Privacy Policy Statement

Strategic Transactions Limited (“STL”) are committed to protecting the privacy, confidentiality and security of all personal data and will ensure compliance by all its staff members with the strictest standards of security and confidentiality.

This privacy policy statement (“Privacy Statement”) is issued pursuant to the Personal Data (Privacy) Ordinance (Cap. 486) and sets out how personal data is collected on (“Website”) and how STL, its affiliates and associated companies use, maintain and process that personal data.

Your use of the Website and/or services is subject to the Terms and Conditions (“Terms”) and this Privacy Statement. By using STL’s Website and/or services and submitting any personal information to STL, you are deemed to have accepted and agreed to the Terms and this Privacy Statement as may be amended, varied, supplemented and/or modified from time to time by STL, at its sole discretion, without any prior notice. All amendments, variations, supplements and/or modifications shall take effect upon posting on the Website. Please read this Privacy Statement carefully and check for updates to this statement on a regular basis.

If you do not agree with the Terms and this Privacy Statement, please do not use this Website and/or services.

Collection of Personal Data

STL collects and stores personal data that you submit on its Website (including subscription to any of STL’s publications, communications with STL and account registration forms) or through other channels. The provision of any personal data by you or on your behalf to STL shall be voluntary. The types of personal data STL collects from you may include (without limitation) the following:-

  1. personal data and sensitive personal information (i.e. name, gender, date of birth, address, telephone number, fax number, email address, education, profession, your business name, purchasing history, nationality, passport or other person identifiable details etc.);
  2. login username and password details for registering an account with STL; and
  3. your comments and/or responses that you enter into data fields on the Website or surveys that STL may circulate or host on its Website from time to time.

Where you provide sensitive personal data to STL voluntarily, it is assumed that STL has your explicit consent to use such data in connection with the purpose which it has been provided.

STL does not guarantee the transmission of person data over the internet and you are urged to exercise caution when submitting your personal data to STL through the Website or otherwise.

Use of Cookies

In order to improve the functionality and efficiency of the Website, various technical information (including but not limited to your browser type, access time, internet protocol (IP) address, internet service provider, operating system, click-stream data, language and your general customization and preferences etc.) may be collected through the use of cookies and similar technologies. STL may use session specific cookies and analytic software to automatically collect data about your usage of the Website and/or services. Cookies are small electronic files that may be stored on your web browser and track technical information about you. The purpose of using cookies is to facilitate content display and webpage redirection.

You may disable or delete cookies at any time on your web browser but by doing so some functions may not work and you may not be able to take full advantage of the Website. You may refer to your ‘Help’ menu of your particular browser to change your cookies settings.

Use of Personal Data

You agree that personal data you provide to STL and all information relating to the use of the Website may be retained and used by STL for the following purposes, without limitation:-

  1. supply of services and information relating to services related to STL and the Website;
  2. verification of identity;
  3. process and evaluation of your applications;
  4. general operation, maintenance and management of the Website and/or services;
  5. administrative activities and management of your account with STL;
  6. processing transactions with you;
  7. design and improvement of the existing Website and/or services;
  8. handling of complaints and enquiries;
  9. marketing, business development or other purposes;
  10. communication with you; and
  11. compliance with laws, regulations or code of practice.

You understand and acknowledge that certain personal data are required for use of the Website and/or related services. If you failed to supply such personal data as required, STL may not be able to provide such services to you and access and/or your use of the Website may be restricted.

All personal data provided by you will only be used for the specific purpose(s) for which it was provided or for directly related purpose(s) unless prior consent is obtained from you by STL. Your personal data will be accessed by the authorized employees of STL, by certain designated companies associated with STL and by authorized agents, contractors or third parties with whom STL contracts with to carry out business and administrative activities for STL. All such person(s) entitled to access and use your personal data will be required to keep your personal data confidential and only use them to perform the specific functions for STL. Your personal data may be transferred, stored and processed in Hong Kong or any other jurisdictions where STL consider appropriate or where a third party contractor provides STL services.

Accuracy of Personal Data

STL will take reasonable steps to ensure that personal data is accurate having regard to the purpose(s) for which the personal data is provided or to be used. Where there are reasonable grounds for believing that personal data is inaccurate, STL shall take all reasonable steps to ensure that the data is not used for that purpose(s) unless and until those grounds cease to be applicable to the data, whether by rectification of the data or otherwise. Where it is practicable in all the circumstances of the case to know that personal data disclosed to a third party is materially inaccurate having regard to the purpose(s) for which the data is provided or to be used by the party and the data is inaccurate at the time of such disclosure, STL shall take reasonable steps to ensure that the third party is informed that the data is inaccurate and is provided with such particulars as will enable the third party to rectify the data having regard to that purpose(s).

Notwithstanding the foregoing, STL does not assume responsibility for confirming the ongoing accuracy of your personal data. If any of your personal data that we retain is inaccurate, you may request correction of the data as described below.

Promotional Activities and Direct Marketing

STL may further use your personal data for promotional and marketing purposes including but not limited to sending you promotional materials and carrying out direct marketing in relation to its services. For the purpose of direct marketing, STL may provide your personal data to various direct marketing agents.

Notwithstanding the foregoing, STL shall obtain your written consent before using or providing your personal data for the purposes as set out in this section. You may withdraw any such consent at any time by written notice to STL and STL shall cease to use or provide your personal data for direct marketing purposes.


Unless you request STL to dispose of all personal data provided by you, you acknowledge that STL may retain all such personal data and continue to deliver to you marketing information. You further acknowledge and agree that your personal data may be stored in and/or at a place outside of Hong Kong as STL considers appropriate.

STL will ensure that your personal data is not kept longer than is necessary to fulfil the purpose(s) for which the data is provided after which it will be destroyed. If STL engages a data processor, whether within or outside Hong Kong, to process personal data on its behalf, STL shall adopt contractual or other means to prevent any personal data transferred to the data processor from being kept longer than is necessary for processing the data.

Disclosure of Personal Data

STL may share and/or disclose your personal data to its affiliates, suppliers, service partners and financial institutions (within or outside of Hong Kong including countries with a lower level of data protection than that afforded in Hong Kong) for the performance and compliance obligations of any contracts entered with them or you. STL may also disclose or transfer your personal data to third party service providers, agents, contractors, advisers, website analytics service providers and data processors (within or outside of Hong Kong including countries with a lower level of data protection than that afforded in Hong Kong) who provides technical, administrative, telecommunication, legal, accounting or other services to STL in connection with its business operation and for the purposes as set out in this Privacy Statement. STL will adopt contractual or other means to ensure protection of the personal data as may be disclosed and/or transferred to such third parties.

STL may, as a result of a sale, merger, change in control, transfer of assets, reorganization or liquidation, transfer, sell or assign your personal data to third parties involved in such transaction. STL may also disclose your personal data when required by relevant laws or by order of the court or as requested by law enforcement authorities to assist with proceedings or investigations.

Security of Personal Data

STL undertake to use it best endeavours to ensure the security and confidentiality of the personal data collected. STL will take all practicable steps and maintain physical, electronic and procedural safeguards to protect all personal data against unauthorized or accidental access, processing, erasure, loss or use. STL limit access to your personal data to those employees, agents, contractors and other third parties strictly on a need-to-know basis and they will only process your personal data on our instructions and subject to a duty of confidentiality.

Notwithstanding the foregoing, you acknowledge there may be certain security, corruption, transmission error and other risks associated with using open networks such as the internet and electronic communications. STL cannot guarantee the security or confidentiality of any material or communication transmitted via such open networks and you hereby agree to assume all such risks. You further agree to be responsible for the data security of the systems used to access this Websites and/or services.

Users’ Rights

Pursuant to the Personal Data (Privacy) Ordinance, you are entitled to:-

  1. check whether STL holds personal data about you;
  2. access your personal data with STL;
  3. require STL to correct any inaccurate date;
  4. request deletion of your personal data if STL no longer have a lawful ground for use;
  5. object to sharing of your personal data;
  6. withdraw your consent if the processing is based on consent; and
  7. ascertain STL’s policies and practices in regards to collecting and processing of personal data.

If you wish to exercise any of the above rights, opt out of any promotional or marketing communications and/or raise any questions or complaints, please contact STL in writing as follows:-

Data control Officer
Strategic Transactions Limited
Address: Unit 405, Wai Wah Commercial Building, 6 Wilmer Street, Sai Yin Pun, Hong Kong
Email: [email protected]

STL reserves the right to charge a reasonable fee for processing a data access request and to refuse any unreasonable requests.

For the avoidance of doubt, your option not to receive promotional and marketing communications shall not preclude STL from corresponding with you regarding your existing relationship with STL.


STL shall exercise reasonable endeavours to ensure that the personal data provided by you shall be kept confidential and be placed in a secure location. Your personal data will not be disclosed to any third party except when required by law or where you have provided your consent or where it is necessary for STL.

Third Party Websites

The Website may contain links to external websites operated by third parties for your reference and convenience. STL has no control over the contents of these third party websites or their privacy policies. You should therefore review the privacy policies applicable to these third party websites.

Changes to this Privacy Statement

STL reserve the right to amend, vary, supplement and/or modify this Privacy Statement at any time and without prior notice. All changes to this Privacy Statement will be effectively upon posting on this Website.

Language and Governing Law

This Privacy Statement may be translated into other languages other than English. In the event of any inconsistency with the different language versions, the English version shall prevail.

This Privacy Statement is governed by and shall be construed in accordance with the laws of Hong Kong. You hereby agree to submit to the non-exclusive jurisdiction of the courts of Hong Kong.

If you have any questions on or require further information about this Privacy Statement, please do not hesitate to contact our Operations Manager – Ms. Tatiana Prokofeva ([email protected]).