Our Privacy Principles

Cirro Capital Limited (“Cirro Capital”, "we", "us" or "our") builds its business on trust between our customers and ourselves. To preserve the confidentiality of all personal data you provide to us, we maintain the following privacy principles:

  • We only collect personal data that we believe to be relevant and required to understand your financial needs and to conduct our business.
  • We use your personal data to provide you with better customer services and products.
  • We will not disclose your personal data to any external organisation unless we (i) have your consent or (ii) are required by law or (iii) have previously informed you.
  • We may be required from time to time to disclose your personal data to governmental or judicial bodies or agencies or our regulators, but we will only do so under proper authority.
  • We aim to keep your personal data on our records accurate and up-to-date.
  • We maintain strict security systems designed to prevent unauthorised access to your personal data by anyone, including our staff.

By maintaining our commitment to these principles, we will ensure that we respect the inherent trust that you place in us.


Your Privacy Matters to Us

This section provides specific details of how we treat any personal data you provide us when you visit Cirro Capital’s website (the “Website”).

Purpose and Use

The purposes for which personal data may be used will vary depending on the nature of your relationship with us. We  intend to use your personal data (including any third party data provided by you) for any or all of the following purposes:

  1. the processing of an application for an account with us including confirming and verifying your identity;
  2. the daily operation of your account and the services to be provided to you;
  3. any purpose related to the administration of the products and services offered by us;
  4. researching, designing and launching financial, investment services or related products for clients;
  5. meeting the disclosure, reporting and compliance requirements (including but not limited to tax reporting) under any laws or regulations, codes, guidelines or internal compliance policies applicable to Cirro Capital;
  6. enabling:
    1. any actual or proposed assignee(s) of Cirro Capital;
    2. any actual or proposed participant(s), sub-participant(s) or transferee(s) of Cirro Capital’s rights or obligations with respect to you; and/or
    3. any person(s) in whose favour Cirro Capital’s obligations with respect to you are, or are to be, novated, to evaluate, execute and/or complete the transaction(s) intended to be the  subject of any assignment, participation, sub-participation, transfer, novation or other similar arrangement; and
  7. any other purpose directly related to any of the above.

Data Security

  • Security is our top priority. We will strive at all times to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
  • Our web servers are protected behind "firewalls" and our systems are monitored to prevent any unauthorised access.
  • We will not send personal data to you by ordinary email. As the security of ordinary email cannot be guaranteed, you should only send email to us using the secure email facility on this Website.
  • We will take all practical steps to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in the Hong Kong Special Administrative Region concerning the retention of personal data.

Security Assurance

  • Both you and us play an important role in safeguarding against online fraud.
  • We endeavour to put in place high standards of security to protect your interests.
  • You should be careful that your account details (including your username and passwords) are not compromised. You should ensure that you do not knowingly or accidentally share, provide or facilitate unauthorised use of such details. Do not share your username or passwords or allow access or use of your username or passwords by others.
  • You should safeguard your username and passwords and keep them secret and confidential. Never write them down. We will never ask you for your passwords given that you should be the only person who knows it.
  • When choosing your username and passwords, do not use easily identifiable information such as your birthday, telephone number or a recognisable part of your name.
  • If you think your username or passwords has been disclosed to another person, is lost or stolen or an unauthorised transaction has been conducted, you are responsible for informing us immediately.
  • If, in the unlikely event, an unauthorised transaction has been conducted through your account through no fraud, fault or negligence on your part, we will see that you are covered for your direct loss up to the full amount of the unauthorised transaction.

Use of Cookies, Spotlight Tags and Web Beacons etc

We may record your visit to this Website for analysing the number of visitors to this Website, general usage patterns and your personal usage patterns and improving your experience. We may gather some of this information through the use of "cookies". Cookies are small bits of information that are automatically stored on your web browser in your computer that can be retrieved by this Website. Cookies are useful because they allow us to recognise your device and they store information about your use of this Website, thus enabling us to provide more useful features to you, to tailor the content of our Website to suit your interests and, where permitted by your marketing preferences, provide you with promotional materials or direct marketing based on your usage patterns. We will be able to access the information stored on the cookies and record how you use this Website. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies or to inform you when they are set. By disabling cookies, you may not be able to take full advantage of this Website. If you accept cookies, you will be acknowledging that your information is being collected, stored, accessed and used as outlined above.

Marketing Promotions

  • Occasionally we may collect personal data from you when you visit this Website or when you participate in a promotion (whether online or over the telephone). We only collect personal data from you if you voluntarily provide it to us. We may use your personal data to inform you of products, services and other marketing materials which we think may be of interest to you. We may also invite you to participate in market research and surveys and other similar activities.
  • You can choose to receive marketing and other promotional materials by email and you may opt out from receiving these materials at any time.
  • If we do ask you to provide your personal data, we will always specify the purposes for which such personal data is collected and ensure that it is only used for the purposes specified at the time of collection.

Your Consent

By using our Website, you consent to our Website’s Privacy Policy. If you do not agree with this Privacy Policy, you must not access or otherwise use this site or any of its contents. In case of discrepancies between the English and other language versions of this Privacy Policy, the English version shall prevail.