Data Privacy

Habib Bank AG Zurich will strive at all times to ensure that your data is kept confidential and secure, occasionally we may collect personal data using our website and when you voluntarily supply your personal data to us. We may use your personal data for sending you details of our products, services and other marketing materials which we think may be of interest to you. We may also invite you to participate in market research, surveys and other similar activities.

If we do ask you to provide your personal data, we will specify the purpose it was collected at the time of collection. If we do send promotional emails and marketing information to you, you will always be given an opportunity to opt out.

Personal Data Collection

Habib Bank AG Zurich will only collect data for provision of financial services or related products;

• we will take all practical steps to ensure that your personal data is accurate
• your personal data will be used for the purpose for which the data was collected
• your personal data will be protected against unauthorised or accidental access, processing or erasure, and
• you have the right to access and correct your personal data held by us. Your request for access or correction will be dealt with in accordance with the Ordinance

Your personal data is classified as confidential and can only be disclosed by us where permitted by, or pursuant to, the operation of the Personal Data (Privacy) Ordinance or where we are otherwise legally compelled to do so.

Please refer to Habib Bank AG Zurich’s Circular to Customers and Other Individuals relating to the Personal Data (Privacy) Ordinance for detailed information about how we handle your personal data.

Warranty

While we have taken care in preparing the content and information on our website, such content and information is provided “as is” without warranty of any kind, whether express or implied. In particular, no warranty about non-infringement, security, accuracy, fitness for a particular purpose or absence of computer viruses is given in connection with such content and information.

Linked Websites

Neither we, nor any member of the Habib Bank AG Zurich Group are responsible for the contents available on or the setup of any other websites linked to our website (“external websites”). Your access to, and use of an external website is at your own risk and subject to any terms and conditions applicable to such access and use.

Internet Communications

Messages sent over the Internet cannot be guaranteed to be completely secure. We are not responsible for any loss or damage you may suffer or incur if you send a message to us, or if we send a message to you at your request, over the Internet. We are not responsible in any way for direct, indirect, special or consequential damages arising from, or in connection with, the use of our website. Due to the nature of the Internet, communications over the Internet may be subject to interruptions, transmission blackouts, delayed transmissions or incorrect data transmissions.

Information Usage

Products and services referred to in this website are offered only in jurisdictions where and when they may be lawfully offered by the Bank. The materials on this website are not intended for use by persons located in, or resident in, jurisdictions that restrict the distribution of this material by the Bank. These pages should not be regarded as an offer or solicitation to sell products or make transactions in any jurisdiction to any person to whom it is unlawful to make such an invitation or solicitation in such jurisdictions. Persons accessing these pages are required to inform themselves about, and observe any relevant restrictions.

The Bank may, from time to time, specify the type and scope of its e-banking services. The Bank reserves the right to modify, expand or reduce the scope of these e-banking services without giving prior notice to the Customer.

Please remember these recommendations are made to protect your interests.

To login to your account, always type: www.hbzhongkong.com

Do not send any confidential information including account numbers, passwords, PINs, or signed payment instructions via regular email because emails are not encrypted and therefore, subject to being intercepted and read by third-parties.

Please check your monthly financial statements and report any discrepancies and/or unusual account activity.

Miscellaneous Additional Security Tips

• Do not install applications on your mobile handsets from untrusted, unsecured, or unverified sources
• Do not use any jailbroken iPhone or rooted Android handset which may have security loopholes and unpredictable consequences
• Do not act on an SMS containing a one-time password that you have not requested and review your existing payee list for any unauthorised additions
• Customers are advised against auto-forwarding/forwarding the SMS one-time password received to another device that is used for accessing internet banking
• Customers are advised that they will be wholly responsible in respect of properly installing and updating other mobile devices’ apps and operating systems of mobile platforms
• Customers are advised to ensure that any USB drive containing HBZSecure Key is removed from the relevant devices and stored securely after conclusion of related transactions
• Business Customers are strongly advised to exercise dual controls/authorizations at the time of submission of requests for funds transfers
• The Customers, and where applicable, users shall be fully responsible for any accidental or unauthorised disclosure of any User Name, Password, Identifier and/or Security Code to any other persons and shall bear the risk of any User Name, Password, Identifier, Security Device or Security Code being used by unauthorised persons or for unauthorised purposes. Subject to above, and if, in the reasonable opinion of the Bank, there is no negligence, fraud or fault on the part of the Customer and, where applicable, the Authorised e-banking Users, the Customers and the Authorised e-banking Users shall not be liable for loss or misplacement of funds caused by unauthorised transactions conducted through the use of the Services as a result of :
  – a computer crime not prevented by the security system of the Bank
  – a human or system error of the Bank
  – a missed, or misdirected payment caused by the Bank

HBZ Mobile Application Security Tips

• Do not share your devices (mobile handset, tablet, computer, etc.) or internet banking/mobile banking username(s)/password(s) with others
• Only use your own devices to login to internet banking or mobile banking; after the login, do not leave your devices unattended
• Only download the HBZ Mobile Banking App from official application stores
• Whenever you try to login to internet banking or mobile banking, do not use any devices in which you have awareness or suspicion of security loopholes
• Do not download or install any software or application onto your devices if you do not trust or have no clear knowledge/understanding of the source
• Only use reliable and trusted Wi-Fi networks and TMDS (Telephone Mobile Data Service) and whenever possible, ensure security protection in this regard is available
• Always logout when you are finished or away from your device, no matter for how long; setup passcode lock and auto-lock to impede unauthorised access to your devices
• Discontinue WIFI/TMDS connection or Bluetooth when you are not using it
• Do not store your username(s) or password(s) in your devices
• Ensure the latest anti-virus and anti-spy software is in place in your devices
• Do not use untrusted virtual keyboards when you are using any mobile banking service at any time
• Ensure that updates are downloaded from trusted and reliable sources and installed properly on your devices
• Always contact us for clarification whenever you are not 100% sure about how to properly use any part of, or any function, within HBZ Mobile Banking App
• If your devices used for mobile banking/internet banking are lost or stolen or you have knowledge or suspicion of unauthorised access, contact us immediately and instruct us to suspend such kind of e-banking service until your further notice on the contrary; in addition, review the banking transaction history immediately
• Erase all the data in your old devices before giving them to others
• Do not use any jailbroken handsets which may have security loopholes and unpredictable consequences

Habib Bank Zurich (Hong Kong) Limited, (the “Bank”)

Circulars to Customers and Other Individuals relating to the Personal Data (Privacy) Ordinance (the “Ordinance”)

From time to time, it is necessary for customers and various other individuals (including without limitations applicants for banking/financial services and credit facilities, sureties and persons providing security or guarantee for credit facilities, shareholders, directors, officers and managers of corporate customers or sole proprietors or partners or applicants and other contractual counterparties) (collectively “data subjects”) to supply the Bank with data in connection with the opening or continuation of accounts and the establishment or continuation of banking/credit facilities or provision of banking/financial services.

Failure to supply such data may result in the Bank being unable to open or continue accounts, establish or continue banking/credit facilities or provide banking/financial services.

It is also the case that data is collected from data subjects in the ordinary course of the continuation of the banking relationship, for example, when data subjects write cheques, deposit money, apply for credit or carry out card transactions.

The purposes for which data relating to a data subjects may be used are as follows:

• the processing of applications for banking/financial services and credit facilities
• the daily operation of the services and credit facilities provided to data subjects
• conducting credit checks at the time of application for credit and at the time of regular or special reviews which normally will take place one or more times each year
• creating and maintaining the Bank’s credit scoring models
• provision of references (status enquiries), assisting other financial institutions on conducting credit checks and collecting debts
• ensuring ongoing credit worthiness of data subjects
• designing financial services or related products for data subjects’ use
• marketing services, products and other subjects in respect of which the Bank may or may not be remunerated (please see further details in paragraph (6) below)
• determining the amount of indebtedness owed to or by data subjects
• the enforcement of data subjects’ obligations, including without limitation the collection of amounts outstanding from data subjects and those providing security for data subjects’ obligations complying with the obligations, requirements or arrangements for disclosing and using data that apply to the Bank or a Bank Group Company or that it is expected to comply according to:
  – any law binding or applying to it within or outside Hong Kong existing currently and in the future or any court order being enforceable on it
  – any guidelines or guidance 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
  – 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 that is assumed by or imposed on the Bank or a Bank 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
• complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Group of the Bank and/or any other use of data and information in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities
• enabling an actual or proposed assignee of the Bank or a Bank Group Company, or participant or sub-participant of the rights of the Bank or those of a Bank Group Company in respect of the data subjects to evaluate the transactions intended to be the subject of the assignment, participation or sub-participation
• exchanging information with merchants who accept credit cards issued by the Bank and entities with whom the Bank provides affinity/co-branded /private label credit card services (each merchant or an affinity entity)
• verifying data subjects’ identities with any card acquirer of a merchant in connection with any card transactions
• for the purpose of risk management of the group of the Bank
• maintaining a credit history or otherwise, a record of data subjects (whether or not there exists any relationship between data subjects and the Bank) for present and future reference, and purposes relating thereto

Data held by the Bank relating to data subjects will be kept confidential but the Bank may provide such information to the following parties, for the purpose set out in paragraph (4).

• any Bank Group Company, agent, contractor or third-party service provider who provides administrative, telecommunications, computer, payment, securities clearing or other services to the Bank or a Bank Group Company in connection with the operation of its business
• any other person under a duty of confidentiality to the Bank or a Bank Group Company which has undertaken to keep such information confidential
• the drawee bank providing a copy of a paid cheque (which may contain information about the payee) to the drawer
• a person making any payment into the data subjects’ accounts (by providing a copy of a deposit confirmation slip which may contain the name of the data subject)
• credit reference agencies, and in the event of default, to debt collection agencies
• any persons to whom the Bank or a Bank Group Company is under an obligation or otherwise required to make disclosure under the requirements of any law, regulation or court order binding on or applying to the Bank or a Bank Group Company, or any disclosure under and for the purpose of any guidelines or guidance 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 with which the Bank or a Bank Group Company is expected to comply, or any disclosure pursuant to any contractual or other commitment of the Bank or a Bank Group Company 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, all of which may be within or outside Hong Kong and may be existing currently and in the future
• any actual or proposed assignee of the Bank or a Bank Group Company, or participant or sub-participant or transferee of the rights of the Bank or those of a Bank Group Company in respect of the data subjects

A merchant or an affinity entity which has undertaken to keep such data confidential, and:

• any Bank Group Company
• third-party financial institutions, insurers, credit card companies, securities and investment services providers
• third-party reward, loyalty, co-branding and privileges programme providers
• co-branding partners of the Bank and any Bank Group Company (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be)
• charitable or non-profit making organisations; and
• external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that the Bank engages for the purpose set out in paragraph (4)(ix)

The Bank may disclose data to any or all the parties stated above and may do so notwithstanding that the recipients in place of business is outside Hong Kong, including Mainland China, or that such information following disclosure will be collected, held, processed or used by such recipient in whole or part outside Hong Kong.

Use Of Data In Direct Marketing

The Bank uses, and/or intends to use, the data of a data subject in direct marketing and the Bank requires the consent of the data subjects (which includes an indication of no objection) for that purpose. In this connection, please note that:

• the name, contact details, products and services portfolio information, transaction pattern, behaviour, financial background and demographic data of a data subjects held by the Bank, from time to time, may be used by the Bank in direct marketing

The following classes of services, products and subjects may be marketed:

• financial, insurance, credit card, banking and related services and products
• reward, loyalty or privileges programmes and related services and products
• services and products offered by the Bank’s co-branding partners (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be) and
• donations and contributions for charitable and/or non-profit making purposes

The above services, products and subjects may be provided or (in the case of donations and contributions) solicited by the Bank and/or:

• any Bank Group Company
• third-party financial institutions, insurers, credit card companies, securities and investment services providers
• third-party reward, loyalty, co-branding or privileges programme providers
• co-branding partners of the Bank and any Bank Group Company (the names of such co-branding partners can be found in the application form(s) for the relevant services and products, as the case may be) and
• charitable or non-profit making organisations

In addition to marketing the above services, products and subjects themselves, the Bank also provides and/or, intends to provide, the data described in paragraph (6)(i) above to all or any of the persons described in paragraph (6)(iii) above for use by them in marketing those services, products and subjects, and the Bank requires written consent of the data subjects (which includes an indication of no objection) for that purpose.

The Bank may receive money or other property in return for providing the data to the other persons in paragraph (6)(iv) above and, when requesting the consent of the data subject or no objection as described in paragraph (6)(iv) above, the Bank will inform the data subjects if it will receive any money or other property in return for providing the data to the other persons. If data subjects does not wish the Bank to use or provide other persons to use their data for use in direct marketing as described above, the data subjects may, without charge, exercise his opt-out right by notifying the Bank.

With respect to data in connection with mortgages applied by data subjects (whether as borrowers, mortgagors or guarantors and whether in the data subjects’ sole name or in joint names with others) on or after 1 April 2011, the Bank may, on its own behalf and/or as agent, provide the following data relating to the data subject (including any update) to a credit reference agency:

• full name
• capacity in respect of each mortgage (as borrower, mortgagor or guarantor, and whether in the data subject’s sole name or in joint names with others)
• Hong Kong Identity Card Number or travel document number
• date of birth
• address
• mortgage account number in respect of each mortgage
• type of the facility in respect of each mortgage
• mortgage account status in respect of each mortgage (e.g., active, closed, write-off (other than due to a bankruptcy order), write-off due to a bankruptcy order) and
• if any, mortgage account closed date in respect of each mortgage

The credit reference agency will use the above data for the purpose of compiling a count of the number of mortgages, from time to time, held by data subjects with credit providers in Hong Kong, as borrowers, mortgagors or guarantors respectively and whether in the data subjects’ sole name or in joint names with others, for sharing in the consumer credit database of the credit reference agency by credit providers (subject to the requirements of the Code of Practice on Consumer Credit Data approved and issued under the Ordinance).

Under and in accordance with the terms of the Ordinance and the Code of Practice on Consumer Credit Data, data subjects has the right:

• to check whether the Bank holds data about them and access to such data
• to require the Bank to correct any data relating to them which is inaccurate
• to ascertain the Bank’s policies and practices in relation to data and to be informed of the kind of personal data held by the Bank
• to be informed on request which items of data are routinely disclosed to credit reference agencies or debt collection agencies, and be provided with further information to enable the making of an access and correction request to the relevant credit reference agency or debt collection agency; and
• in relation to any account data (including, for the avoidance of doubt, any account repayment data) which has been provided by the Bank to a credit reference agency, to instruct the Bank, upon termination of the account by full repayment, to make a request to the credit reference agency to delete such account data from its database, as long as the instruction is given within five years of termination and at no time was there any default of payment in relation to the account, lasting in excess of 60 days within five years immediately before account termination. Account repayment data, includes amount last due, amount of payment made during the last reporting period (being a period not exceeding 31 days immediately preceding the last contribution of account data by the Bank to a credit reference agency), remaining available credit or outstanding balance and default data (being amount past due and number of days past due, date of settlement of amount past due, and date of final settlement of amount in default lasting in excess of 60 days (if any))

In the event of any default of payment relating to an account, unless the amount in default is fully repaid or written off (other than due to a bankruptcy order) before the expiry of 60 days from the date such default occurred, the account repayment data (as defined in paragraph (8)(v) above) may be retained by the credit reference agency until the expiry of five years from the date of final settlement of the amount in default.

If any amount in an account is written off due to a bankruptcy order being made against a data subject, the account repayment data (as defined in paragraph (8)(v) above) may be retained by the credit reference agency, regardless of whether the account repayment data reveal any default of payment lasting in excess of 60 days, until the expiry of five years from the date of final settlement of the amount in default or the expiry of five years from the date of discharge from a bankruptcy as notified by data subjects with evidence to the credit reference agency, whichever is earlier.

The Bank may, from time to time, access the consumer credit data of data subjects held by a credit reference agency in the course of the consideration of any grant of consumer credit or the review or renewal of existing customer credit facilities granted to data subjects as a borrower or to another person, for whom data subjects propose to act as guarantor or for the purpose of the reasonable monitoring of the indebtedness of the data subject while there is currently a default by the data subject as borrower or as guarantor. In particular, the Bank may access the consumer credit data for the purpose of the review of the existing consumer credit facilities granted to assist the Bank in considering any of the following matters:

• an increase in the credit amount
• the curtailing of credit (including the cancellation of credit or a decrease in the credit amount), or
• the putting in place or the implementation of a scheme of arrangement with the individual customer

If data subjects wish to access the credit report obtained by the Bank from the credit reference agency, the Bank will advise the contact details of the relevant credit reference agency.

In accordance with the terms of the Ordinance, the Bank has the right to charge a reasonable fee for the processing of any data access request.

The person to whom, requests access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:

The Data Protection Officer,
Habib Bank Zurich (HK) Limited, Main Branch,
1701-05, Wing On House, 71, Des Voeux Road,
Central, Hong Kong.
Tel: +852 2906 1139 / 2906 1818

Nothing in this Circular shall limit the rights of data subjects under the Ordinance

This Circular shall be deemed an integral part of all contracts, agreements, credit facility letters, account mandates and other binding arrangements which the data subject has entered into, or intends to enter into with the Bank

In this Circular, the following terms shall have the following meanings:

Bank Group Company means any subsidiary of the Bank, any direct or indirect holding company of the Bank, any subsidiary of any such holding company or any of their related companies (that is such companies’ equity interest is held by any of the foregoing) including companies within the group of Habib Bank Zurich (Hong Kong) Limited; subsidiary and holding company bear the meanings under the Companies Ordinance (Cap.622)

For additional security tips please visit www.hkab.org.hk