Privacy Policy

Harvest Global recognizes the importance of protecting your personal and financial information when you visit our website ("Website"). The following information is designed to help you understand the information collection practices at this Website.

By visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use this Website. Please review the Terms and Conditions to learn of other terms and conditions applicable to your use of this Website.

Changes to this Privacy Policy

Harvest Global reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. We suggest that you review this Privacy Policy periodically for changes. The current version of this Privacy Policy can be accessed from the link on our homepage, at the bottom of our Website pages.

With respect to any expansion of the purposes of using your personally identifiable information received by us from the purposes as stated in this Privacy Policy, prior notice will be given to you and you have the right to decline acceptance of such expansion however in such circumstances our provision of continuing services to you may be limited.

Information Collection and Use

Methods of Information Collection

We may receive personally identifiable information you submit to or through our Website. Failure to provide such personally identifiable information may result in Harvest Global being unable to provide you with the services or information requested.

Separately we use "cookies" to collect and store information about your internet connection when you visit our Website. Cookies or other technology help us to provide customized services and information. "Cookies" are small files placed on your hard drive. Each website that you visit can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Website. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

Information Collected and Purpose of Information Collection

The types of personally identifiable information that may be collected at our Website include information you provided to us through the "Contact" page (e.g. your name and email address).

Separately the "cookies" may track and record information of your activities on our Website (including user's preference and behaviour, navigation on the Website, logged-on identity, etc.). When you are navigating our Website, we record your IP address.

Opt-out

If you would prefer not to accept cookies from us, you may set your browser accordingly. If you choose to disable cookies in your browser, you may not be able to access all pages on our Website.

Use of Personally Identifiable Information

The personally identifiable information you submit to or through our Website is used only for responding to your inquiry sent to us, for business administration, business reporting and statistical analysis purposes, for the provision of information on Harvest Global products and services to you, for servicing your account, that are set out at the section “Information Collected and Purpose of Information Collection” and for other directly related purposes (the "Purposes"). Your personally identifiable information may also be used for purposes set out in the sections below headed "Aggregate Information", "Affiliates and Service Providers", "Compliance with Laws", "E-mail and Marketing" and "Business Transfers".

We will not sell, share, rent or otherwise disclose or transfer your personally identifiable information to others for monetary gains.

With respect to your information collected through cookies, we will use such information to assess how and when pages in our Website are visited, what our users' technology preferences are (such as what type of video player they use), whether our Website is functioning properly and for systems, trouble shooting, administrative and reporting purposes.

Additionally, you may encounter cookies or other similar devices on our Website that are placed by third party website tracking companies. In such circumstances the purpose and means of collection and retention policy of your personal identifiable information is the same as stated in this Privacy Policy and such information will not be transferred to any third parties except as provided under this Privacy Policy.

Aggregate Information: We generally record certain usage information, such as the number and frequency of visitors to our Website. This information may include the websites that you access immediately before and after your visit to our Website, the Internet browser you are using and your IP address. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.

We may also disclose details about the general use of our Website to third parties e.g. to demonstrate patterns of use to advertisers and other business partners.  Information we pass on will not include any personal information by which you may be identified.

Retention Period: Your personally identifiable information will be retained by us for a period of two (2) years after you last accessed the Website, or we have last corresponded with you and your personally identifiable information will be erased after such retention period.

Privacy Preferences: The Website may contain information, including P3P privacy policies ("Privacy Preference Information"), intended to work with your selected privacy preferences. While we have tried to conform such Privacy Preference Information included within the Website to this full-text Privacy Policy, this Privacy Policy is the definitive statement of privacy policies and practices for the Website.

Affiliates and Service Providers: We may provide your personally identifiable information to our Affiliates and other third party service providers (including information technology service providers) for the Purposes. The third party service provider will not use your personally identifiable information for any direct marketing purpose. By disclosing your personally identifiable information to us via our Website, you consent to our disclosing of your personally identifiable information to such parties both in your country of residence and outside your country of residence. These persons may have access to the personally identifiable information you submit through our Website, but only for the purpose of performing their duties specified in this paragraph. These persons may not use your personally identifiable information for any purpose other than those stated above.

Compliance with Laws: Except as otherwise provided in this Privacy Policy, Harvest Global does not automatically collect personally identifiable information from visitors to our Website, except to the extent we are required to do so pursuant to any law or regulation binding on us. We will (and you authorize us to) disclose your personally identifiable information if we are required to make such a disclosure under applicable law or regulation, or where requested to do so by the police or by regulatory bodies, or where we wish to do so in relation to any suspected misuse by you of our Website, or of any of our Website services.

E-mail and Marketing: You acknowledge and consent that we and/or our Affiliates may use your personally identifiable information provided to or obtained by us through the Website as referred to above for purposes of direct marketing in relation to our investment/financial products or services. If you would like us to stop sending direct marketing to you, you may do so, free of charge, by selecting the unsubscribe facility in any email or by writing to us at the address set out in the "Contact Us" section of this Privacy Policy. Harvest Global will not send you e-mail messages without first receiving your consent, unless it relates to responding to your inquiry or unless you have consented to receiving electronic delivery of documents as part of our E-Delivery service. It is our policy to include instructions for unsubscribing from these consent-based programs. We recommend that you do not send us any individual personal information via nonsecure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure.

Harvest Global does not sell its customers' e-mail addresses, nor will we provide your personally identifiable information to third parties or our Affiliates for their marketing purposes without your consent. It is only voluntary for you to provide your personally identifiable information for marketing purposes. As a matter of policy, Harvest Global generally does not transfer any of your personally identifiable information to any third parties or its affiliates for marketing purposes and even if it does, it will only do so with your prior written consent.

Business Transfers: If the business, stock or assets of Harvest Global are acquired or merged with another business entity, we will share all or some of your information (including your personally identifiable information) with this other entity to continue to provide services to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, it will inform you beforehand and you may decline such use at that time.

For Hong Kong residents – your rights under PDPO: Under and in accordance with the terms of the Personal Data (Privacy) Ordinance ("PDPO") of Hong Kong and codes and guidelines issued pursuant thereto, any individual:

(i) may check whether Harvest Global holds personally identifiable information about him/her and may request access to such information;

(ii) may request Harvest Global to correct any personally identifiable information relating to him/her which is inaccurate;

(iii) may request Harvest Global to specify its policies and practices in relation to personally identifiable information and to be informed of the kind of personally identifiable information held by Harvest Global; and

(iv) may object to the use of his/her personally identifiable information for marketing purposes; Harvest Global will not use his/her personally identifiable information for these purposes if he/she communicates his/her objection to Harvest Global.

In accordance with the terms of PDPO, Harvest Global has the right to charge a reasonable fee for the processing of any request for access or correction mentioned above.

The person to whom requests for (i) access to or correction of personally identifiable information or (ii) information regarding policies and practices and kinds of information held by Harvest Global should be sent is our Data Protection Officer. Contact details of this Officer are set out below in the section headed "Contact Us".

Nothing in this Privacy Policy shall limit your rights of under the PDPO.

Security

Harvest Global protects your personally identifiable information when you visit our Website by requiring the use of a browser software program that supports industry standard SSL encryption with 128-bit key lengths. The "128-bit" designation refers to the length of the key used to encrypt the data being transmitted, with a longer key representing a higher level of security.

Harvest Global endeavours to prevent unauthorised disclosures of your personal information by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority.

Contact Us

For more information on Harvest Global, please do not hesitate to contact us:

Data Protection Officer 
Harvest Global Investments Limited 
31/F One Exchange Square 
8 Connaught Place
Central 
Hong Kong

 The General Data Protection Regulation (“GDPR”)

 This Privacy Policy explains, where the relevant requirements of GDPR applies, how we use the personal information that Harvest collects or generates both in relation to this website and our products and services.

 

1. BACKGROUND

1.1 Harvest Global Investments Limited with its registered office at  31/F One Exchange Square, 8 Connaught Place, Central, Hong Kongand other companies in the Harvest group collect and use certain Personal Data. Harvest is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.

1.2 At Harvest we respect the privacy of our clients and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by Harvest in the course of carrying on commercial activities.

1.3 We use the following definitions in this Privacy Policy:

“Harvest”, “we or “us” means Harvest and other companies in the Harvest group.

 

“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Harvest (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Harvest or any other person in respect of an individual.

 

2.THE PRODUCTS AND SERVICES WE PROVIDE

2.1 This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:

1. Information we receive through our websites ("Harvest Websites");
2. Information we receive through our products ("Harvest Products");
3. Information we receive through our support, mobile security solution or cloud-based services ("Harvest Services").

3.THE TYPES OF PERSONAL DATA WE COLLECT

3.1 Many of the services offered by Harvest require us to obtain Personal Data about you in order to perform the services we have been engaged to provide. In relation to each of the services described at paragraph 2.1 above, we will collect and process the following Personal Data about you:

• Information that you provide to Harvest. This includes information about you that you provide to us. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list):

 

• basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);

• any information that you choose to share on any Harvest internet forums which may be considered Personal Data.

 

• Information that we collect or generate about you. This includes (by way of non-exhaustive list):

 

• a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;

• through our cloud security services, traffic and security reports that include information on the internet usage of the organisation’s computer users (e.g. what websites were visited by each user, any documents downloaded, security incidents, prevention measures taken by the gateway, etc.); and

• activity data relating to the use of protected documents, such as altering a document’s permissions and information regarding the individual that performed the activity.

• Cookies.

• When you visit Harvest Websites, cookies are used to collect technical information about the services that you use, and how you use them.

• Anonymized data

• In addition to the categories of Personal Data described above, Harvest will also process further anonymized information and data that is not processed by reference to a specific individual.

4. HOW WE USE YOUR INFORMATION

4.1 Your Personal Data may be stored and processed by us in the following ways and for the following purposes:

• for ongoing review and improvement of the information provided on Harvest Websites to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;

• to allow you to use and access the functionality provided by the Harvest Products;

• to assess your application for Harvest Products, where applicable;

• to set up customers to use Harvest Products;

• to conduct analysis required to detect malicious data and understand how this may affect your IT system;

• for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;

• to understand feedback on Harvest Products and to help provide more information on the use of those products and services quickly and easily;

• to communicate with you in order to provide you with services or information about Harvest and Harvest Products;

• for in-depth threat analysis;

• to understand your needs and interests;

• for the management and administration of our business;

• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or

• for the administration and maintenance of databases storing Personal Data.

 

4.2 However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

• we need to do so in order to perform its contractual obligations with its customers;

• we have obtained your consent;

• we have legal and regulatory obligations that we have to discharge;

• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

• the use of your Personal Data as described is necessary for our legitimate business interests, such as: 

    - allowing us to effectively and efficiently manage and administer the operation of our business;
    - maintaining compliance with internal policies and procedures;
    - monitoring the use of our copyrighted materials;
    - enabling quick and easy access to information on Harvest Products;
    - offering optimal, up-to-date security solutions for mobile devices and IT systems; and
    - obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

 

4.3 We will take steps to ensure that the Personal Data is accessed only by employees of Harvest that have a need to do so for the purposes described in this Privacy Policy.

5. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

5.1 We may share your Personal Data within the Harvest group of companies for the purposes described above.

5.2 We may also share your Personal Data outside of the Harvest group for the following purposes:

• with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased the Harvest product(s). Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;

• with third party agents and contractors for the purposes of providing services to us (for example, Harvest’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;

• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;

• if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and

• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.

6. INTERNATIONAL TRANSFERS OF PERSONAL DATA

6.1 Harvest is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.

6.2 Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:

• the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data (Israel is an approved country);

• the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;

• where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or

• in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.

6.3 You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 11 below.

7. HOW WE SAFEGUARD YOUR INFORMATION

7.1 We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

7.2 As a condition of employment, Harvest employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Harvest employee is prohibited and may result in disciplinary measures.

7.3 When you contact a Harvest employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.

8. HOW LONG WE KEEP YOUR PERSONAL DATA

8.1 How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose for which we are using it – Harvest will need to keep the data for as long as is necessary for that purpose; and

• legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.

9. YOUR RIGHTS

9.1 In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;

• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;

• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Harvest;

• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;

• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;

• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and

• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

9.2 You can exercise your rights by contacting us using the details listed in paragraph 11 below.

10. DESIGNATED REPRESENTATIVE

10.1 Harvest’s registered office may be contacted using the following contact information:

            Address:              31/F One Exchange Square, 8 Connaught Place, Central, Hong Kong

                                        

            Email Address:    HGICompliance@hk.jsfund.cn

 

10.2 Harvest’s designated representative in the EU may be contacted using the following contact information:

            Address:             Level 30, The Leadenhall Building, 122 Leadenhall Street, London UK EC3V 4AB

                                        

            Email Address:    HGICompliance@hk.jsfund.cn

 

11. QUESTIONS AND CONCERNS

11.1 If you have any questions or concerns about Harvest’s handling of your Personal Data, or about this Policy, please contact our Privacy Officer using the following contact information:

            Address:              31/F One Exchange Square, 8 Connaught Place, Central, Hong Kong

 

        Email Address:       HGICompliance@hk.jsfund.cn

We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Harvests’ Privacy Officer will provide you with the contact information for that regulator.

 

Dated: May 2018

© 2018 Harvest Global Investments Limited. All rights reserved.