Privacy Policy

1. Introduction and Scope

Admiralty Capital Limited ("Admiralty Capital", "we", "us", or "our") is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, transfer, and otherwise process personal information in connection with our website (www.admcl.com), our services, and our business operations.

This Privacy Policy applies to all individuals who interact with us, including prospective and current clients, business partners, service providers, website visitors, and any other individuals whose personal information we may process.

We are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and other applicable data protection laws in jurisdictions where we operate. By providing your personal information to us or using our services, you acknowledge that you have read and understood this Privacy Policy.

2. Data Controller Information

Admiralty Capital Limited is the data controller responsible for the personal information described in this Privacy Policy.

For any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Data Protection Officer
Admiralty Capital Limited
Central, Hong Kong
Email: privacy@admcl.com

We will respond to your inquiry within a reasonable timeframe, typically within 40 days as required under the PDPO.

3. Categories of Personal Information We Collect

We collect and process various categories of personal information depending on the nature of your relationship with us:

3.1 Identity Information

  • Full legal name (including any aliases or former names)
  • Date of birth and place of birth
  • Nationality and citizenship
  • Government-issued identification numbers (passport, HKID, etc.)
  • Photographs and signatures
  • Gender and marital status

3.2 Contact Information

  • Residential and business addresses
  • Email addresses (personal and corporate)
  • Telephone numbers (mobile, landline, fax)
  • Social media profiles (where relevant)

3.3 Financial and Business Information

  • Employment history and current position
  • Business ownership and directorships
  • Company registration details
  • Financial statements and tax records
  • Banking details and transaction history
  • Credit history and credit scores
  • Investment history and portfolio information
  • Source of funds and wealth documentation

3.4 Transaction Information

  • Details of financing applications and proposals
  • Transaction documents and correspondence
  • Payment and repayment records
  • Collateral information and valuations
  • Contract and agreement details

3.5 Technical Information

  • IP addresses and device identifiers
  • Browser type and version
  • Operating system and platform
  • Time zone settings and geographic location
  • Website usage data and navigation patterns
  • Cookies and similar tracking technologies (see Section 12)

3.6 Communications Data

  • Email correspondence and attachments
  • Meeting notes and records
  • Telephone call recordings (where disclosed)
  • Chat and messaging communications

3.7 Due Diligence Information

  • Background check results
  • Adverse media screening results
  • Sanctions and PEP (Politically Exposed Person) screening results
  • References and third-party reports
  • Court records and legal proceedings information

4. Sources of Personal Information

We collect personal information from various sources:

4.1 Directly from You

  • Information you provide when completing application forms
  • Information shared during meetings, calls, and correspondence
  • Information submitted through our website contact forms
  • Documents you provide as part of due diligence processes

4.2 From Third Parties

  • Credit reference agencies and rating agencies
  • Government and regulatory authorities
  • Professional advisors (lawyers, accountants, etc.)
  • Business information providers and databases
  • Sanctions screening and compliance databases
  • Industry associations and networks
  • References and former employers
  • Publicly available sources (company registries, news media, etc.)

4.3 Automatically Through Our Website

  • Technical data collected through cookies and similar technologies
  • Analytics data about your use of our website
  • Server logs and access records

4.4 From Our Business Partners

  • Information shared by co-investors or syndicate members
  • Referral information from introducers
  • Information from service providers acting on your behalf

5. Purposes of Processing

We process your personal information for the following purposes:

5.1 Client Onboarding and Services

  • Evaluating financing applications and proposals
  • Conducting credit assessments and risk analysis
  • Performing due diligence and background checks
  • Structuring and documenting transactions
  • Managing ongoing client relationships
  • Providing customer support and responding to inquiries

5.2 Legal and Regulatory Compliance

  • Complying with anti-money laundering (AML) requirements
  • Fulfilling know-your-customer (KYC) obligations
  • Meeting sanctions screening and monitoring requirements
  • Responding to regulatory inquiries and examinations
  • Maintaining required records and documentation
  • Filing required reports with authorities

5.3 Risk Management

  • Assessing creditworthiness and default risk
  • Monitoring collateral values and coverage ratios
  • Managing portfolio concentration and exposure
  • Conducting stress testing and scenario analysis
  • Implementing fraud prevention measures

5.4 Business Operations

  • Processing payments and financial transactions
  • Managing internal administration and record-keeping
  • Conducting audits and compliance reviews
  • Training staff and improving our services
  • Planning and developing our business

5.5 Communications

  • Responding to your inquiries and requests
  • Providing updates on applications and transactions
  • Sending service-related communications
  • Distributing newsletters and market updates (with consent)

5.6 Website and Technology

  • Operating and maintaining our website
  • Analyzing website usage and improving user experience
  • Ensuring website security and preventing fraud
  • Personalizing content and recommendations

5.7 Legal Purposes

  • Establishing, exercising, or defending legal claims
  • Complying with court orders and legal processes
  • Enforcing our contractual rights and obligations

6. Legal Basis for Processing

Under the PDPO and other applicable data protection laws, we process personal information on the following legal bases:

6.1 Consent

Where you have given explicit consent for specific processing activities, such as receiving marketing communications or participating in certain programs.

6.2 Contractual Necessity

Where processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract.

6.3 Legal Obligation

Where processing is necessary for compliance with a legal obligation to which we are subject, including AML/KYC requirements and regulatory reporting.

6.4 Legitimate Interests

Where processing is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests. Our legitimate interests include:

  • Conducting our business and providing our services
  • Managing risk and protecting our assets
  • Preventing fraud and maintaining security
  • Improving and developing our services
  • Marketing our services to appropriate audiences

6.5 Vital Interests

In rare circumstances, where processing is necessary to protect your vital interests or those of another person.

6.6 Public Interest

Where processing is necessary for the performance of a task carried out in the public interest.

7. Disclosure and Sharing of Personal Information

We may disclose your personal information to the following categories of recipients:

7.1 Group Companies

We may share personal information with our parent company, subsidiaries, and affiliated entities for the purposes described in this Privacy Policy.

7.2 Professional Advisors

  • Legal counsel and law firms
  • Accounting and audit firms
  • Valuation and appraisal firms
  • Tax advisors and consultants
  • Management and financial consultants

7.3 Service Providers

  • IT service providers and cloud hosting services
  • Data analytics and business intelligence providers
  • Communication service providers
  • Document storage and management providers
  • Translation and interpretation services
  • Background check and screening providers
  • Credit reference and rating agencies

7.4 Financial Institutions

  • Banks and custodians
  • Insurance companies
  • Co-lenders and syndicate participants
  • Co-investors and fund managers
  • Securities intermediaries

7.5 Government and Regulatory Authorities

  • Financial regulators (SFC, HKMA, etc.)
  • Tax authorities (IRD, etc.)
  • Law enforcement agencies
  • Courts and tribunals
  • Company registries
  • Anti-money laundering authorities

7.6 Other Third Parties

  • Potential buyers or investors in connection with a sale or transfer of our business
  • Counterparties in potential or actual transactions
  • Industry associations and professional bodies
  • Any other party with your consent

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

8. International Data Transfers

8.1 Transfer of Personal Information

Your personal information may be transferred to, stored, and processed in countries outside Hong Kong, including countries where we have offices, where our service providers are located, or where our business partners operate.

8.2 Safeguards for International Transfers

When we transfer personal information internationally, we implement appropriate safeguards to ensure that your information receives an adequate level of protection, including:

  • Entering into data transfer agreements incorporating standard contractual clauses
  • Transferring to jurisdictions that have been determined to provide adequate protection
  • Implementing binding corporate rules for intra-group transfers
  • Obtaining your explicit consent where required
  • Relying on other lawful transfer mechanisms recognized under applicable law

8.3 Jurisdictions

Your personal information may be processed in the following jurisdictions:

  • Hong Kong SAR (primary processing location)
  • Singapore (regional operations)
  • British Virgin Islands (corporate structuring)
  • Other jurisdictions as necessary for specific transactions

Each of these jurisdictions may have different data protection laws than Hong Kong. We take steps to ensure that your personal information is protected in accordance with this Privacy Policy regardless of where it is processed.

9. Data Retention

9.1 Retention Periods

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, accounting, or reporting requirements.

The specific retention period for different types of personal information depends on:

  • The nature and sensitivity of the information
  • The purpose for which it was collected
  • Applicable legal and regulatory requirements
  • Potential or ongoing legal proceedings
  • Our legitimate business interests

9.2 General Retention Guidelines

  • Client information: 7 years after the end of the relationship
  • Transaction records: 7 years after completion of the transaction
  • AML/KYC records: 7 years after the end of the business relationship (as required by AMLO)
  • Marketing preferences: Until you withdraw consent or the information becomes outdated
  • Website analytics: 3 years
  • Application records (unsuccessful): 3 years after the application is declined
  • Employment records: 7 years after termination of employment

9.3 Criteria for Determining Retention Periods

When determining the appropriate retention period, we consider:

  • The amount, nature, and sensitivity of the personal information
  • The potential risk of harm from unauthorized use or disclosure
  • The purposes for which we process the information
  • Whether we can achieve those purposes through other means
  • Applicable legal, regulatory, tax, accounting, or other requirements

9.4 Secure Destruction

When personal information is no longer required, we ensure it is securely destroyed or anonymized using appropriate technical and organizational measures.

10. Your Rights

Subject to applicable law, you may have the following rights regarding your personal information:

10.1 Right of Access

You have the right to request access to your personal information and to receive a copy of the personal information we hold about you. We may charge a reasonable fee for providing this information.

10.2 Right to Correction

You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.

10.3 Right to Erasure

In certain circumstances, you have the right to request that we erase your personal information. This right is not absolute and may be limited by our legal obligations or legitimate interests.

10.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal information in certain circumstances.

10.5 Right to Data Portability

Where applicable, you have the right to receive your personal information in a structured, commonly used, and machine-readable format.

10.6 Right to Object

You have the right to object to the processing of your personal information in certain circumstances, including processing for direct marketing purposes.

10.7 Right to Withdraw Consent

Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time. This will not affect the lawfulness of processing conducted prior to the withdrawal.

10.8 Exercising Your Rights

To exercise any of these rights, please contact us using the details provided in Section 2. We will respond to your request within the timeframes required by applicable law. We may need to verify your identity before processing your request.

10.9 Complaints

If you are not satisfied with our response to your request or believe that we are processing your personal information in a way that is not compliant with the law, you have the right to lodge a complaint with the Privacy Commissioner for Personal Data in Hong Kong.

11. Data Security

11.1 Security Measures

We have implemented appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest
  • Firewalls and intrusion detection systems
  • Access controls and authentication mechanisms
  • Regular security assessments and penetration testing
  • Employee training on data protection and security
  • Incident response and breach notification procedures
  • Physical security measures for our premises
  • Secure destruction of data when no longer needed

11.2 Third-Party Security

We require our service providers and business partners to implement appropriate security measures and to comply with applicable data protection laws.

11.3 Limitations

While we take reasonable steps to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your information.

11.4 Your Responsibilities

You are responsible for maintaining the confidentiality of any login credentials or access codes provided to you. Please notify us immediately if you become aware of any unauthorized use of your account or any security breach.

12. Cookies and Similar Technologies

12.1 What Are Cookies

Cookies are small text files that are placed on your device when you visit our website. They help us recognize your device and provide you with a personalized experience.

12.2 Types of Cookies We Use

Essential Cookies: These cookies are necessary for the website to function properly. They enable basic functions like page navigation and access to secure areas.

Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. We use this information to improve our website.

Functional Cookies: These cookies enable enhanced functionality and personalization, such as remembering your preferences and settings.

Marketing Cookies: These cookies may be set through our website by our advertising partners. They may be used to build a profile of your interests and show you relevant advertisements on other sites.

12.3 Cookie Management

Most web browsers allow you to control cookies through their settings. You can typically:

  • Accept or reject all cookies
  • Accept only certain types of cookies
  • Be notified when a cookie is set
  • Delete cookies that have already been set

Please note that disabling certain cookies may affect the functionality of our website.

12.4 Other Tracking Technologies

We may also use other tracking technologies such as web beacons, pixel tags, and clear GIFs. These technologies help us understand which emails have been opened and track website usage.

12.5 Do Not Track

Some browsers have a "Do Not Track" feature that lets you tell websites that you do not want your online activities tracked. We currently do not respond to "Do Not Track" signals.

13. Marketing Communications

13.1 Marketing Preferences

We may use your personal information to send you marketing communications about our services, industry updates, and other information that may be of interest to you. We will only do so where we have your consent or where we are otherwise permitted by law.

13.2 Opting Out

You can opt out of receiving marketing communications from us at any time by:

  • Clicking the "unsubscribe" link in any marketing email
  • Contacting us at privacy@admcl.com
  • Updating your communication preferences

Please note that even if you opt out of marketing communications, we may still send you service-related communications that are necessary for the provision of our services.

13.3 Third-Party Marketing

We do not share your personal information with third parties for their own direct marketing purposes without your explicit consent.

14. Children's Privacy

Our services are not directed at children under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personal information from children. If you believe that we have collected personal information from a child, please contact us immediately so that we can take appropriate steps to delete such information.

15. Changes to This Privacy Policy

15.1 Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes to this Privacy Policy, we will notify you by:

  • Posting the updated Privacy Policy on our website
  • Updating the "Last Updated" date at the top of this page
  • Sending you an email notification (where appropriate)
  • Providing a notice through our website

15.2 Review

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal information.

15.3 Continued Use

Your continued use of our website or services after any changes to this Privacy Policy will constitute your acceptance of such changes.

16. Contact Information

If you have any questions, concerns, or complaints about this Privacy Policy or our privacy practices, please contact us:

Data Protection Officer
Admiralty Capital Limited
Central, Hong Kong
Email: privacy@admcl.com

For general inquiries:
Email: enquiry@admcl.com

We take all privacy inquiries seriously and will respond within the timeframes required by applicable law.