BlackRock recognizes the importance of protecting your personal and financial information when access our mobile applications. The following information is designed to help you understand the information collection practices of this application (the “Application”).
By using this Application, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use this Application. Please review the Terms and Conditions to learn of other terms and conditions applicable to your use of this Application.
Changes to this Privacy Policy
BlackRock reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. We suggest that you review this Privacy Policy periodically for changes. The current version of this Privacy Policy can be accessed in the user settings of the Application. We will provide users with a notification whenever an amendment is made to this Privacy Policy so that you will know when to check. You acknowledge that by accessing our Application after we have posted changes to this Privacy Policy, you are agreeing to the terms of the Privacy Policy as modified.
With respect to any expansion of the purposes of using your personally identifiable information received by us from the purposes as stated in this Privacy Policy, prior notice will be given to you and you have the right to decline acceptance of such expansion however in such circumstances our provision of continuing services to you may be limited.
Information Collection and Use
Methods of Information Collection
We may receive personally identifiable information you submit to or we collect through our Application. Failure to provide such personally identifiable information may result in BlackRock being unable to provide you with the services or information requested.
Separately we may use “Adobe Analytics”, “Localytics” or other similar technology (collectively “Analytics Tools”) to collect and store anonymized information about user behavior and engagement (including but not limited to data such as number of users, time spent in the Application, contents which users have clicked on, city, time of day used, type of device used, whether a user has enabled or disenabled push notifications etc.) (“Anonymized Information”) when you visit our Application. Analytics Tools help us to provide customized services and information.
If you would prefer us not to collect and store Anonymized information when you visit our Application, please do not use this Application.
Information Collected and Purpose of Information Collection
The types of personally identifiable information that may be collected by this Application include information you provided to us through the "Contact Us" page (e.g. your name and email address).
Separately Analytics Tools may track and record information of your activities on our Application (including user's preference and behaviour, navigation on the Application etc.). When you are navigating our Application, we may also record your IP address.
Use of Personally Identifiable Information
The personally identifiable information you submit to or through our Application is used only for responding to your inquiry sent to us, for business administration, business reporting and statistical analysis purposes, for the provision of information on BlackRock products and services to you, for servicing your account, that set out at the section “Information Collected and Purpose of Information Collection” and for other directly related purposes. Your personally identifiable information may also be used for purposes set out in the sections below headed "Aggregate Information", "Affiliates and Service Providers", "Compliance with Laws", "E-mail and Marketing" and "Business Transfers" (Collectively the "Purposes").
We will not sell, share, rent or otherwise disclose or transfer your personally identifiable information to others for monetary gains.
With respect to your information collected through Analytics Tools, we will use such information to assess how and when different pages in our Application are visited, what our users' technology preferences are (such as what type of video player or operating system they are using), whether our Application is functioning properly and for systems, trouble shooting, administrative and reporting purposes.
Additionally, you may encounter Analytics Tools or other similar devices on our Application that are placed by third party companies. In such circumstances the purpose and means of collection and retention policy of your information is the same as stated in this Privacy Policy and such information will not be transferred to any third parties except as provided under this Privacy Policy. These third party companies are our data processors which only process information on our behalf and do not process the information for any of their own purposes.
Aggregate Information: We generally record certain usage information, such as the number and frequency of visitors to our Application. If we use such data at all it will be on an aggregate basis, and we will not disclose to third parties any information that could be used to identify you personally.
We may also disclose details about the general use of our Application to third parties. Information we pass on will not include any personal information by which you may be identified.
Retention Period: We will take practicable steps to ensure your personally identifiable information will not be retained by us longer than is necessary for the fulfilment of the Purposes.
Affiliates and Service Providers: We may provide your personally identifiable information to our affiliates and other third party service providers (including information technology service providers) for the Purposes. The third party service provider only processes your personally identifiable information on our behalf and will not use your personally identifiable information for any of its own purposes or for any direct marketing purpose. By disclosing your personally identifiable information to us via our Application, you understand that we may transfer your personally identifiable information to our affiliates or such other third service providers outside of Hong Kong to the extent legally permissible. These persons may have access to the personally identifiable information you submit through our Application, but only for the purpose of performing their duties specified in this paragraph. These persons may not use your personally identifiable information for any purpose other than those stated in this Privacy Policy.
Compliance with Laws: Except as otherwise provided in this Privacy Policy, BlackRock does not automatically collect personally identifiable information from application users, except to the extent we are required to do so pursuant to any law or regulation binding on us. We will (and you authorize us to) disclose your personally identifiable information if we are required to make such a disclosure under applicable law or regulation, or where requested to do so by the police or by regulatory bodies, or where we wish to do so in relation to any suspected misuse by you of our Application.
E-mail and Marketing: We may use your personally identifiable information in direct marketing our investment/financial products and/or services but we cannot so use your personally identifiable information without your consent. Before we do so, we shall take all necessary steps to obtain your consent for us to so use your personally identifiable information provided to or obtained by us through the Application as referred to above (the types of data to be specified when we take steps to obtain your consent) for purposes of direct marketing in relation to our investment/financial products or services. After you have given us your consent, if you would like us to stop sending direct marketing to you, you may do so, free of charge, by selecting the unsubscribe facility in any email or by writing to us clientservices.hk@blackrock.com. BlackRock will not send you e-mail messages without first receiving your consent, unless it relates to responding to your inquiry or unless you have consented to receiving electronic delivery of documents as part of our e-delivery service. It is our policy to include instructions for unsubscribing from these consent-based programs. We recommend that you do not send us any individual personal information via non-secure methods of correspondence, including via public electronic communication channels, such as Internet e-mail, which are generally not secure.
BlackRock does not sell its customers' e-mail addresses, nor will we provide your personally identifiable information to third parties or our affiliates for their marketing purposes or any of their other purposes without your consent. It is only voluntary for you to provide your personally identifiable information for marketing purposes. As a matter of policy, BlackRock generally does not transfer any of your personally identifiable information to any third parties or its affiliates for marketing purposes and even if it does, it will only do so with your prior written consent.
Business Transfers: If the business, stock or assets of BlackRock are acquired or merged with another business entity, we will share all or some of your information (including your personally identifiable information) with this other entity to continue to provide services to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in these Privacy Statements. If the new entity wishes to make additional use of your information, it will inform you beforehand and you may decline such use at that time.
For personal identifiable information collected in Hong Kong – your rights under PDPO: Under and in accordance with the terms of the Personal Data (Privacy) Ordinance ("PDPO") of Hong Kong and codes and guidelines issued pursuant thereto, any individual:
(i) may check whether BlackRock holds personally identifiable information about him/her and may request access to such information;
(ii) may request BlackRock to correct any personally identifiable information relating to him/her which is inaccurate;
(iii) may request BlackRock to specify its policies and practices in relation to personally identifiable information and to be informed of the kind of personally identifiable information held by BlackRock; and
(iv) may withdraw his/her consent for Blackrock to use his/her personally identifiable information for marketing purposes; BlackRock will not use his/her personally identifiable information for these purposes if he/she communicates his/her withdrawal of consent to BlackRock.
In accordance with the terms of PDPO, BlackRock has the right to charge a reasonable fee for the processing of any request to supply you with a copy of your personal identifiable information (ie. data access request) mentioned above.
You may submit any of your requests above to our Data Protection Officer at 16/F Champion Tower, 3 Garden Road, Central, Hong Kong (email: clientservices.hk@blackrock.com).
Nothing in this Privacy Policy shall limit your rights of under the PDPO.
Security
BlackRock protects your personally identifiable information when you visit our Application by requiring the use of a software program that supports industry standard SSL encryption with 128-bit key lengths. The "128-bit" designation refers to the length of the key used to encrypt the data being transmitted, with a longer key representing a higher level of security.
BlackRock endeavours to prevent unauthorised disclosures of your personal information by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority.
Contact Us
For more information on BlackRock, please do not hesitate to contact us:
Data Protection Officer
BlackRock Asset Management North Asia Limited
16/F Champion Tower
Three Garden Road
Central
Hong Kong
Phone: + 852 3903 2688
Email: clientservices.hk@blackrock.com
Dated: March 2019
©2019 BlackRock, Inc. All rights reserved. iShares® and BlackRock® are registered trademarks of BlackRock, Inc., or its subsidiaries in the United States and elsewhere. All other trademarks, servicemarks or registered trademarks are the property of their respective owners.
