Privacy Policy
As a client of Webull (the “Client”), it is necessary from time to time for the Client to supply his/her personal data (“Personal Data”), within the meaning ascribed in the Personal Data (Privacy) Ordinance (Chapter 486 of the laws of Hong Kong) (the “Privacy Ordinance”) to Webull or Affiliates when opening or maintenance of accounts, or in the establishment, continuation or provision of investment, dealing or related services.
Failure to supply Personal Data may result in Webull being unable to open or maintain accounts or establish, continue or provide investment, dealing or related services.
Personal Data may also be collected in the ordinary course of continuation of the business relationship with Webull and/or Affiliates.
Subject to the provisions of the Privacy Ordinance, any Personal Data may be used for the following purposes:
the daily operation of the services provided to the Client;
conducting credit and/or AML checks;
ensuring ongoing credit worthiness and AML risk level of the Client;
marketing investment, dealing or related services or products (please see further details in paragraph 8 below);
supporting any statements made in any documents in connection with the services of Webull;
assisting other relevant parties, professionals, institutions or relevant regulatory authorities to verify certain facts in connection with the services of Webull;
meeting the requirements to make disclosures under the requirements of any laws and/or regulations binding on Webull;
forming part of the records of the recipient of the data as to the business carried on by it; and
any other purposes relating to or incidental to any of the above.
Webull will keep Personal Data confidential, but Webull may provide Personal Data to the following persons in furtherance of the purposes set in the above paragraph 4:
any agent or third party service provider who provides services to Webull in connection with the operation of its business;
an appropriate person under a duty of confidentiality to Webull including any Affiliate which has undertaken to keep such information confidential;
any person or institution with which the Client has or proposes to have dealings;
credit reference agencies and debt collection agencies (in the event of default payment);
any regulatory authorities or exchanges which relate to or govern any business of Webull and any Affiliate;
any assignee, transferee, delegate, successor or person to whom the account of the Client is transferred and the authorized person of the Client; and
any of Webull’s actual or proposed assignee or participant or sub participant or transferee.
The Personal Data may be transferred to any place outside Hong Kong, whether for the processing, holding or use of such data outside Hong Kong, and also to service providers which offer services to any Affiliate in connection with the operation of its business.
To the extent permitted by law, the Personal Data collected by Webull from time to time may be used and disclosed in accordance with the Data Privacy Policy.
Use of Personal Data in Direct Marketing
Webull intends to use your Personal Data in direct marketing and we require your consent (which includes an indication of no objection) before we can use your Personal Data for this purpose. Your provision for this purpose is voluntary. In this connection, please note that:
your name, contact details, products and services portfolio information, transaction pattern and behavior, financial background and demographic data held by Webull from time to time (“Marketing Personal Data”) may be used by Webull in direct marketing.
the following classes of services, products and subjects may be marketed:
financial, insurance, securities, commodities, investment and related services and products and facilities;
reward, loyalty or privileges programmes in relation to the class of marketing subjects as referred to in paragraph 8.b.i above;
services and products offered by Webull’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) in relation to the class of marketing subjects as referred to in paragraph 8.b.i above; and
donations and contributions for charitable and/or non-profit marking purposes;
the above services, products and subjects may be provided or (in the case of donations and contributions) solicited by Webull and/or:
any Affiliate;
third party financial institutions, insurers, securities, commodities and investment services providers;
third party reward, loyalty, co-branding or privileges programme providers;
co-branding partners of Webull (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 organization;
In addition to marketing the above services, products and subjects itself, Webull also intends to provide the Personal Data described in paragraph 8.a above, whether such provision is for gain or not, to all or any of the persons described in paragraph 8.c above for use by them in marketing those services, products and subjects described in paragraph 8.b above (in respect of which Webull may or may not be remunerated), and Webull requires your written consent (which includes an indication of no objection) for those purposes;
Webull may not use your Marketing Personal Data for direct marketing without your consent. Please indicate your consent when signing Account Opening Form or similar document.If you give your consent but subsequently change your mind and no longer wish Webull to use or provide to other persons your Marketing Personal Data for use in direct marketing as described above, you may exercise your opt-out right by notifying Webull in writing addressed to the Data Protection Officer in paragraph 11 of this policy.
Please note however that the right to make such a request is not applicable to you if the direct marketing is addressed to you in your capacity as a representative of a company or business and is not sent to you in your individual or personal capacity.
Processing of Personal Data as part of the Stock Connect Northbound Trading
You acknowledge and agree that in providing our Stock Connect Northbound Trading Service to you, we will be required to:
tag each of your orders submitted to the CSC with a Broker-to-Client Assigned Number ("BCAN") that is unique to you or the BCAN that is assigned to your joint account with us, as appropriate; and
provide to the Exchange your assigned BCAN and such identification information (“Client Identification Data” or “CID”) relating to you as the Exchange may request from time to time under the Rules of the Exchange.
Without limitation to any notification we have given you or consent we have obtained from you in respect of the processing of your personal data in connection with your account and our services to you, you acknowledge and agree that we may collect, store, use, disclose and transfer personal data relating to you as required as part of our Stock Connect Northbound Trading Service, including as follows:
to disclose and transfer your BCAN and CID to the Exchange and the relevant SEHK Subsidiaries from time to time, including by indicating your BCAN when inputting a China Connect Order into the CSC, which will be further routed to the relevant China Connect Market Operator on a real-time basis;
to allow each of the Exchange and the relevant SEHK Subsidiaries to:
collect, use and store your BCAN, CID and any consolidated, validated and mapped BCANs and CID information provided by the relevant China Connect Clearing House (in the case of storage, by any of them or via HKEX) for market surveillance and monitoring purposes and enforcement of the Rules of the Exchange;
transfer such information to the relevant China Connect Market Operator (directly or through the relevant China Connect Clearing House) from time to time for the purposes set out in (c) and (d) below; and
disclose such information to the relevant regulators and law enforcement agencies in Hong Kong so as to facilitate the performance of their statutory functions with respect to the Hong Kong financial markets;
to allow the relevant China Connect Clearing House to:
collect, use and store your BCAN and CID to facilitate the consolidation and validation of BCANs and CID and the mapping of BCANs and CID with its investor identification database, and provide such consolidated, validated and mapped BCANs and CID information to the relevant China Connect Market Operator, the Exchange and the relevant SEHK Subsidiary;
use your BCAN and CID for the performance of its regulatory functions of securities account management;;
disclose such information to the Mainland regulatory authorities and law enforcement agencies having jurisdiction over it so as to facilitate the performance of their regulatory, surveillance and enforcement functions with respect to the Mainland financial markets; and
to allow the relevant China Connect Market Operator to:
collect, use and store your BCAN and CID to facilitate their surveillance and monitoring of securities trading on the relevant China Connect Market through the use of the China Connect Service and enforcement of the rules of the relevant China Connect Market Operator; and;
disclose such information to the Mainland regulatory authorities and law enforcement agencies so as to facilitate the performance of their regulatory, surveillance and enforcement functions with respect to the Mainland financial markets.
By instructing us in respect of any transaction relating to China Connect Securities, you acknowledge and agree that we may use your personal data for the purposes of complying with the requirements of the Exchange and its rules as in force from time to time in connection with the Stock Connect Northbound Trading. You also acknowledge that despite any subsequent purported withdrawal of consent by you, your personal data may continue to be stored, used, disclosed, transferred and otherwise processed for the above purposes, whether before or after such purported withdrawal of consent.
Consequences of failing to provide Personal Data or Consent
Failure to provide us with your personal data or consent as described above may mean that we will not, or no longer be able, as the case may be, to carry out your trading instructions or provide you with our Stock Connect Northbound Trading Service.
In accordance with the terms of the Privacy Ordinance, any individual has the right to:
check whether Webull holds data about him/her and access to such data;
require Webull to correct any data relating to him/her which is inaccurate;
ascertain Webull’s policies and practices in relation to data and be informed of the kind of personal data held by Webull; and
in relation to customer credit, request to be informed which items of Personal 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.
In accordance with the Privacy Ordinance, Webull has the right to charge a reasonable fee for the processing of any data access request. All requests for access to data or correction of data (when client considers that his/her Personal Data, supplied by the Webull following a data access request, are inaccurate) or for information regarding policies and practices and kinds of data held or for exercising your opt out right relating to direct marketing should be addressed as follows: Suites 2509-12, 25/F, Tower 6, The Gateway, Harbour City, Kowloon, Hong Kong.