Last updated May 2023
Sustainable Finance Initiative (“SFi”, “we”, “our”, “us”) is an investor-sponsored community with a mission to convene Asia’s leading family offices and modern wealth owners in the impact space to explore ways to accelerate Asia’s transition towards a sustainable finance hub. We are concerned about your personal data privacy and are committed to handling and protecting your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“Ordinance”). We know you share our concerns, and in the interest of letting you know how we protect the privacy and security of the personal data you provide to us, we provide you with information about our data protection practices and policies below.
If you wish to know more about the data protection practice of our impact education platform New Impact Society, please visit https://www.newimpactsociety.com/privacy-policy.
Personal data we collect from you
Under the Ordinance, personal data means information which relates to a living individual and can be used to identify that individual. It must also exist in a form which access to or processing of is practicable.
We may collect your personal data whether directly or indirectly, for example, when you:
apply to join our SFi’s community or membership;
register for / purchase tickets for our Impact Services;
request for and are contacted by us to provide you with the Impact Services;
visit our Websites;
contact us to provide questions, comments or enquire about our Impact Services by using our website’s enquiry form or by other means;
provide your consent and signup to receive our e-bulletins/newsletters by email.
We will ensure that your personal data is processed and handled in accordance with the Ordinance. In particular, we will keep your personal data on our records accurate and up-to-date. We will keep your personal data confidential and will not use or disclose or transfer the same for any other purposes without your consent unless such use or disclosure is required or permitted by law. We are equally committed to ensuring that all our staff members, subcontractors and agents uphold these obligations. Under the circumstances where you directly collect personal data from individuals and provide us with such data, you must (a) ensure that you have collected, handled and disclosed the personal data in compliance with the Ordinance; and (b) act in such ways which enables SFi to be in compliance with (and not breach any) applicable data privacy laws.
What type of personal data is collected from you?
The personal data we collect might include but is not limited to your personal data (i.e. name, address, landline telephone and mobile, email address, location), your business information (i.e. company name, countries your company operate in, job title, work email address), your background, investor type and field of interest in impact investing, and photos and videos submitted or uploaded by you or your organisation. We may also arrange for our videographers or photographers to take photos and videos of participants including you when you physically attend our activities, events, summits and exhibitions.
When you register for or purchase tickets to our Impact Services provided by us and/or our business partners through third party ticketing platforms (e.g. Eventbrite), we may receive from those platforms information you provided during your transactions for our record purposes. However, we do not collect or record any of your credit card and payment transaction details which are kept by third party payment processors engaged by those third-party ticketing platforms. For more information about the data protection practices of these third-party ticketing platforms or payment processors, please carefully review their terms and conditions and privacy policies.
Certain personal data may be necessary to our provision of Impact Services to you and if you fail to supply such data as requested, we may not be able to provide you with the same. Regarding your receipt of promotional information from us or our business partners or event sponsors in the industry of or have an interest in impact investing, please note that it is not obligatory for you to provide us with your contact details unless you wish to receive such promotional information.
We may use (including disclose or transfer) your personal data to:
assess, approve, open, maintain and manage your membership account or subscription with us and providing you with membership services
supply you with orders, our consulting or impact investment services and products and / or other subjects which you request and which we may offer to you from time to time
help us manage and operate our Impact Services
record your interest in our Impact Services and membership subscription
communicate with you by email, phone or other means regarding for example, your registration, purchases, enquiries, feedbacks or comments, or changes to our services
process your orders and purchases for our Impact Services and deliver to you the relevant tickets, including handling any refunds / transfers / cancellations
with your consent, send you newsletters, information and / or updates about products and service you have requested and that may be of interest to you, including but not limited to latest promotions and Impact Services
allow our business partners or event sponsors in the industry of or have an interest in impact investing to send you promotional information / updates on their impact investing products / services
process your job application which you have sent to us
audit or verify your enrollment, registration and attendance of our Impact Services
connect you with other impact investors, fund companies or investment firms for you to explore business collaboration opportunities
provide you with factual information of impact investing funds and ventures displayed by fund companies and investment firms
allow you to display your organisation’s products or goods to impact investors and family offices
to photograph, film or otherwise record your facial images / appearance/voice for release, publication, exhibition or reproduction of any and all recorded media (whether for commercial purpose or otherwise)
internally assessing our performance and improving our Impact Services offered to you
maintain your personal data in our internal database and conduct aggregated statistical analysis of the numbers of members
make disclosures when legally required by applicable laws, regulations or a court or tribunal order or as requested by any government, regulatory or law enforcement agency of the Hong Kong Special Administrative Region of the People’s Republic of China
establish, exercise or defend our legal rights, claims and defences and seek legal advice from our legal and professional advisors thereof
prevent or detect crime, or prevent, preclude or remedy (including punish) unlawful or seriously improper conduct, or dishonesty or malpractice, by any persons
for any other related or incidental purposes relating to the above, or any other purposes which we will inform you from time to time.
We will hold this personal data for as long as is necessary for the fulfillment of the purpose (including any directly related purpose) for which the data is or is to be used. If and when we are asked to remove personal data by an individual or organisation whose data we have recorded, we will endeavour to process the removal request within 2-3 working days of our receipt of the written request. If this personal data remains relevant to one or other service we are providing to the individual or organisation, we may be legally or commercially required to hold some information to fulfil the obligations to that service.
Do we use your personal data for promotion?
Subject to your consent, we will use your contact information (including your name and email address) to send you newsletters, latest information and / or updates about products and service you have requested and that may be of interest to you, including but not limited to our latest promotions and Impact Services.
Subject to your consent, we also intend to provide your contact information (including your name, job title, company name and email address) to third parties (including our business partners or event sponsors in the industry of or have an interest in impact investing) for them to send you promotional information / updates on their impact investing products / services and we will only do so upon obtaining your explicit consent.
You may opt-out from receiving our promotional messages at any time without charge, by following the opt-out instructions set out in our e-newsletters or write to us at SFi, 21/F Greatmany Centre, 109-115 Queen’s Road East, Wanchai, Hong Kong. For promotional messages sent by third parties, you may follow the opt-out instructions as provided by those third parties.
Please be advised that when you interact with third party service providers, they may use your personal data for their own marketing and advertising purposes, or to target advertisements to you or customise their recommendations to you, or they may engage third party or social media platforms to show advertisements to you. Such practices are governed by separate privacy policies and you should review their privacy policies to ensure that you are familiar with their data protection practices.
Who has access to your personal data?
SFi will not sell or rent your personal data to third parties for any purpose. However, SFi may, for one or more purposes specified in the section above, disclose or transfer your personal data to the below classes of persons, whether within or outside Hong Kong:
our contractor, sub-contractor or third-party service provider who provides administrative, event management and ticketing, marketing, human resources, audit, data storage/processing, photography, technical support or other services to support SFi’s business and provision of Impact Services
other attendees and corporate sponsors of our Impact Services, and our business partners or event sponsors in the industry of, or have an interest in, impact investing
any impact investors, fund companies and investment firms in the industry of, or have an interest in, impact investing
the government, court or tribunal or law enforcement authority
any person under a duty of confidentiality to us (including but not limited to legal, accounting or tax advisors)
any actual or proposed acquirer / assignee of all or any part of the business and/or assets of SFi
What rights do you have in relation to the personal data held by us?
You are entitled to request for access to and correction of your personal data held by us in accordance with the Ordinance. You may submit your requests for access to and correction of your personal data to email@example.com.
How do we protect your personal data?
When you give us personal data, we take steps to ensure that it is treated securely. We do not hold any of your payment information. More general contact details such as your name, address, telephone and email may be held on our servers, which we have restricted access to authorised personnel on a need-to-know basis. We have adopted security measures such as regularly scanning data files on these servers for virus detection and protecting the same by strong firewalls for which access passwords are regularly updated. For purposes of providing our services to you, we may share your personal data with our third-party service providers such as marketing automation and data storage service providers which may store your data on overseas servers.
You are responsible for the security of your own usernames and passwords. You must keep your usernames or passwords confidential and must not disclose or share these with any third parties.
Third-party websites’ privacy policies
Our Websites may contain hyperlinks to external websites operated or administered by third parties.
Your access to our Impact Services
We may suspend or terminate your right to receive our Impact Services including if:
you engage in conduct of bullying, insulting, intimidating, harassing or humiliating other persons when accessing using our Websites or participating in our Impact Services, or engaging in conduct that jeopardizes the safety of SFi’s community or interferes with the experience of the SFi’s community;
you defame or otherwise damage the name or reputation of SFi;
you act in such way which renders SFi to be in breach of any applicable laws and regulations;
allowing you to access and use the services would cause SFi to be in breach of any applicable law, rules, regulations or court order or would expose SFi to liability.
We may choose to stop offering our Impact Services to you or modify or replace any of our Impact Services at any time. We will use reasonable efforts to provide you with notice of our termination of your access to our Impact Services. You agree that we will not be liable to you or any third party as a result of our termination of your right to access or use our Impact Services.
Your use of our Websites
You may only use our Websites for lawful purposes when seeking information and must not use our Websites in any way that breaches any applicable laws or is fraudulent or produces any such purpose or effect.
You must not, whether directly or indirectly:
conduct any text or data mining or web scraping using any “robot”, bot”, “spider”, “scraper” or other automated device, program, tool, algorithm, code, process or methodology to access, obtain, copy, monitor or publish any portion of our Websites
undermine the security of the Website or any information submitted to or available on it
knowingly introduce viruses, trojans, worms, time-bombs, keyloggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of the Websites or related software or hardware
carry out unauthorised access, interfere with, damage or disrupt any part of our Websites or any equipment or network on which our Websites is stored, or any software used in the provision of our Websites
attack our Websites via a denial-of-service attack or distributed denial-of-service attack
overload the system / server of our Websites via spamming or flooding
take any action or use any device, routine or software to crash, delay, damage or otherwise interfere with the operation of our Websites
decipher, disassemble or modify any of the software, coding or information on our Websites or attempt to do any of the aforesaid
publish defamatory, obscene, offensive, hateful, inflammatory, immoral, discriminatory, violent or illegal contents on our Websites
You must not share or disclose your username or password and must not disclose or share these with any third parties. If you suspect that anyone other than you knows your username or password, you must promptly notify us at firstname.lastname@example.org.
Interruptions in our Websites
Every effort is made to ensure that our Websites is accurate, secure and accessible at all times. However, we do not guarantee that our Websites, or any content on it, will always be available or uninterrupted. We may suspend, withdraw or restrict the availability of all or any part of our Websites for business or operational reasons. We will try to give you reasonable notice of any interruption, suspension or withdrawal.
We do not accept any liability arising from or in connection to any such interruption, withdrawal, suspension or restriction or any ongoing obligation or responsibility to operate this Websites (or any part of it) or to provide the goods / service offered on this Websites. We may vary the specification of our Websites from time to time without notice.
Information on our Websites
We reserve the right to revise, modify or update our Websites and the contents therein from time to time, which may be done without prior notice to you.
Whilst we make every effort to update the information and contents on our Websites, we make no representations, warranties or guarantees, whether express or implied, that the information and content on our Websites is accurate, complete or up to date. We expressly disclaim any liability arising from any inaccuracy, error or omission in any of the contents on our Websites.
Rules about linking to our Websites
You may link to our Websites, provided that you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. Our Websites must not be framed on any other site. We reserve the right to withdraw linking permission without notice.
SFi is the owner of the Websites, including but not limited to all mark (whether registered or unregistered), illustrations, photographs, recordings, images, notes, documents, texts, brands, trademarks and product names, video, audio, design, text, material, logo, graphic thereon, and their entire contents, features and functionality which are protected by copyright and other forms of intellectual property rights / proprietary rights around the world. SFi and/or its licensors further reserve all forms of intellectual property rights in our Impact Services provided to you, where applicable.
You must not use any part of the content on our Websites for commercial purposes without obtaining a license to do so from us. No part of our Websites may be copied, modified, imitated or re-transmitted or used for non-permitted purposes without SFi’s prior written consent.
You must not use SFi’s marks (whether registered or unregistered) to disparage us, any third party, or in any manner that damage any goodwill in SFi’s marks.
Subject to specific terms and conditions governing a specific event, activity, exhibition, summit or course, you may take photos or videos of a limited part of the same for your personal use only and any commercial purpose of use is strictly prohibited.
To the maximum extent permissible under applicable law, you waive and release any moral rights you may have in our recordings which contain your facial images, appearance and voice and any claims you may have related to the use of recorded media of you, including, without limitation, any right to inspect or approve the photo, video or audio recording of you, any claims for invasion of privacy, violation of the right of publicity, defamation, and copyright infringement or for any fees for use of such record media. You hereby grant SFi a perpetual, royalty free, sub-licensable, worldwide licence to use recordings which contain your facial images, appearance and voice in actual or simulated likeness in connection with the production, exhibition, advertising or exploitation of any film, video and/or audio recording (or any part of it), in any media (e.g. in future marketing materials). If you have any concerns about this, please notify us prior to attending any of our Impact Services.
You agree to defend, indemnify, and hold harmless SFi from any and all damage (whether direct, indirect, incidental, consequential or otherwise), loss, liability, cost and expense (including reasonable legal and accounting fees) resulting from any claim, demand, suit, proceeding or investigation made by any third party relating to or arising out of:
your breach of any applicable laws, rules or regulations or the rights of any third party.
We will provide notice to you of any such claim, but our failure or delay in providing such notice will not limit your indemnification obligations except to the extent you are materially prejudiced by such failure. Also, in certain circumstances, we may choose to handle the claim ourselves, in which case you agree to cooperate with us in any way we request.
Do not rely on information provided to you in our Impact Services and on our Websites
SFi is not an investment advisor. All Impact Services provided by us and information on our Websites is for your information purpose only and is not intended to amount to investment, tax, legal, financial or any other advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of our Impact Services or the content on our Websites.
Our Impact Services and all information provided by us on our Websites is not intended and should not be used or construed as an offer to sell, or a solicitation of any offer to purchase any stock, any other security or any financial instrument or to provide any investment service or investment advice in any jurisdiction.
We merely serve as a platform to provide you with opportunities to connect with other impact investors or stakeholders in the industry. Your interaction with any such third parties is solely at your own risk and SFi shall not be liable for any loss incurred or suffered by you under any circumstances.
SFi’s limitation of liability
Our Impact Services and our Websites are provided on an "as is" and “as available” basis, without any warranty or representation of any kind, either express or implied, including, but not limited to, quality, success, accuracy, adequacy, legality, completeness, reliability, security, timeliness, appropriateness, implied warranties of merchantability, fitness for a particular purpose, title or non-infringement for use in any circumstances. We do not guarantee that our Impact Services will meet your requirements or expectations and the Websites are and will be uninterrupted or free of viruses, malicious codes or other defects, or the continued availability of the Websites.
Other users’ materials and links to third party websites
Our Websites may include information and materials uploaded or contributed by other users of the Websites. This information has not been verified or approved by us. The views expressed by other users do not represent our views or values.
Where our Websites contain links to other sites or resources provided by third parties, these links are provided for your information only. We have no control over the contents of these sites or resources. We cannot and have not reviewed all such links or resources and therefore cannot be liable for, and do not give any representation or warranty of any kind (whether express or implied) with respect to any such links or resources. Users link to such links or resources provided by third parties and use such sites according to the terms and conditions of use of those sites. The inclusion of any such sites and resources does not imply approval or endorsement by SFi of such sites and resources. SFi shall not be liable for any loss, whether direct or indirect and howsoever arising from or in respect of any access to, use or misuse of or reliance on such sites and resources, or any interruption or inability to access or use such sites and resources.
Choice of Law and Jurisdiction