted by law as described below. In the normal course of serving clients, Personal Data may be transferred to affiliates of Dimensional or third-party companies that perform various services for Dimensional, such as transfer agents, custodians, proxy solicitation firms, or printers or mailers that may assist Dimensional in the distribution of investor materials and/or in providing Services. The organizations that receive Personal Data will only receive the information that Dimensional believes to be necessary or advisable to carry out the organizations’ assigned responsibilities. Such organizations are authorized by Dimensional to use Personal Data only for the services required and are not permitted to share or use Personal Data for any other purpose.
We may disclose or report Personal Data to governmental or regulatory authorities (or others as permitted by law) in limited circumstances where we believe in good faith that such disclosure has been requested by a governmental or regulatory authority or is required or permitted by law (for example, to cooperate with regulators or law enforcement authorities, such as responding to a subpoena or other legal process, or to protect accounts from fraud). We may also disclose or report Personal Data as required to fulfill a judgment or order of a court or other tribunal, or otherwise to resolve disputes.
These privacy practices apply to both current and former clients, and we may disclose non-public Personal Data about former clients to the same extent as for current clients. The practices described above also apply to client representatives and individuals other≈than clients who Dimensional does business with. The practices described above may involve transfer of your Personal Data outside of Hong Kong.
Dimensional does not generally obtain any information from a consumer reporting agency or information that is derived from a consumer report that identifies an individual. If Dimensional obtains a consumer report on an individual, Dimensional will aim to erase and/or destroy such information that identifies an individual and that is not required to be kept for record keeping purposes.
The Internet and Third-Party Sites
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any Personal Data or other information that you transmit to us online is transmitted at your own risk.
Inquiries, Access, and Correction
Data Protection Officer,
Dimensional Hong Kong Limited,
8 Marina View, #33-01 Asia Square Tower 1,
Please include your name and contact information with your request. We may charge a reasonable fee for processing a data access request.