Privacy Policy

Information about our use of personal data and cookies

BANDS Financial Limited ("BANDS"), with a place of business at Unit 1007, Level 10, Cyberport 1, 100 Cyberport Road, Pokfulam, Hong Kong ("we", "us" and "our"), operate the website ("Website") and other brokerage or ancillary services, applications and APIs ("Services"). BANDS acts as the Controller and is therefore responsible for your personal data.

Our Website uses cookies and other tools to help distinguish you from other users of the Website. This helps us provide you with a better experience when using the Services and improve the Services. This policy is designed to explain how we use the personal data we collect from you when you use our Website or Services and assist you in making informed decisions when using our Services. This privacy policy should also be read in conjunction with our cookie policy.

What is personal data?

Personal data is any information which is related to an identified or identifiable natural person.

Data subjects are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier or one of several special characteristics, which expresses the physical, physiological, genetic, mental, commercial, cultural or social identity of these natural persons. This may also include all data which is or can be assigned to a person in any kind of way, such as the telephone, credit card or personnel numbers of a person, account data, appearance, customer number or address information.

What personal data do we collect?

We may collect the following personal data depending on the relationship between you and BANDS and which of our Services you use:

  • Personal identification data - Your name, email address, phone number, IP address, ID number, etc.
  • Contact data - Your email address, phone & mobile number, address, etc.
  • User and Registration data - Your name, account name, nationality, ID number, contact number, etc.; any other necessary KYC or registration information
  • Financial and Transaction data - Your bank account details, payment information, information about Services provided to you, etc.

How do we collect your personal data?

You directly provide us with most of the personal data we collect. We collect and process personal data when:

  • you become a client of our Services
  • you voluntarily register online or otherwise sign up for events or activities organised by us;
  • you contact us by email, phone, in person or otherwise;
  • your actions and interactions with us as part of our Services;
  • we administer and manage your account or provide certain Services;
  • you use or view our Website via your browser's cookies;
  • from time to time, we collect personal data from publicly available resources such as social media, websites and media reports or through third parties such as event partners or introducing brokers.

Who do we collect personal data from?

We may collect and process personal data from the following people:

  • Clients - We collect all necessary personal data to satisfy legal and internal KYC and account opening requirements to provide our Services.
  • Counterparties, Suppliers, Serivce Providers and Partners - We collect all necessary personal data to meet legal and internal requirements to operate and provide Services to our clients.
  • Prospective Clients, Visitors and other People contacting us - We collect and process your personal data to the extent necessary to establish and maintain communication, such as publicly available information or any other personal data you voluntarily provide in connection with your interaction with us.
  • Event or Activity Participants - We may collect and process registration data you voluntarily provide when joining an event or other activity (co)-organised or supported by us.
  • Website Visitors - We collect and process your personal data in conneciton with your visit to and interaction with our website or other online Services.

Why do we collect and process personal data?

We primarily collect and process personal data where this is necessary for the provision of Services to our clients, carrying out our contractual duties and exercising our contractual rights and obligations and to comply with our legal and regulatory obligations.

We or a third party have legitimate interests in carrying on, managing and administering our respective businesses effectively and properly and in connection with those interests processing your personal data. Your data will not be processed on this basis if our or a third party's interests are overridden by your own interests, rights and freedoms.

We may also process your personal data when you have given your specific consent in cases where this is necessary.

In rare cases, we may also process your personal data in emergency situations where we cannot acquire consent or use another legal basis and are required to use your data or if it is in the public interest, such as in cases affecting the rights, health, or finances of the public at large.

How do we store your personal data?

We primarily store your personal data in the Hong Kong Special Administrative Region ("HKSAR"). However, BANDS is a globally active commodities broker. We may transfer your personal data abroad in connection with the provision of Services to you. This may include countries or territories outside the HKSAR, UK and European Economic Area.

We take appropriate technical and organisational measures to keep your personal data secure in accordance with our internal policies and procedures covering the storage, disclosure of and access to personal data. This personal data may be kept on our systems or in paper files. Our employees respect your privacy and are required to safeguard your personal data pursuant to the terms of their employment contracts with BANDS.

Who may we share your personal data with?

We may share your personal data with third parties for the sole purpose of providing our Services to you. When we share your personal data with vendors or otherwise, we use reasonable endeavours to ensure those third parties only use this personal data for the specific purposes for which it is provided to them, as consistent with this policy.

We may share your personal data in the following cases:

  • between BANDS group companies, including BANDS Unified Limited, BANDS Financial Limited, BANDS Risk Management Limited, BANDS Capital Management Limited and BANDS (Shanghai) Investment Management Ltd, on a confidential basis where required for the purposes of providing our Services to you and for administrative, billing and other business purposes;
  • with payment providers and banks;
  • with event partners and suppliers;
  • with recruitment agencies and related organisations;
  • with courts, law enforcement authorities, auditors, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, for the purposes of a confidential alternative dispute resolution process, or to seek advice and assistance in relation to the lawful and effective management of our business;
  • to instruct third-party service providers (such as firms providing applications, data processing or IT services) to process your personal data on behalf of BANDS and in accordance with our instructions. We retain control over and remain fully responsible for this personal data and use appropriate safeguards to ensure the integrity and security of your personal data when engaging such service providers;
  • with any third party to whom we assign or if we novate any of our rights or obligations, including in a possible sale of BANDS or any of its assets, shares or entities;
  • with other third parties, for instance, to comply with requests from any third party with the authority to obtain disclosure, investigate an alleged crime, or establish, exercise or defend legal rights.

In any other case, we will only disclose your personal data upon your request or with your permission, when required by applicable law or regulation or judicial or official request, or when required to investigate actual or suspected fraudulent or criminal activities.

What are your rights with regard to your personal data?

Subject to certain legal conditions, you may:

  • access the personal data we process of you by requesting a copy;
  • receive a limited set of data transferred directly to another controller or processor, or directly to yourself;
  • object to the processing of your personal data or have your personal data processing restricted;
  • withdraw your consent to the processing of your personal data for a purpose you previously consented to. This does not affect the lawfulness of processing that was done before consent was revoked;
  • have your personal data erased or rectified;
  • object to being subjected to profiling and automated decision-making and require a human review of any automated decision. BANDS does not process personal data in a manner which would make this right applicable.

To exercise any of your rights, please email us.


We may occasionally send you information about market news, new products or services of ours that we think may be relevant to you.

You have the right to opt out of our marketing communications at any time and stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, please email us.

Privacy and cookie policies of other websites

Our Website contains links to other websites. Our privacy policy applies only to our Website, so if you click on a link to another website, you should read their privacy and cookie policies first.

Changes to our privacy and cookie policies

We keep our privacy and cookie policies under regular review and place any updates on this web page.

How to contact us

If you have any questions or concerns about our privacy or cookie policies, the data we hold on you, or you would like to exercise one of your data protection rights, please email us at

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Office of the Privacy Commissioner for Personal Data or your local equivalent authority.

Updated in April 2024