Schroders' Data Protection Policy

Schroder Investment Management (Hong Kong) Limited and its affiliates, including members of the Schroder Group, are referred to in this policy as “Schroders”, “we”, “us”, “our”. To protect the interests of both existing and prospective clients , Schroders undertakes to comply fully with the Personal Data (Privacy) Ordinance of Hong Kong (“PDPO”). In order to achieve the highest standards of confidentiality, Schroders personnel are trained to deal with client data in the most professional manner.

1. Purpose of use of personal data

Schroders’ principal business activities are the provision of asset management and financial services. Personal data (if any) collected from Schroders' clients through the Internet may be used by Schroders within or outside Hong Kong, for the following purposes:

• conducting its business, including providing investment advisory and management services to its clients, direct marketing (subject to as further set out in section 2 below), compiling statistics for internal use, complying with any applicable law or an order of a competent court binding on or applicable to Schroders, and taking action to defend or protect the interests of Schroders.

Failure to supply the requested personal data may result in Schroders being unable to provide the relevant financial and/or administrative services or support to you in a timely manner.

2. Use of personal data for direct marketing

Schroders will use client’s personal data for direct marketing in the manner described below only if consent (including any indication of no objection) is obtained.

The following client personal data may be collected and used for direct marketing:

• name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data.

Direct marketing communications may be issued for one or more of the following products / services offered by Schroders:

• (i) financial, investment, wealth management, securities, retirement and related services and products;, (ii) financial and investment seminars/events/forums, and (iii) any other products / services directly related to the above.

Should you no longer wish to receive direct marketing communications from us, you can withdraw your consent any time by writing to our Data Protection Officer at the address provided in section 4 below.

Client personal data will not be disclosed and / or transferred by us to any third party for direct marketing without client’s prior written consent.

3. To whom the personal data may be provided

For the purposes set out in sections 1 and 2 above, Schroders may, in the course of conducting its business or to the extent necessary, provide personal data to the following parties, who may be based within or outside Hong Kong:

• authorised persons of Schroders; any agent, contractor or third party service provider who offers administrative, telecommunications, computer, payment or other services to Schroders in connection with the operation of its business; any legal or tax adviser, accountant, other financial or professional adviser to Schroders; any actual or proposed assignee of Schroders’ business or transferee of the Schroders’ rights in respect of you; and any competent authority to whom personal data is required to be disclosed in accordance with any applicable laws or an order of a competent court binding on / applicable to Schroders.

4. What rights do you have?

In accordance with the PDPO, you may:

• check whether Schroders holds personal data about you and gain access to such data; require Schroders to correct any personal data relating to you which is inaccurate; ascertain Schroders’ policies and practices in relation to personal data and be informed of the kind of personal data held by Schroders.

You may exercise the above rights by contacting our Data Protection Officer, c/o Head of Compliance, Schroder Investment Management (Hong Kong) Limited, Level 33, Two Pacific Place, 88 Queensway, Hong Kong

Schroders undertakes to ensure the security of any personal data collected, and will (to the extent practicable and appropriate)erase a client's personal data on receipt of a client request to do so.

5. Use of cookies

We may collect and use cookies relating to your usage of our website. For further details on the Schroders Group cookie policy, please click this link:

https://www.schroders.com/en-hk/hk/individual/footer/schroders-group-cookie-policy/

For further information on how Schroders collect, process and/or use personal data, please refer to Schroders’ group privacy policy: https://www.schroders.com/en/privacy-policy/