HSBC Bank (China) Company Limited (“HSBC”, “the Bank”, “we” or “us”) take personal information confidentiality and security very seriously, and strive at all times to protect personal information and privacy of our customers and other related personal information subjects (“you” or “Personal Information Subject”) according to law. We therefore formulate this Personal Information and Privacy Protection Policy for Personal Digital Banking Services (this “Policy”) to help you understand the purposes, methods, and scope of personal information we collect and use, our practices regarding personal information and privacy protection, your rights and interests with regard to personal information and privacy and how to assert your rights and interests.
This Policy applies to your use of our personal digital banking services (including telephone banking, internet banking, mobile banking and WeChat Service Account).
The table of content of this Policy is set out as below:
I. How We Protect Your Personal Information
II. How We Collect Your Personal Information
III. How We Use Your Personal Information
IV. How We Store Your Personal Information
V. How We Share, Transfer and Publicly Disclose Your Personal Information
VI.Special Circumstances for Information Processing
VII. How We Use Cookies and Similar Technologies
VIII. Your Rights Relating to Personal Information
X. Protection of Minors' Personal Information
XI. Formulation, Effectiveness and Update of this Policy and Others
Please read through this Policy carefully and pay particular attention to the provisions that are bolded and underlined which we think have material impacts on your interests and/or deal with your sensitive personal information. The key points of this Policy are summarized as below:
- For your convenience to understand the purpose and category of personal information we collect when you sign up for our service, we therefore explain them under the particular service scenario.
- When you sign up for some particular services, we will collect your sensitive personal information after you give us express consent if required by applicable laws and regulations. Refusal on providing consent might affect you use related service, but will not affect you use other services we provided.
- To provide the service per you request, we might need to share your personal information to a third party. We will carefully assess the legitimacy, propriety, and necessity of the data sharing with the third party. We will ask the relevant third party to take all data protection measures required pursuant to applicable laws and regulations.
We fully understand how important your personal information means to you, and we will exert our best effort to protect the security of your personal information. We have always been committed to maintain your trust and will stick to below principles to protect your personal information: Right and Responsibility Consistency, Explicit Purpose, Freely Given Consent, Minimum and Necessity, Assurance of Information Security, Participation, Fairness and Transparency. We are also committed to take appropriate security measures to protect your information.
We shall collect, use, store, disclose, and protect your and related parties’ personal information in accordance with this Policy. If there is any discrepancy between this Policy and the other agreements entered into or other terms and conditions agreed between you and us, such other agreements or terms and conditions shall prevail.
I. How We Protect Your Personal Information
- Information security is our top priority. We will endeavour at all times to safeguard your personal information against unauthorised or accidental access, processing or damage. We maintain this commitment to information security by implementing appropriate security and managerial measures to secure your personal information. We will take responsibility in accordance with the law if your personal information suffers from unauthorised access, public disclosure, erasure or damage for a reason attributable to us and so impairs your lawful rights and interests.
- Our website supports advanced encryption technology - an existing industry standard for encryption over the internet to protect your personal information. When you provide sensitive personal information through our website, APP or other digital channels, it will be automatically converted into codes so as to ensure secure transmission afterwards. Our web servers are protected behind “firewalls” and our systems are monitored to prevent any unauthorized access. Our mobile banking application software has passed Union-pay payment application software security test conducted by Bank Card Test Centre and the software filing for financial client mobile application with National Internet Finance Association of China.
- We maintain strict security system to prevent unauthorized access to your personal information. We exercise strict management over our staff members who may have access to your personal information, including but not limited to access control applied to different positions, contractual obligation of confidentiality agreed with relevant staff members, formulation and implementation of information security related policies and procedures, and information security related training offered to staff.
- We will not disclose your personal information to any third party, unless the disclosure is made to comply with laws, regulations and regulatory requirements or according to this Policy or separate agreement between us, or based on your separate consent or authorisation. When we use services provided by external service providers (entities or individuals), we also impose strict confidentiality obligations on them and require them to take all data protection measures required pursuant to applicable laws and regulations when processing your personal information.
- For the security of your personal information, you take on the same responsibility as us. You shall properly take care of your personal information, such as your bank account information, identity verification information (e.g. user name, password, dynamic password, verification code, etc.), and all the documents, devices or other media that may record or otherwise relate to such information, and shall ensure your personal information and relevant documents, devices or other media are used only in a secured environment. You shall not, at any time, disclose to any other person or allow any other person to use such information and relevant documents, devices or other media. Once you think your personal information and/or relevant documents, devices or other media have been disclosed, lost or stolen, or may otherwise affect the security of your use of our digital banking services, you shall notify us immediately so that we may take appropriate measures to prevent further loss from occurring.
- We will organize regular staff training and drills on emergency response so as to let the relevant staff be familiar with their job duties and emergency procedures. If unfortunately, personal information security incident occurs, we will adopt emergency plan and take relevant actions and remediation measures to mitigate the severity and losses in connection therewith. Meanwhile, we will, following the applicable requirements set out in law and regulation, inform you of the basic information of the security incident and its possible impact, the actions and measures we have taken or will take, suggestions for you to prevent and mitigate the risk, and applicable remediation measures. We will inform you about the security incident by email, mail, call, SMS, push notification or through other methods as appropriate in a timely manner. Where it is difficult to notify each Personal Information Subject, we will post public notice in a reasonable and effective way. Meanwhile, we will report such personal information security incident and our actions in accordance with applicable law, regulation and regulatory requirements.
II. How We Collect Your Personal Information
1. Personal information refers to any kind of information related to an identified or identifiable natural person as electronically or otherwise recorded, excluding information that has been anonymized. Personal information include name, birth date, ID certificate information (ID card, passport and etc.,), personal biometrics recognition information, contact information, address, account information, property status, location and etc. Sensitive personal information refers to personal or property information that, once leaked or illegally provided or misused, may harm personal or property safety and will easily lead to infringement of the personal reputation, human dignity, physical or psychological health, or discriminatory treatment. Such information mainly includes ID certificate information (ID card, passport and etc.,), personal biometrics recognition information, credit information, property information, transaction information, medical and health information, specific identity, financial account, individual location tracking etc. as well as any personal information of a minor under the age of 14 (i.e. child).
The personal information we collect may be recorded in paper, electronic means (including but not limited to the information we collect via our self-service machine, website, online banking, mobile banking, WeChat account, WeChat application or other mobile device applications, email, SMS or other channels) or any other means.
| Purposes or Functions | Information We Need to Collect |
|---|---|
| Registering digital banking service account |
Your name, mobile phone number, ID certificate type and number, bank card number and password, telephone banking number, telephone banking password. If you hold a CAT II or CAT III account with us, you need to provide face feature information to register digital banking service account. |
| Logging onto digital banking service account or retrieving logon password |
Your user name/logon name, security question and answer, any password, code, dynamic password, security code, verification code pre-set by you or created or sent via security device, mobile phone, email or other equipment or methods. |
| Maintaining proper and secure operation of digital banking services, preventing and controlling digital banking related risk |
Your device type, operating system, unique device identifier (Android ID, UUID, IMEI, MAC address), software version, logon IP address, internet service provider (ISP), device accelerators and gravity sensing devices.
Technical information that may not be used to identify an individual’s identity will not be treated as personal information. But if the information alone or in combination with other information may be used to identify your identity, we will treat it as your personal information and have it properly protected. |
| Registration and use of telephone banking services | Your ID certificate number, date of birth, debit card number, credit card number, savings account number, debit card password, credit card inquiry password, text message authentication code, CVV2 code, telephone banking service number, telephone banking service password. |
| Purposes or Functions |
Registering digital banking service account |
|---|---|
| Information We Need to Collect |
Your name, mobile phone number, ID certificate type and number, bank card number and password, telephone banking number, telephone banking password. If you hold a CAT II or CAT III account with us, you need to provide face feature information to register digital banking service account. |
| Purposes or Functions |
Logging onto digital banking service account or retrieving logon password |
| Information We Need to Collect | Your user name/logon name, security question and answer, any password, code, dynamic password, security code, verification code pre-set by you or created or sent via security device, mobile phone, email or other equipment or methods. |
| Purposes or Functions |
Maintaining proper and secure operation of digital banking services, preventing and controlling digital banking related risk |
| Information We Need to Collect |
Your device type, operating system, unique device identifier (Android ID, UUID, IMEI, MAC address), software version, logon IP address, internet service provider (ISP), device accelerators and gravity sensing devices.
Technical information that may not be used to identify an individual’s identity will not be treated as personal information. But if the information alone or in combination with other information may be used to identify your identity, we will treat it as your personal information and have it properly protected. |
| Purposes or Functions | Registration and use of telephone banking services |
| Information We Need to Collect | Your ID certificate number, date of birth, debit card number, credit card number, savings account number, debit card password, credit card inquiry password, text message authentication code, CVV2 code, telephone banking service number, telephone banking service password. |
If you refuse to provide these information, you will not be able to register or logon our digital banking service account, or will not be able to use our regular digital banking services in a safe and normal way.
| Purposes or Functions |
Personal Biometrics Recognition Information We Collect |
|---|---|
| Logon verification |
To provide you more safe and convenient mobile banking logon service, you can choose to logon mobile banking via fingerprint recognition. User of some mobile device models also can choose to logon mobile banking via facial (facial ID) recognition.
We will only receive equipment verifications results and will not collect your original fingerprint or face image. You can choose to logon via password if you have no desire to logon via fingerprint or facial ID. |
| Services require Facial Verification Functions | Your face feature information
To provide you more safe and convenient mobile banking service experience, you can choose to use facial verification function. We will collect your face feature information but will not collect your face image. This information is only used in assisting identity verification in processing your business requirements during relevant online journey to ensure your use of our digital service. We may send your face information to the China Ministry of Public Security system for your identity verification and receive the verification results. This information is encrypted in the back-end database of the Bank's system and follows the data retention policy set out in Article IV of this Policy “How Do We Store Your Personal Information”. After the expiration of retention period, we will delete or anonymize your personal biometrics recognition information.
You have the right to choose whether to provide your face feature information or not, but if you chose not, we will not be able to provide you with certain online products or services which are subject to face verification according to the nature of business and/or risk management purpose. Alternatively you may handle the relevant business/service at our branches.
Mobile banking APP services require facial verification functions: Modify Personal Information>Modify Mobile Phone Number, Modify Identity Information; Open CAT II/CAT III account online; Payment by Mobile Phone Number: Register/Unregister Mobile Phone Number, Adjust Default Account; Credit Card>Virtual Card Activation, Setup Enquiry Password, Enquiry CVV2. |
| Purposes or Functions |
Logon verification |
|---|---|
| Personal Biometrics Recognition Information We Collect |
To provide you more safe and convenient mobile banking logon service, you can choose to logon mobile banking via fingerprint recognition. User of some mobile device models also can choose to logon mobile banking via facial (facial ID) recognition.
We will only receive equipment verifications results and will not collect your original fingerprint or face image. You can choose to logon via password if you have no desire to logon via fingerprint or facial ID. |
| Purposes or Functions |
Services require Facial Verification Functions |
| Personal Biometrics Recognition Information We Collect |
Your face feature information
To provide you more safe and convenient mobile banking service experience, you can choose to use facial verification function. We will collect your face feature information but will not collect your face image. This information is only used in assisting identity verification in processing your business requirements during relevant online journey to ensure your use of our digital service. We may send your face information to the China Ministry of Public Security system for your identity verification and receive the verification results. This information is encrypted in the back-end database of the Bank's system and follows the data retention policy set out in Article IV of this Policy “How Do We Store Your Personal Information”. After the expiration of retention period, we will delete or anonymize your personal biometrics recognition information.
You have the right to choose whether to provide your face feature information or not, but if you chose not, we will not be able to provide you with certain online products or services which are subject to face verification according to the nature of business and/or risk management purpose. Alternatively you may handle the relevant business/service at our branches.
Mobile banking APP services require facial verification functions: Modify Personal Information>Modify Mobile Phone Number, Modify Identity Information; Open CAT II/CAT III account online; Payment by Mobile Phone Number: Register/Unregister Mobile Phone Number, Adjust Default Account; Credit Card>Virtual Card Activation, Setup Enquiry Password, Enquiry CVV2. |
| Purposes or Functions |
Information We Collect |
|---|---|
| WeChat Logon |
Your WeChat ID, WeChat name and profile photo, mobile phone number |
| Appointment to Consultation |
Your title, name, area code, mobile phone number, province, city, whether own a personal account in HSBC or not |
| Functions based on geographic location such as finding the nearest branches and designated merchants (e.g. in bank card promotion campaign) |
Your geographic location information |
| Important notice for cross border sales and marketing |
Your GPS location and logon IP address |
| To purchase investment, or other financial products |
Your personal identity information, including name, sex, nationality, citizenship, type/number/validity period of ID certificate, occupation, contact information, age, date of birth, number of dependents;
Your personal property information, including personal or family income status, real property, financial assets, indebtedness, investment, whether 6 months of emergency liquidity is reserved;
Your personal account information, including account number, time of account opening, institution with which the account is opened, account balance, account transaction information;
Your personal financial transaction information, including personal information acquired, kept, recorded during any payment, settlement, wealth management, safe deposit box or other banking business, personal information generated from transactions made through us with any third party institution like securities company, fund house, futures company or payment agency;
Your transaction or risk preference, risk appetite, investment intention, investment goal, knowledge and experience;
For foreign exchange settlement and sale, may need to provide purpose of the transaction or source of funds; if the payment amount exceeds the annual exchange allowance, supporting documents are required including proof of income, work information, letter of colleague admission, medical certificate.
Any other personal information acquired during the establishment or maintenance of business relationship for the performance of contracts or for compliance with laws and regulations and regulatory requirements, time/location (including geographic location and network address) of service use, correspondence or other communication records (including video or audio records, call log and correspondence records and contents). |
| Friends and Family Referral Programmes for opening banking account with the Bank |
Referral’s name, gender, contact information, province/city where referral plans to open banking account, product or services the referral may be interested in |
| HSBC Jade customers’ insurance related privileges | Name, gender, ID certificate type and number of the insured |
| Appointment booking on WeChat for account opening |
Your name, nationality, country/place of birth, country/place of residence, gender, mobile phone number, number/validity period/place of issuing of ID identity certificate, email address, occupation and salary information, tax resident status |
| Smart Mobile On Boarding |
Your name (including former name and alias), gender, mobile phone number, photo of front side and back side of ID certificate, country/place of birth, residential address and the date of moving to the address, mailing address, occupation information, tax resident status, tax payer identification number, email address, purpose of account opening, use plan of the account, source of funds. |
| Transfer and remittance |
Domestic transfer and remittance: name of payee, information of beneficiary bank, beneficiary bank account number.
When you preset the payees for domestic transfer and remittance, or make domestic transfer and remittance, we will, based on your choice, collect your face feature information or the security code generated by security device as you input to verify your identity.
If you make domestic transfer by “mobile phone number payment” function, you need to provide payee’s name, payee’s mobile phone number, name of beneficiary bank, and to complete identity verification by SMS OTP; if you logon mobile banking by using facial biometrics information or fingerprint biometrics information to complete identity verification, you need to use mobile banking logon password for a further verification; if you receive money by using “mobile phone payment” function, you need to firstly set mobile phone number receiving function and we need to obtain the bank name and account number set up by the same mobile phone number in another bank under your name and use your face feature information to verify your identity.
Overseas transfer and remittance: payee’s name, name of beneficiary bank, beneficiary account number, type of currency of beneficiary account, country/place where beneficiary bank is located or beneficiary bank’s address
IEPS transfer service will require to provide name of colleague/university, colleague/university bank account, student ID, tuition fee invoice number, payment purpose, email address; if the payment amount exceeds the annual exchange allowance, supporting documents are required including ID certificate, tuition fee invoice, admission letter, passport, VISA, registered residence (Hu Kou of direct relatives) |
| QR code payment and payment password setting |
When you set payment password, you need to provide us with the transaction password of debit card or inquiry password of credit card, and the SMS OTP.
For each transaction made via QR code payment, we need to collect your device type, device identifier and device GPS location to ensure the safety of the transaction. |
| Application for credit card |
Your name, gender, nationality, date of birth, ID information(including: ID type, ID number, ID validity period, place of issuing of ID certificate and ID front and back images), place of residence, mobile phone number, email address，employment information(including: industry, occupation type, job level, employer information, employee duration), contact information(including: name, phone number and relationship), marital status, education level, after tax income;
When you apply for credit card via digital channels, we will need to obtain card number of bank card you applied for with other bank and corresponding mobile phone number used for your application for that bank card; if the said mobile phone number is different from the mobile phone number you provide to us at the time of credit card application, we will need the SMS OTP sent to the said mobile phone number to verify your identity;
We may inquire your credit information and/or credit report with the Basic Financial Credit Information Database and/or other credit reference agencies legally incorporated. |
| Inquiry of credit card application status |
ID certificate number you provided at the time of application and SMS OTP |
| Activation of physical credit card |
Credit card number, type/number of ID certificate, date of birth, card expiry date, CVV2 and SMS OTP |
| Activation of virtual credit card and inquiry password setting |
Your name, type/number of ID certificate, date of birth, SMS OTP and your face feature information |
| Inquiry of virtual credit card information |
Credit card inquiry password, SMS OTP and your face feature information |
| Credit Card Repayment and Repayment Setup |
Credit Card Prompt Repayment: repayment Bank account, repayment amount, bank account of banks other than HSBC;
Credit Card Bill Setup: Mail address, E-mail address |
| Application for CIP or ALOC |
Bank account number of the account to receive disbursement of CIP or ALOC and loan purpose;
We may inquire your credit information and/or credit report with the Basic Financial Credit Information Database and/or other credit reference agencies legally incorporated;
We may also need to obtain invoice or other transaction voucher from you to verify the purpose for use of the fund. |
| Know Special Offers Nearby |
Receive the special offer activities information and the coupon. We may inquire your location information to show you promotion stores at your most convenience. |
| Logon to CVP platform |
Last four digits of the card number (for credit card cardholders) or last four digits of your ID certificate number (for debit card cardholders), your mobile phone number and SMS OTP |
| Redemption of reward points |
Your name, mobile phone number, ID certificate number, address information, credit card number, credit card status and credit card reward points balance.
We need to provide above information to third party vendor so as to deliver the goods you exchanged or purchased in the reward mall. |
| Opening CAT II and CAT III account |
Photo of front side and back side of your ID certificate, name (including the former name), gender, number/valid period/ place of issuing of ID certificate, age, date of birth, place of birth, nationality, mobile phone number, email address, residence address, country and region of tax authority, tax payer identification number, employer and occupation information;
We need to obtain the card number of the debit card you applied for with other bank and the corresponding mobile phone number to verify your identity. |
| Appointment booking for home mortgage loan inquiry and inquiry of application status of home mortgage loan |
Your name, type/number of ID certificate, as well as the city where you plan to purchase the real estate |
| Application for retail business loan | Business license number of the company which is financed by your loan, your name, ID certificate type and number, bank card number used for real-name verification, bank name, associated mobile phone number, name of the pledger (if any), type and number of identity certificate of the pledger (if any) |
| Enrolment in online or offline activities organized by us |
Your name, area code, mobile phone number, province or area you are in, whether own personal account in HSBC or not |
| Improving service experience | Information you provide when raising your feedback, suggestion or complaint, information you input when participating in campaigns or surveys
Meanwhile, to assure the service quality, we may record the service call content. We will provide necessary hint before recording to protect your right to be informed and the right of choice. |
| Provide Marketing and Event Information | Information you provide to participate in our marketing campaigns, events or surveys. Only after obtaining your consent or on your own request, we will then contact you, send you information about products and services information you may be interested in, invite you to participate in our events and surveys, or send you promotion information.
If at any time you would like change your choice on this part, you can exercise your right of choice by referring to the relevant section 9 in Article VIII of this Policy “Your Rights Relating to Personal Information”. |
| Provide Personalized Contents | The information you provide when you open an account at our bank, buy our products, use our services, and participate in our marketing activities. We will collect and analyse this information to provide you with more accurate, convenient and personalized content display or information push / sending services. If at any time you would like change your choice on this part, you can exercise your right of choice by referring to the relevant section 7 in Article VIII of this Policy “Your Rights Relating to Personal Information”. |
| Uploading from Document Center |
To certify your eligibility of the investment products’ application and insurance, you need to upload documents as evidence, in which might include info like name, passport number, nationality, date of birth, gender, ID certificate. |
| Fraud risk control when using mobile banking applications after login | After you log in to your mobile banking application, to control the risk of fraud, we collect the GPS location of the device to you. You can manage location authorization in the feature rights page of your device, especially for Android phones with Google GMS (Google Mobile Service), you can set whether to enable Google Basic Services to get GPS location information in your phone rights management. |
| Purposes or Functions |
WeChat Logon |
|---|---|
| Information We Collect |
Your WeChat ID, WeChat name and profile photo, mobile phone number |
| Purposes or Functions |
Appointment to Consultation |
| Information We Collect |
Your title, name, area code, mobile phone number, province, city, whether own a personal account in HSBC or not |
| Purposes or Functions |
Functions based on geographic location such as finding the nearest branches and designated merchants (e.g. in bank card promotion campaign) |
| Information We Collect |
Your geographic location information |
| Purposes or Functions |
Important notice for cross border sales and marketing |
| Information We Collect |
Your GPS location and logon IP address |
| Purposes or Functions |
To purchase investment, or other financial products |
| Information We Collect |
Your personal identity information, including name, sex, nationality, citizenship, type/number/validity period of ID certificate, occupation, contact information, age, date of birth, number of dependents;
Your personal property information, including personal or family income status, real property, financial assets, indebtedness, investment, whether 6 months of emergency liquidity is reserved;
Your personal account information, including account number, time of account opening, institution with which the account is opened, account balance, account transaction information;
Your personal financial transaction information, including personal information acquired, kept, recorded during any payment, settlement, wealth management, safe deposit box or other banking business, personal information generated from transactions made through us with any third party institution like securities company, fund house, futures company or payment agency;
Your transaction or risk preference, risk appetite, investment intention, investment goal, knowledge and experience;
For foreign exchange settlement and sale, may need to provide purpose of the transaction or source of funds; if the payment amount exceeds the annual exchange allowance, supporting documents are required including proof of income, work information, letter of colleague admission, medical certificate.
Any other personal information acquired during the establishment or maintenance of business relationship for the performance of contracts or for compliance with laws and regulations and regulatory requirements, time/location (including geographic location and network address) of service use, correspondence or other communication records (including video or audio records, call log and correspondence records and contents). |
| Purposes or Functions |
Friends and Family Referral Programmes for opening banking account with the Bank |
| Information We Collect |
Referral’s name, gender, contact information, province/city where referral plans to open banking account, product or services the referral may be interested in |
| Purposes or Functions |
HSBC Jade customers’ insurance related privileges |
| Information We Collect |
Name, gender, ID certificate type and number of the insured |
| Purposes or Functions |
Appointment booking on WeChat for account opening |
| Information We Collect |
Your name, nationality, country/place of birth, country/place of residence, gender, mobile phone number, number/validity period/place of issuing of ID identity certificate, email address, occupation and salary information, tax resident status |
| Purposes or Functions |
Smart Mobile On Boarding |
| Information We Collect |
Your name (including former name and alias), gender, mobile phone number, photo of front side and back side of ID certificate, country/place of birth, residential address and the date of moving to the address, mailing address, occupation information, tax resident status, tax payer identification number, email address, purpose of account opening, use plan of the account, source of funds. |
| Purposes or Functions |
Transfer and remittance |
| Information We Collect |
Domestic transfer and remittance: name of payee, information of beneficiary bank, beneficiary bank account number.
When you preset the payees for domestic transfer and remittance, or make domestic transfer and remittance, we will, based on your choice, collect your face feature information or the security code generated by security device as you input to verify your identity.
If you make domestic transfer by “mobile phone number payment” function, you need to provide payee’s name, payee’s mobile phone number, name of beneficiary bank, and to complete identity verification by SMS OTP; if you logon mobile banking by using facial biometrics information or fingerprint biometrics information to complete identity verification, you need to use mobile banking logon password for a further verification; if you receive money by using “mobile phone payment” function, you need to firstly set mobile phone number receiving function and we need to obtain the bank name and account number set up by the same mobile phone number in another bank under your name and use your face feature information to verify your identity.
Overseas transfer and remittance: payee’s name, name of beneficiary bank, beneficiary account number, type of currency of beneficiary account, country/place where beneficiary bank is located or beneficiary bank’s address
IEPS transfer service will require to provide name of colleague/university, colleague/university bank account, student ID, tuition fee invoice number, payment purpose, email address; if the payment amount exceeds the annual exchange allowance, supporting documents are required including ID certificate, tuition fee invoice, admission letter, passport, VISA, registered residence (Hu Kou of direct relatives) |
| Purposes or Functions |
QR code payment and payment password setting |
| Information We Collect |
When you set payment password, you need to provide us with the transaction password of debit card or inquiry password of credit card, and the SMS OTP.
For each transaction made via QR code payment, we need to collect your device type, device identifier and device GPS location to ensure the safety of the transaction. |
| Purposes or Functions |
Application for credit card |
| Information We Collect |
Your name, gender, nationality, date of birth, ID information(including: ID type, ID number, ID validity period, place of issuing of ID certificate and ID front and back images), place of residence, mobile phone number, email address，employment information(including: industry, occupation type, job level, employer information, employee duration), contact information(including: name, phone number and relationship), marital status, education level, after tax income;
When you apply for credit card via digital channels, we will need to obtain card number of bank card you applied for with other bank and corresponding mobile phone number used for your application for that bank card; if the said mobile phone number is different from the mobile phone number you provide to us at the time of credit card application, we will need the SMS OTP sent to the said mobile phone number to verify your identity;
We may inquire your credit information and/or credit report with the Basic Financial Credit Information Database and/or other credit reference agencies legally incorporated. |
| Purposes or Functions |
Inquiry of credit card application status |
| Information We Collect |
ID certificate number you provided at the time of application and SMS OTP |
| Purposes or Functions |
Activation of physical credit card |
| Information We Collect |
Credit card number, type/number of ID certificate, date of birth, card expiry date, CVV2 and SMS OTP |
| Purposes or Functions |
Activation of virtual credit card and inquiry password setting |
| Information We Collect |
Your name, type/number of ID certificate, date of birth, SMS OTP and your face feature information |
| Purposes or Functions |
Inquiry of virtual credit card information |
| Information We Collect |
Credit card inquiry password, SMS OTP and your face feature information |
| Purposes or Functions |
Credit Card Repayment and Repayment Setup |
| Information We Collect |
Credit Card Prompt Repayment: repayment Bank account, repayment amount, bank account of banks other than HSBC;
Credit Card Bill Setup: Mail address, E-mail address |
| Purposes or Functions |
Application for CIP or ALOC |
| Information We Collect |
Bank account number of the account to receive disbursement of CIP or ALOC and loan purpose;
We may inquire your credit information and/or credit report with the Basic Financial Credit Information Database and/or other credit reference agencies legally incorporated;
We may also need to obtain invoice or other transaction voucher from you to verify the purpose for use of the fund. |
| Purposes or Functions |
Know Special Offers Nearby |
| Information We Collect |
Receive the special offer activities information and the coupon. We may inquire your location information to show you promotion stores at your most convenience. |
| Purposes or Functions |
Logon to CVP platform |
| Information We Collect |
Last four digits of the card number (for credit card cardholders) or last four digits of your ID certificate number (for debit card cardholders), your mobile phone number and SMS OTP |
| Purposes or Functions |
Redemption of reward points |
| Information We Collect |
Your name, mobile phone number, ID certificate number, address information, credit card number, credit card status and credit card reward points balance.
We need to provide above information to third party vendor so as to deliver the goods you exchanged or purchased in the reward mall. |
| Purposes or Functions |
Opening CAT II and CAT III account |
| Information We Collect |
Photo of front side and back side of your ID certificate, name (including the former name), gender, number/valid period/ place of issuing of ID certificate, age, date of birth, place of birth, nationality, mobile phone number, email address, residence address, country and region of tax authority, tax payer identification number, employer and occupation information;
We need to obtain the card number of the debit card you applied for with other bank and the corresponding mobile phone number to verify your identity. |
| Purposes or Functions |
Appointment booking for home mortgage loan inquiry and inquiry of application status of home mortgage loan |
| Information We Collect |
Your name, type/number of ID certificate, as well as the city where you plan to purchase the real estate |
| Purposes or Functions |
Application for retail business loan |
| Information We Collect |
Business license number of the company which is financed by your loan, your name, ID certificate type and number, bank card number used for real-name verification, bank name, associated mobile phone number, name of the pledger (if any), type and number of identity certificate of the pledger (if any) |
| Purposes or Functions |
Enrolment in online or offline activities organized by us |
| Information We Collect |
Your name, area code, mobile phone number, province or area you are in, whether own personal account in HSBC or not |
| Purposes or Functions |
Improving service experience |
| Information We Collect |
Information you provide when raising your feedback, suggestion or complaint, information you input when participating in campaigns or surveys
Meanwhile, to assure the service quality, we may record the service call content. We will provide necessary hint before recording to protect your right to be informed and the right of choice. |
| Purposes or Functions |
Provide Marketing and Event Information |
| Information We Collect |
Information you provide to participate in our marketing campaigns, events or surveys. Only after obtaining your consent or on your own request, we will then contact you, send you information about products and services information you may be interested in, invite you to participate in our events and surveys, or send you promotion information.
If at any time you would like change your choice on this part, you can exercise your right of choice by referring to the relevant section 9 in Article VIII of this Policy “Your Rights Relating to Personal Information”. |
| Purposes or Functions |
Provide Personalized Contents |
| Information We Collect |
The information you provide when you open an account at our bank, buy our products, use our services, and participate in our marketing activities. We will collect and analyse this information to provide you with more accurate, convenient and personalized content display or information push / sending services. If at any time you would like change your choice on this part, you can exercise your right of choice by referring to the relevant section 7 in Article VIII of this Policy “Your Rights Relating to Personal Information”. |
| Purposes or Functions |
Uploading from Document Center |
| Information We Collect |
To certify your eligibility of the investment products’ application and insurance, you need to upload documents as evidence, in which might include info like name, passport number, nationality, date of birth, gender, ID certificate. |
| Purposes or Functions |
Fraud risk control when using mobile banking applications after login |
| Information We Collect |
After you log in to your mobile banking application, to control the risk of fraud, we collect the GPS location of the device to you. You can manage location authorization in the feature rights page of your device, especially for Android phones with Google GMS (Google Mobile Service), you can set whether to enable Google Basic Services to get GPS location information in your phone rights management. |
If you refuse to provide the above information, you are not able to use or enjoy the relevant functions, but your use of other functions of our digital banking will not be adversely affected.
|
Permitted Functions |
|---|---|
|
Identity recognition, logon, and verification using fingerprint(s) |
|
Logon mobile banking via facial recognition on some type of device |
|
QR code payment, upload of application materials for loan and other business/service, facial recognition, bank card identification, ID certificate identification |
|
Upload of profile photo, upload of application materials for loan and other business/service, electronic receipt storage, QR code scanning, bank card and ID certificate identification |
|
To improve the information accuracy for retailers with credit card offers and to enhance marketing messages for customers who are currently located outside of mainland China, including information on account opening, loans, insurance and more, and the risk control of fraud after the mobile bank logs in. |
|
Voice input, voice verification and recognition services |
|
Fund transfer via mobile phone number, friends and family referral. We only obtain the contact information you select from your contacts and do encrypted transmission to prevent malicious interception. |
|
SMS notification service |
|
Push messages with alerts, sounds and icon tags |
|
Upload of profile photo, upload of application materials for loan and other business/service, electronic receipt storage, QR code scanning, bank card and ID certificate identification |
|
To maintain proper and secure operation of digital banking services, prevent and control fraud risk |
|
For message push |
|
For accessing the network |
|
|
|---|---|
| Permitted Functions |
Identity recognition, logon, and verification using fingerprint(s) |
|
|
| Permitted Functions |
Logon mobile banking via facial recognition on some type of device |
|
|
| Permitted Functions |
QR code payment, upload of application materials for loan and other business/service, facial recognition, bank card identification, ID certificate identification |
|
|
| Permitted Functions |
Upload of profile photo, upload of application materials for loan and other business/service, electronic receipt storage, QR code scanning, bank card and ID certificate identification |
|
|
| Permitted Functions |
To improve the information accuracy for retailers with credit card offers and to enhance marketing messages for customers who are currently located outside of mainland China, including information on account opening, loans, insurance and more, and the risk control of fraud after the mobile bank logs in. |
|
|
| Permitted Functions |
Voice input, voice verification and recognition services |
|
|
| Permitted Functions |
Fund transfer via mobile phone number, friends and family referral. We only obtain the contact information you select from your contacts and do encrypted transmission to prevent malicious interception. |
|
|
| Permitted Functions |
SMS notification service |
|
|
| Permitted Functions |
Push messages with alerts, sounds and icon tags |
|
|
| Permitted Functions |
Upload of profile photo, upload of application materials for loan and other business/service, electronic receipt storage, QR code scanning, bank card and ID certificate identification |
|
|
| Permitted Functions |
To maintain proper and secure operation of digital banking services, prevent and control fraud risk |
|
|
| Permitted Functions |
For message push |
|
|
| Permitted Functions |
For accessing the network |
For those functions that need your permission, you may, at your free choice, decide whether to additionally grant the permission for the said functions on mobile banking applications. If you refuse to grant permission for a specific function, you are not able to use that specific function, but your use of other functions in our mobile banking will not be adversely affected.
6. When you use our mobile banking service, under certain particular scenarios, we will use the software service toolkit provided by a third party(“SDK”). To provide the service to you, such third party SDK will collect your information. For details, please refer to Annex I.
If you refuse to agree on the SDK service providers listed under Annex I to collect your information, you may not be able to access these services, but you can still access to other functionality or services on digital banking.
7. Please understand that the digital banking services we provide to you are constantly evolving. If you choose to use any other service not listed above for which we have to collect your information, we will separately explain to you, the purposes, methods and scope of personal information we collect, through reminders on pages, interaction with you or agreements entered into with you or other appropriate method, and obtain your consent for that. We will use, store, disclose and protect your information in accordance with this Policy and other agreements (if any) between you and us. If you choose not to provide certain information, you may be unable to use certain or part of the service, but your use of other services we provide will not be affected.
III. How We Use Your Personal Information
1. We will use your information in the following circumstances:
(1) To realize the purposes and functions mentioned in above Article II of this Policy “How We Collect Your Personal Information”; to contact you, or to approve, process, manage, execute or effect your application or instruction for transactions;
(2) To ensure safe and stable financial services, we will use your information for identity verification, safety precaution, fraud detection, prevention or prohibition of illegal or incompliant activities, control or reduction of risks, recording or filing purposes;
(3) To comply with the applicable laws and regulations or discharge of legal duties; to report to relevant regulators or other authorities according to laws, regulations or regulatory requirements;
(4) To maintain and improve digital banking service or any function thereof, develop new service or function (if use of your personal information in the new service or function goes beyond your consent, we will obtain your additional consent before we use your information for such new service or function);
(5) Subject to your authorization, to promote the Bank’s other products and services and to recommend to you the products or services that may interest you;
(6) To make statistics and analysis of the use of our business, products, services or functions; we may share such statistics to the public or third parties to present overall trend of relevant business, products, services or functions. But such statistics will not contain any of your personal identifiable information.
2. The above content related to information collection and use in this Policy shall not impact our use of your information for the purposes as otherwise agreed between you and us separately.
3. If we use your personal information for the purposes other than the purposes of information collection and use as set forth in this Policy or in other agreement between you and us, we shall let you know how we use this information and obtain your consent before using your personal information for such additional purposes as per applicable laws and regulations.
IV. How We Store Your Personal Information
In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored in the territory of the People's Republic of China. Since we provide products or services through resources and servers across the world, which means that to the extent permitted by regulatory rules and applicable laws, your personal information may be transferred to the foreign jurisdiction, or be accessed from these jurisdictions. If we transfer your personal information overseas, we will comply with applicable laws and regulations related to cross border data sharing. Whether it is processed domestically or overseas, in accordance with applicable data protection legislation, your personal information will be protected by a strict code of secrecy and security which, the Bank, other members of the HSBC Group, their staff and third parties are subject to.
We comply with Chinese laws and regulations on data storage. When we collect or process your information, we will, according to applicable laws and regulations, regulatory, archival, accounting, auditing or reporting requirements, and the purposes as set forth in this Policy, store your information for a period as minimum as necessary to fulfill the purposes of information collection. In this regard, we have developed data retention policies, under which the actual data retention period is defined accordingly as per the specific business scenario and business nature. After the retention period expires under relevant data retention policy, we will destroy, delete or anonymize relevant information, or where the destruction, deletion or anonymization is not possible, store your personal information in a safe and segregation way. The exception is when the information needs to be retained according to applicable laws and regulations, regulatory, archival, accounting, auditing or reporting requirements, special agreement between you and us, or for settlement of indebtedness between you and us, or for record check or enquiry from you, regulators or other authorities.
V. How We Share, Transfer and Publicly Disclose Your Personal Information
1. Entrusted Processing and Sharing
For the purposes set out above in this Policy, we may provide or disclose all or part of your personal information to the following recipients under the preconditions that such provision or disclosure is necessary and is made with proper protective measures (please refer to Article I of this Policy “How We Protect Your Personal Information” for details) and the recipients may also, for the aforesaid purposes, use, process or further disclose the information they receive provided that corresponding protective measures are adopted pursuant to the applicable laws or our requirements:
(1) any member of the HSBC Group;
(2) any contractor, subcontractor, agent, third party product or service provider, licensor, professional consultant, business partner, or associated person of the HSBC Group (including their employees, directors and officers);
(3) any regulator of the Bank or any member of the HSBC Group or any other authority, or any organisation or individual designated by such regulators or authorities;
(4) anyone acting on your behalf according to your authorisation or according to law, payment recipients, beneficiaries, account agents , correspondent and agent banks (e.g. for CHAPS, BACS, SWIFT), clearing houses, clearing or settlement systems, or anyone making any payment to you;
(5) any person or related party who has the right or obligation, acquires an interest or assumes risk, in or in connection with any product or service you receive from the Bank, or any business you handle at the Bank or any transaction you make with the Bank (for example, the person who provides or intends to provide any mortgage or other security for any of your debt to the Bank, or the beneficiary of the insurance product that the Bank distributes to you);
(6) other financial institutions, industrial associations, bank card organisations, credit rating agencies, credit reference agencies (including without limitation, the Basic Financial Credit Information Database or information service providers);
(7) any third party fund manager providing you with asset management services through us;
(8) any third party to whom we provide referral, agency or intermediary service;
(9) any party in connection with any business/asset transfer, restructure, disposal, merger, spin-off or acquisition transactions of the Bank.
Subject to applicable laws and regulations, we will seek your separate consent (if legally required) and notify you of the data sharing with the third parties, including the data receiver’s identity, contact information, purpose of processing, method of processing and the type of personal information.
In case of cross border personal data sharing, we will also conclude a data protection agreement with the offshore personal information recipient, and if required, in the format of standard data protection clause issued by Cyberspace Administration of China as well as specify your relevant personal information subject’s right in your capacity as a third party beneficiary under said agreement pursuant to applicable laws and regulations, for example the manner and method of exercising your right towards the offshore personal information recipient. If you want to know more details about aforesaid data protection agreement, you may contact us to raise such request via the method listed in Article IX of this Policy “How to Contact Us”.
2. Transfer
Without your separate consent, we will not transfer your personal information to any other company, organization or individual, except in the case of business/asset transfer, restructure, disposal, merger, spin-off or acquisition transactions where the transfer is necessary. Where any personal information is transferred, we will inform you of the identity and contact method of the personal information recipient as per applicable laws and regulations as well as request said recipient to comply with this Policy. If the personal information recipient changes the purpose and method of personal information processing activities under this Policy, it shall obtain separate consent from you.
3. Public Disclosure
We will not disclose your personal information to the public unless we have your separate consent.
VI.Special Circumstances for Information Processing
We will process your personal information (such as information collection, storage, use, analysis, transfer, provision, disclosure) based on your consent. To the extent allowed by laws and regulations, we may process your personal information without your consent under the following circumstances:
(1) where it is necessary for entering into a contract or the performance of a contract to which you are the party;
(2) where it is necessary for compliance with a legal obligation to which we are subject;
(3) where it is necessary in order to protect your or others’ vital interests related to life and property in an emergency or respond to public health emergencies;
(4) where it is within reasonable limits in order to carry out news coverage or media supervision for the public interest;
(5) where it is within reasonable range according to law to process the information which has been legally made public or publicized by yourself;
(6) other circumstances stipulated by laws and regulations.
VII. How We Use Cookies and Similar Technologies
1. Your visit, browse, use of any of our website or digital banking service related applications may be recorded for analysis on the number of visitors to the site and/or applications, general use patterns and your personal use patterns and improving your experience. Some of this information will be gathered through the use of "Cookies" and similar technologies. Such technologies can enable our website or applications to recognise your device and store information about your use of website and/or applications so to provide continuous services to you and to tailor the content of our website/applications to suit your interests and, where permitted by you, to provide you with promotional materials based on your use patterns. We will be able to access the information stored on the Cookies and similar technologies for the aforesaid purpose.
The information collected by Cookies is anonymous aggregated data, and contains no personal information, such as name, address, telephone, email etc.
2. Most local terminals are initially set to accept Cookies. You can manage or disable Cookies based on your own preference. Should you wish to disable the Cookies, you may do so by changing the setting on your local terminals. However, after changing the setting you may not be able to enjoy the convenience that Cookies bring, but your normal use of other functions of the local terminals will not be affected.
VIII. Your Rights Relating to Personal Information
1. You have the right to request us to protect and secure your personal information in accordance with the provisions of the law, regulation and this Policy. You have the right to exercise your rights of individual granted by applicable laws and regulations
2. Right of access to data/copies of data: you have the right to check with us whether we hold your personal information and to access and copy your personal information. You can log in to our mobile banking application and go to the Me > Personal Information page to see your basic profile.
3. Right to rectification of errors: you have the right and obligation to update your personal information at the Bank in a timely manner to ensure that relevant information is accurate and up-to-date. You have the right to request us to facilitate your update of personal information and to request us to correct any inaccurate information about you. You can log in to our mobile banking application and go to Me > Personal Information, or you can log in to our online banking and click on your name > Update Personal Information and Contact Information in the upper right corner to update your personal information such as email, home phone number, fax number, mobile phone number, corporate phone number, corporate fax number, occupation information and mailing address.
4．Right to change or withdraw consent: you have the right to change the scope of your authorized consent and to withdraw your consent. However, your decision to withdraw your consent will not affect the handling of personal information previously conducted on your consent. Specifically, you can change your choice related to "marketing preferences" through our mobile banking application and/or, our WeChat applet; turn on/off geographic location permissions, photo album permissions, camera permissions, fingerprint permissions etc., through "Settings->HSBC Mobile Banking" on your mobile device to change or withdraw your device's functional permissions to us.
5. Right to deletion: you are entitled to require us to delete or otherwise properly dispose your personal information that exceeds the retention period in accordance with applicable laws and regulations, this Policy and your agreement with us. You can raise such request via the method described in Article IX of this Policy “How to Contact Us”. If we cease to operate, we will stop collecting your personal information in a timely manner, notify you of such operation cessation via courier or public announcement, and delete or anonymize your personal information held, except as otherwise provided by laws and regulations or where the personal data deletion is technically not possible.
6．Right to cease online banking service: you have the right to uninstall digital banking service related applications. Please note that to uninstall the applications will not cease your online banking service. You have the right to cease your online banking service (by closing all your bank accounts or raising request of de-registering online banking service, for the sake of account safety we advise you to visit our branches or sub-branches in person for such closure) and request for deletion of your personal information in accordance with the applicable laws and regulations, this Policy, and other agreement between you and us. You can raise deregistration request of online banking service through Mobile Bank channel- Online Customer Service. You can also raise the request by visiting our branches or sub branches in person, and you need to provide ID certificate, personal online banking change/closing form for such deregistration purpose. It will take us three to five working days to handle your request and close your account. After you cease your online banking service, we will no longer collect your information through relevant channel. we will store and delete your personal information pursuant to Article IV of this Policy “How We Store Your Personal Information” .
7. Automated decision-making related: you have the option of using the “personalized recommendation” feature. The “personalized recommendation” feature is designed to enhance your experience, and recommend contents for more relevant information based on your personal characteristics and preferences, data analysis or automated decision making. You have the right to decide and manage how to set up this feature. If you want to turn this feature on or off, you can use our mobile banking application Me > Settings & Preferences; or HSBC China WeChat Applet > Help and Tools, to find the “Personalization and Marketing Preferences” menu, and make your adjustment on “Personalized Content” page and the “Marketing Preferences” page – “Personalized Marketing Information” section. Among them, the switch of the " Personalized Content" page is used to control whether the products and marketing information displayed to you on our electronic channels use the "Personalized Recommendation" function. Turning off the switch, we will display general products and marketing information not based on your personal characteristics. The “Marketing Preferences” page – “Personalized Marketing Information” section controls whether the “Personalized Recommendation” feature is used by the Bank when proactively push products and marketing information to you by phone, text message, email, etc. Turning off this switch will not affect your access to that type of push information, but the push you receive will be general product and marketing information that is not based on your personal characteristics.
In some occasions, we may make decisions only on the basis of automated decision-making mechanisms without human intervention such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us and we will provide an appropriate solution.
8．Personal credit related: in cases related to personal credit, you have the right to request to be informed of your personal information that is disclosed to credit reference agencies by us, so as to enable your request to the relevant credit reference agencies for access to and correction of your information.
9．Marketing information related: unless we have your prior consent, we will not send you advertisement promotion message. If at any time you would like us to cease using or providing to others your personal information for advertisement promotion purpose, you are entitled to notify us and exercise your right of choice, not to receive such advertisement promotion any more. If you so choose to reject advertisement promotion message, or you wish to adjust your channels of communication for receiving marketing information, you can access My > Settings and Preferences at our mobile banking application, or Help & Tools in the HSBC China WeChat applet, to the “Personalized and Marketing Preferences” menu, to self-adjust on the “Marketing Preferences” page, or you can also call 95366 to contact our Customer Service Center to adjust for you.
10. Responding to your request: in addition to the above-mentioned ways of exercising your rights, you may also make your request in the manner listed in Article IX of this Policy "How to Contact Us".
For security purpose, you may need to raise your request in written form or use other methods to prove your identity. We may request you to verify your identity before processing your request. We will complete the verification and processing within 15 working days upon receipt of your request or within a shorter period of time as prescribed by laws and regulations (if any).
We will not charge fees for the processing of your above-mentioned reasonable requests for checking, correcting or otherwise disposing of your personal information.
Notwithstanding the foregoing, we may reject your request if it is illegal, noncompliant or unnecessarily repeated, needs excessive technical means (for example, the need to develop information systems or fundamentally change current practices), brings risks to the legitimate rights and interests of others, is unreasonable or technically impracticable.
We may not be able to respond to your request under any of the following circumstances:
(1) where the request is in relation to our legal and financial compliance obligation under laws and regulations.
(2) where the request is in direct relation to state security or national defence security;
(3) where the request is in direct relation to public security, public sanitation, or major public interests;
(4) where the request is in direct relation to criminal investigations, prosecutions, trials, execution of rulings, etc.;
(5) where there is sufficient evidence that you are intentionally malicious or abuse your rights;
(6) where the purpose is to protect you or other individual’s life, property and other substantial legal interests but difficult to acquire your consent；
(7) where responses to your request will give rise to serious damage to your or any other individual or organisation’s legal rights and interests; or
(8) where the request involves any trade secret.
IX.How to contact us
Requests for a copy of this Policy, or enquiries about our practices regarding personal information and privacy protection, as well as exercising other rights you are granted by laws and regulations can be raised via Contact HSBC and/or addressed to:
Data Privacy Officer (DPO)
HSBC Bank (China) Company Limited
36/F HSBC Building, Shanghai IFC, 8 Century Avenue, Pudong, Shanghai, 200120
E-mail: hsbcaoc@hsbc.com.cn
Tel: +86 95366 (8:30am - 5:30pm, Monday to Friday during the working days)
Unless otherwise specified in other sections of this Policy, we will normally respond to you within 15 working days upon receipt of your questions, complaints, feedbacks, opinions or suggestions or within a shorter period of time as prescribed by laws or regulations (if any). Same as above, we may require you to verify your identity before processing your request and may under certain circumstances be unable to respond to your request (see Article VIII Section 10 of this Policy regarding the identity verification process and the exceptional circumstances that cannot be responded to).
You may supervise or make suggestions for our practices regarding personal information and privacy protection, and lodge complaints or file a lawsuit with the competent Chinese court according to law against us or our staff for any infringement of your rights and interests in your personal information and privacy.
You may contact us through the contact information listed in this Policy, by calling our hotline or visiting our branches or sub-branches. You may also visit our official website www.hsbc.com.cn or official WeChat account “汇丰中国客户服务” (WeChat ID: HSBCeBanking) to enquire the nearby branches or sub-branches, or other contact information of us suitable for you.
X. Protection of Minors' Personal Information
1．We pay particular attention to protection of the minors’ personal information. We have no intention to collect any minors’ personal information, unless it is agreed by their parents or guardians and it is necessary for the products or services offered to the minors (for example, the minors may be the holders of the Junior Account offered by us, the holders of supplementary card of certain credit cards issued by us, the beneficiaries of the insurance products that we distribute, the heirs of our customers, etc.)
2．If you are under the age of 18 (including children under the age of 14), it is suggested that your parents or guardians should carefully read this Policy and any of your personal information should be provided only after seeking consent from them. Meanwhile, it is suggested that your use of our products and services should be under the guidance of your parents or guardians. If they do not agree you to provide your personal information or to use any of our products or services, you should immediately stop providing the information or stop using our products and services. Please notify us of such event as soon as possible, so as to allow us to take appropriate measures accordingly.
3. If you are under the age of 18 (including children under the age of 14), for those personal information we collect with the consent of your parents or guardians, we will only use or disclose such information to the extent allowed by law and regulation or expressly consented by your parents or guardians or necessary for protection of the minors’ interests.
XI. Formulation, Effectiveness, Update of this Policy and Others
1． The Policy is made by us and published at our digital banking service related websites or applications and takes effect on the effective date as indicated at the beginning of this Policy. The Policy may be amended or updated from time to time, particularly in the events of major changes as follows:
(1) Major changes in our service model, such as changes in the purpose of processing personal information, changes in the types of personal information being processed, the use methods of personal information, etc.;
(2) Major changes in our ownership structure, organisational structure, etc., such as changes as result of business adjustments, bankruptcy, mergers, etc.;
(3)Changes in the main objects of personal information sharing, transfer or public disclosure;
(4)Significant changes in your rights relating to personal information or in the methods to exercise such rights;
(5) Changes of our contacts for personal information related requests/enquiries, changes of our contacts for complaint or feedback;
(6) Other major changes which may significantly impact your interests in personal information.
We will post the changes to the Policy or the updated Policy through push notifications, pop-ups, announcements etc., on our digital banking service related websites and/or applications to keep you up-to-date on this Policy. Changes to the Policy shall not diminish or limit the rights you should have as a Personal Information Subject under applicable laws and regulations.
You can access to the Policy via “Me – General – Legal Terms – Privacy and Security”, HSBC Mobile Banking APP or via ”My HSBC – Help and Tools – Privacy Policy”, HSBC official WeChat account “汇丰中国客户服务”. You shall pay attention to the changes of relevant announcements, reminders, agreements, rules, and so on from time to time. You acknowledge and confirm that if you do not agree to the updated content, you shall immediately cease the use of the relevant service and cancel the relevant account, and in this case we will cease the collection of your relevant personal information. If you continue to use our digital banking service after this Policy amendment, it will be treated that you have fully read, understood and accepted this Policy amendment and agreed with us to collect, use, store and share your relevant information in accordance with the updated Policy.
2. Where you provide to us personal information about another person, you should ensure that person acknowledges this Policy and, in particular, tell him/her how we may collect and use his/her personal information and obtain the consent/authorization of such person. You should remind that person to read this Policy in advance and may also give him/her a copy of this Policy.
3. In case of discrepancy between the Chinese and English versions of this Policy, the Chinese version shall apply and prevail.
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| SDK Name | Third-party Agency Name | Business Scene | SDK User Information | Usage Purpose |
|---|---|---|---|---|
| Gaode Positioning SDK | Gaode Software Co., Ltd | Branch networks near you | Store permissions, device unique identifiers, latitude and longitude information，hardware serial number, IP address, MAC address, coarse location information |
Location functions |
| Mobile Push TPNS SDK | Shenzhen Tencent Computer System Co., Ltd | Push service notification on mobile terminal devices |
Device vendor, system language, mobile phone model, network type, notification bar status, running app process | Performs message push |
| TPNS SDK contains the VIVO Push SDK | Vivo Mobile Communications Ltd | When using vivo vendor push (vivo vendor push is not turned on for this app) | Device identification information (IMEI, EmmCID, UFSID, , GUID, GAID, OPENID, VAID, OAID, RegID, encrypted Android ID), application software information using push services (app package name, version number, APPID, installation, uninstall, recovery from factory settings, running status), device manufacturer, network type, country code, device type, timestamp for message creation/delivery and click, message content, push SDK version number, device model, operating system version, current network type, message sending result, notification bar status (e.g. notification bar permissions, user click behavior), lock screen status (e.g. lock screen notification) Allow lock screen notification) |
Improve message arrival rate |
| TPNS SDK contains the OPPO Push SDK | Guangdong Huantai Technology Co., Ltd. | When using OPPO Vendor Push (OPPO Vendor Push Not Enabled for This App) | Message content, device-related information (IMEI or OAID, Serial Number, IMSI, User ID, Android ID, Google Advertising ID, mobile Region settings, device model, phone power, mobile operating system version and language), application information using push services (APP package name and version number, running state), push SDK version number, network-related information (e.g., current network type of IP or domain name connection result), message sending result, notification bar status (e.g. notification bar permissions, user click behavior), lock screen status (e.g., whether lock screen notification is allowed), instructions from advertisers or developers to collect device identification codes (IMEI or OAID), IP addresses, client systems, client network |
Improve message arrival rate |
| TPNS SDK contains the Xiaomi push SDK | Beijing Xiaomi Mobile Software Co., Ltd | When using the Xiaomi vendor push | 1. Android version: device identification (OAID and encrypted Android ID), and application information using push services such as app package name, version number, and running state; |
Improve message arrival rate |
| TPNS SDK contains Meizu Push SDK | Zhuhai Meizu Communications Equipment Co., Ltd |
When using Meizu Vendor Push (This app has not turned on Meizu Vendor Push yet) |
Device information (phone model, IMEI number, UUID), application information, log information, other information, location information, push SDK version number, network related information, message sending result, notification bar status, lock screen status |
Improve message arrival rate |
TPNS SDK contains the Huawei Push SDK |
Huawei Software Technology Co., Ltd |
When using the Huawei vendor push |
Application Basic Information (AppID, Application Version Number and Application Package Name, Huawei Push SDK Version Number, Installed Application List is used to obtain the Push Service Application and HMS Core Application Version Number), Application Device Identifier (AAID, Push Token), Device Identifier (Android ID), Device Hardware Information (Device Type, Device Model), System Basic Information (System Type, System Version), System Setup Information (Country Code), Network Information (BSSID) |
Improve message arrival rate |
TPNS SDK contains Google FCM SDK |
Google LLC |
When using pushing FCM. (This app is not currently turning on FCM vendor push.) |
IP Address, Mobile Ad IDFV, androidID, FireBase Installation ID, Analytics Apps, Device Information, Push Message Related Information |
Improve message arrival rate |
Yidao Bo shi SDK |
Beijing Yidao Bo shi Technology Co., Ltd |
Registration and RMB transfer |
Obtain ID number through device scanning function, bank card number information |
Scanning ID card number obtaining ID card number and scanning bank card number obtaining bank card number |
The Face++ SDK |
Beijing Kuangshi Technology Co., Ltd |
Mobile phone number transfer, credit card virtual card activation, set query passwords, and view CVV2. open Cat Ⅱ、Cat Ⅲ account |
verify your identity by identifying your facial features and moving actions, but not storing your facial features and actions |
Get camera permissions for face recognition |
Sensors Data SDK |
Sensors Data Network Technology (Beijing) Co., Ltd |
Improving customer experience during the use of mobile App |
Obtain device information (including IMEI, Android ID, IDFA, IDFV, OAID, UUID, Mac address, IMSI information, etc.), log information (including IP address, URL for accessing services, browser type and language used, etc.), location information, unique application number. |
User access behavior analytics |
| WeChat SDK | Tencent Computer Systems Limited |
binding your WeChat account to our bank's mobile banking，allowing you to log in through your WeChat account and using our WeChat bank's products or services |
To access your authorized and shared WeChat account information (WeChat profile photo, WeChat name, region, gender) from WeChat |
log in to our bank's mobile banking services via WeChat account |
AppDynamics SDK |
AppDynamics LLC |
Availability Improvement of mobile app |
Get device vendor, phone model, network type, telecom operator, system version, app log information |
Statistics of App performance and availability |
RASP SDK |
OneSpan | Detects the integrity of the app and whether the customer's phone has a security vulnerability |
Reads the list of installed apps and running process lists to protect the app |
Preventing customers from running the app on a mobile phone with security issues |
Tencent Big Data SDK |
Tencent Computer Systems Co., Ltd |
New to bank user apply for opening Catt II\Cat Ⅲ account through WeChat channel |
Collect equipment models, GPS longitude and latitude, mobile phone serial number (IMEI), |
Used to create equipment fingerprints for anti-fraud purpose |
Ali mPaaS SDK and the included Ali cloud face recognition SDK, Alipay payment SDK, Ali fastjson, Ali UC crash SDK, UC browser service SDK |
Ali Cloud Computing Co., Ltd |
Provides remote sales services |
Use on line video call capabilities provided by Ali mPaas SDK. obtain mobile phone cameras, microphones, access network, access network status, access WI-FI status, foreground services, background voice，writing to an external storage file permissions |
Provide remote sales services to ensure that the remote sales functions are smooth |
OAID SDK |
China Information Communications Research Institute |
Vendors push |
Device manufacturers, device models, device brands, device network operator names and App package names and signature information need to be collected, or collecting the APPID of the corresponding Store |
The invention is used for generating device unique identifier, anonymous device identifier, developer anonymous device identifier and application anonymous device identifier, which is pushed to the manufacturer for use. |
Yunzhengtong (China Financial Certification Center CFCA) |
China Financial Certification Center |
Login and Transaction authentication |
For AOS system SDKs, device information, model number, brand name, system image compilation information, system image compilation sequence, vendors, and chip vendors will be collected. For IOS systems, the SDK collects IP addresses. |
For electronic certificate issuance, download and electronic signature services |
Zhong'an SDK |
Zhong'an Information Technology Service Co., Ltd |
when you use our investment and insurance transactions (including application/subscription, contract signing, redemption, conversion, regular investment, cancelation of bills, and insurance purchase) through mobile banking and on line banking channels |
Collect the record of customer operation behavior |
For retrospective inspection and verification evidence obtaining |
| Convertlab SDK | Shanghai Xin Zhao Yang Information Technology Co., Ltd |
During the use of the mobile phone app |
Obtains your mobile phone IP, device manufacturer, model of the mobile phone, network type, browser type and browsing behavior |
User Access statistics and Customer Behavior Analytics |
Chromium SDK |
Uses Built-in Browser To Browse Web |
To Collect SSID, Wi-Fi Information, Sensors, Application List Information |
View webpage through Browser |
|
okhttp/retrofit2.0/okio |
The Apache Software Foundation |
For system development |
Do not collect personal information |
For system development |
| Appache | The Apache Software Foundation |
For system development |
Do not collect personal information |
For system development |
bouncycastle |
Legion of the Bouncy Castle Inc. |
For system development |
Do not collect personal information |
For system development |
injekt-coroutines-jvm |
The Apache Software Foundation |
For system development |
Android ID |
For system development |
| SDK Name | Gaode Positioning SDK |
|---|---|
| Third-party Agency Name | Gaode Software Co., Ltd |
| Business Scene | Branch networks near you |
| SDK User Information |
Store permissions, device unique identifiers, latitude and longitude information，hardware serial number, IP address, MAC address, coarse location information |
| Usage Purpose | Location functions |
| SDK Name | Mobile Push TPNS SDK |
| Third-party Agency Name | Shenzhen Tencent Computer System Co., Ltd |
| Business Scene |
Push service notification on mobile terminal devices |
| SDK User Information | Device vendor, system language, mobile phone model, network type, notification bar status, running app process |
| Usage Purpose | Performs message push |
| SDK Name | TPNS SDK contains the VIVO Push SDK |
| Third-party Agency Name | Vivo Mobile Communications Ltd |
| Business Scene | When using vivo vendor push (vivo vendor push is not turned on for this app) |
| SDK User Information |
Device identification information (IMEI, EmmCID, UFSID, , GUID, GAID, OPENID, VAID, OAID, RegID, encrypted Android ID), application software information using push services (app package name, version number, APPID, installation, uninstall, recovery from factory settings, running status), device manufacturer, network type, country code, device type, timestamp for message creation/delivery and click, message content, push SDK version number, device model, operating system version, current network type, message sending result, notification bar status (e.g. notification bar permissions, user click behavior), lock screen status (e.g. lock screen notification) Allow lock screen notification) |
| Usage Purpose | Improve message arrival rate |
| SDK Name | TPNS SDK contains the OPPO Push SDK |
| Third-party Agency Name | Guangdong Huantai Technology Co., Ltd. |
| Business Scene | When using OPPO Vendor Push (OPPO Vendor Push Not Enabled for This App) |
| SDK User Information |
Message content, device-related information (IMEI or OAID, Serial Number, IMSI, User ID, Android ID, Google Advertising ID, mobile Region settings, device model, phone power, mobile operating system version and language), application information using push services (APP package name and version number, running state), push SDK version number, network-related information (e.g., current network type of IP or domain name connection result), message sending result, notification bar status (e.g. notification bar permissions, user click behavior), lock screen status (e.g., whether lock screen notification is allowed), instructions from advertisers or developers to collect device identification codes (IMEI or OAID), IP addresses, client systems, client network |
| Usage Purpose | Improve message arrival rate |
| SDK Name | TPNS SDK contains the Xiaomi push SDK |
| Third-party Agency Name | Beijing Xiaomi Mobile Software Co., Ltd |
| Business Scene | When using the Xiaomi vendor push |
| SDK User Information |
1. Android version: device identification (OAID and encrypted Android ID), and application information using push services such as app package name, version number, and running state; |
| Usage Purpose |
Improve message arrival rate |
| SDK Name | TPNS SDK contains Meizu Push SDK |
| Third-party Agency Name |
Zhuhai Meizu Communications Equipment Co., Ltd |
| Business Scene |
When using Meizu Vendor Push (This app has not turned on Meizu Vendor Push yet) |
| SDK User Information |
Device information (phone model, IMEI number, UUID), application information, log information, other information, location information, push SDK version number, network related information, message sending result, notification bar status, lock screen status |
| Usage Purpose |
Improve message arrival rate |
| SDK Name |
TPNS SDK contains the Huawei Push SDK |
| Third-party Agency Name |
Huawei Software Technology Co., Ltd |
| Business Scene |
When using the Huawei vendor push |
| SDK User Information |
Application Basic Information (AppID, Application Version Number and Application Package Name, Huawei Push SDK Version Number, Installed Application List is used to obtain the Push Service Application and HMS Core Application Version Number), Application Device Identifier (AAID, Push Token), Device Identifier (Android ID), Device Hardware Information (Device Type, Device Model), System Basic Information (System Type, System Version), System Setup Information (Country Code), Network Information (BSSID) |
| Usage Purpose |
Improve message arrival rate |
| SDK Name |
TPNS SDK contains Google FCM SDK |
| Third-party Agency Name |
Google LLC |
| Business Scene |
When using pushing FCM. (This app is not currently turning on FCM vendor push.) |
| SDK User Information |
IP Address, Mobile Ad IDFV, androidID, FireBase Installation ID, Analytics Apps, Device Information, Push Message Related Information |
| Usage Purpose |
Improve message arrival rate |
| SDK Name |
Yidao Bo shi SDK |
| Third-party Agency Name |
Beijing Yidao Bo shi Technology Co., Ltd |
| Business Scene |
Registration and RMB transfer |
| SDK User Information |
Obtain ID number through device scanning function, bank card number information |
| Usage Purpose |
Scanning ID card number obtaining ID card number and scanning bank card number obtaining bank card number |
| SDK Name |
The Face++ SDK |
| Third-party Agency Name |
Beijing Kuangshi Technology Co., Ltd |
| Business Scene |
Mobile phone number transfer, credit card virtual card activation, set query passwords, and view CVV2. open Cat Ⅱ、Cat Ⅲ account |
| SDK User Information |
verify your identity by identifying your facial features and moving actions, but not storing your facial features and actions |
| Usage Purpose |
Get camera permissions for face recognition |
| SDK Name |
Sensors Data SDK |
| Third-party Agency Name |
Sensors Data Network Technology (Beijing) Co., Ltd |
| Business Scene |
Improving customer experience during the use of mobile App |
| SDK User Information |
Obtain device information (including IMEI, Android ID, IDFA, IDFV, OAID, UUID, Mac address, IMSI information, etc.), log information (including IP address, URL for accessing services, browser type and language used, etc.), location information, unique application number. |
| Usage Purpose |
User access behavior analytics |
| SDK Name | WeChat SDK |
| Third-party Agency Name |
Tencent Computer Systems Limited |
| Business Scene |
binding your WeChat account to our bank's mobile banking，allowing you to log in through your WeChat account and using our WeChat bank's products or services |
| SDK User Information |
To access your authorized and shared WeChat account information (WeChat profile photo, WeChat name, region, gender) from WeChat |
| Usage Purpose |
log in to our bank's mobile banking services via WeChat account |
| SDK Name |
AppDynamics SDK |
| Third-party Agency Name |
AppDynamics LLC |
| Business Scene |
Availability Improvement of mobile app |
| SDK User Information |
Get device vendor, phone model, network type, telecom operator, system version, app log information |
| Usage Purpose |
Statistics of App performance and availability |
| SDK Name |
RASP SDK |
| Third-party Agency Name | OneSpan |
| Business Scene |
Detects the integrity of the app and whether the customer's phone has a security vulnerability |
| SDK User Information |
Reads the list of installed apps and running process lists to protect the app |
| Usage Purpose |
Preventing customers from running the app on a mobile phone with security issues |
| SDK Name |
Tencent Big Data SDK |
| Third-party Agency Name |
Tencent Computer Systems Co., Ltd |
| Business Scene |
New to bank user apply for opening Catt II\Cat Ⅲ account through WeChat channel |
| SDK User Information |
Collect equipment models, GPS longitude and latitude, mobile phone serial number (IMEI), |
| Usage Purpose |
Used to create equipment fingerprints for anti-fraud purpose |
| SDK Name |
Ali mPaaS SDK and the included Ali cloud face recognition SDK, Alipay payment SDK, Ali fastjson, Ali UC crash SDK, UC browser service SDK |
| Third-party Agency Name |
Ali Cloud Computing Co., Ltd |
| Business Scene |
Provides remote sales services |
| SDK User Information |
Use on line video call capabilities provided by Ali mPaas SDK. obtain mobile phone cameras, microphones, access network, access network status, access WI-FI status, foreground services, background voice，writing to an external storage file permissions |
| Usage Purpose |
Provide remote sales services to ensure that the remote sales functions are smooth |
| SDK Name |
OAID SDK |
| Third-party Agency Name |
China Information Communications Research Institute |
| Business Scene |
Vendors push |
| SDK User Information |
Device manufacturers, device models, device brands, device network operator names and App package names and signature information need to be collected, or collecting the APPID of the corresponding Store |
| Usage Purpose |
The invention is used for generating device unique identifier, anonymous device identifier, developer anonymous device identifier and application anonymous device identifier, which is pushed to the manufacturer for use. |
| SDK Name |
Yunzhengtong (China Financial Certification Center CFCA) |
| Third-party Agency Name |
China Financial Certification Center |
| Business Scene |
Login and Transaction authentication |
| SDK User Information |
For AOS system SDKs, device information, model number, brand name, system image compilation information, system image compilation sequence, vendors, and chip vendors will be collected. For IOS systems, the SDK collects IP addresses. |
| Usage Purpose |
For electronic certificate issuance, download and electronic signature services |
| SDK Name |
Zhong'an SDK |
| Third-party Agency Name |
Zhong'an Information Technology Service Co., Ltd |
| Business Scene |
when you use our investment and insurance transactions (including application/subscription, contract signing, redemption, conversion, regular investment, cancelation of bills, and insurance purchase) through mobile banking and on line banking channels |
| SDK User Information |
Collect the record of customer operation behavior |
| Usage Purpose |
For retrospective inspection and verification evidence obtaining |
| SDK Name | Convertlab SDK |
| Third-party Agency Name |
Shanghai Xin Zhao Yang Information Technology Co., Ltd |
| Business Scene |
During the use of the mobile phone app |
| SDK User Information |
Obtains your mobile phone IP, device manufacturer, model of the mobile phone, network type, browser type and browsing behavior |
| Usage Purpose |
User Access statistics and Customer Behavior Analytics |
| SDK Name |
Chromium SDK |
| Third-party Agency Name | |
| Business Scene |
Uses Built-in Browser To Browse Web |
| SDK User Information |
To Collect SSID, Wi-Fi Information, Sensors, Application List Information |
| Usage Purpose |
View webpage through Browser |
| SDK Name |
okhttp/retrofit2.0/okio |
| Third-party Agency Name |
The Apache Software Foundation |
| Business Scene |
For system development |
| SDK User Information |
Do not collect personal information |
| Usage Purpose |
For system development |
| SDK Name | Appache |
| Third-party Agency Name |
The Apache Software Foundation |
| Business Scene |
For system development |
| SDK User Information |
Do not collect personal information |
| Usage Purpose |
For system development |
| SDK Name |
bouncycastle |
| Third-party Agency Name |
Legion of the Bouncy Castle Inc. |
| Business Scene |
For system development |
| SDK User Information |
Do not collect personal information |
| Usage Purpose |
For system development |
| SDK Name |
injekt-coroutines-jvm |
| Third-party Agency Name |
The Apache Software Foundation |
| Business Scene |
For system development |
| SDK User Information |
Android ID |
| Usage Purpose |
For system development |