PRIVACY POLICY

Protecting the privacy and safeguarding the personal information of our existing customers, former customers and persons who visit our website is one of our highest priorities. The following statement explains how Sorrento ("Sorrento”) or any of Sorrento HK’s affiliates (collectively referred to as “Sorrento Group”, “us”, “we” or “our”) collects, maintains and protects your personal information.

By your use of any website operated by Sorrento or any of its affiliates or opening an Account with Sorrento, you give your consent to the collection and use of personal information by all members of the Sorrento Group on an ongoing basis as explained in this statement.

This statement also briefly describes our privacy policies and procedures.

COLLECTION AND RETENTION OF YOUR PERSONAL INFORMATION

We collect your personal information both directly from you and indirectly as a result of your relationship with us from time to time.

PURPOSES OF COLLECTION

We may use the information collected to verify your identity, open a trading account for leveraged foreign exchange contracts for you (including issuing you with an Account number and password), service your account including providing statements and trade confirmations, facilitate Account funding and withdrawals, including in connection with margin trading, conduct credit checks at account opening and regularly thereafter, collect outstanding amounts from you whether through the use of cheques or bank transfers, collect personal information from those who provide security or guarantee your performance in connection with your account, carry out statistical and other analysis, and for any other purposes directly related to any of the above purposes (“Business Purposes”). If you do not provide us with your personal information for these Business Purposes, we may not be able to open an account or to provide any services to you.

PERSONAL INFORMATION TO BE COLLECTED

Most of the personal information we collect is provided directly by you, for example by you filling in an application form. This information includes, but is not limited to, personal details, such as your name, address, date of birth, telephone number and e-mail address, information required pursuant to regulatory requirements verifying your identity such as a passport or other government issued photo identification, financial information such as your Account trading details, annual income, net worth, risk capital financial information, bank account details and credit card information.

Other information, such as your IP address, web browser type, operating system and your internet service provider, will be provided by you indirectly in the ordinary course of our business relationship with you, for example through online tracking, as described in the section below entitled “Cookies”.

COOKIES

We use cookies and other technologies (collectively, "cookies") on our website to store and track information about you and your actions for the purposes of providing us with data we can use to improve your experience and to know you better. Cookies are small text files sent from various web servers that may be stored on your computer. Cookies enable us to capture how you arrived at our website, how often you visit, when you return, which pages on our website you visit, and to recognize when you are logged on when we receive a request from your web browser. We may link the information we store in cookies in order to identify information you submit while on our website. Cookies are readable only by us and do not on a standalone basis contain any personal, financial or Account information. We cannot and will not gather information about other websites you have visited in the past.

We may share usage information about persons who visit our website with reputable advertising companies for the purpose of targeting our banner advertisements on the internet. The information collected by the advertising company through the use of these pixel tags does not identify you personally.

Additionally, we may use third party software to track and analyze usage and volume information including page requests, form requests and click paths. The third party may use cookies to track your web browsing behavior and may implement cookies on behalf of us. Your personal information will not be used by that third party or be further transferred by that third party to any other person.

All web browsers have settings that allow you to block cookies. By visiting our website with your web browser set to allow cookies, you consent to our use of cookies as described above. If you choose to block cookies you may use our services, however, some functions and features may be disabled or may not work as they were initially designed to.

SECURITY AND RETENTION OF YOUR PERSONAL INFORMATION

We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the local applicable legal requirements including the Personal Data (Privacy) Ordinance in Hong Kong with respect to managing your personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations.

We employ physical, electronic, and procedural safeguards in order to protect your personal, financial and Account information and to offer you a safe and secure trading environment. When you open an Account with us, you are issued a unique Account number and password, as well a unique user id and password for the Secure Access Website.

Our employees are required to maintain and protect the confidentiality of your personal information and must follow established procedures to do so.

We limit access to your personal, financial and Account information to those employees and employees of our affiliates who need to know in order to conduct business, including servicing your Account. These employees will have access to your Account number and user id. Although certain employees have the ability to reset your Account password and Secure Access Website password for you, they will not have access to your password, as they are not saved in our systems.

We have employed adequate security measures based on recognized international standards, to safeguard your personal information and protect from it from being disclosed, compromised or leaked.

Your personal, financial, and Account information, including your credit card details (where applicable), will be disposed of or purged from our records based on our data retention policy seven years after the Account has been closed, which is compliance with recognized international standards.

You are ultimately and solely responsible for maintaining the secrecy of your Account number and password and the Secure Access Website user id and password. In order to better safeguard this information, we highly recommend you the following precautions:

ACCESS RIGHTS

You have the right to request access to and correction of any of your personal data held by us. For data access requests, we may charge a reasonable fee. You can contact us if you would like to make such a request or have any queries as to how we handle such request, using the contact details set out under the section entitled “Contact us” below.

OPT-OUT

If you do not agree to allow us to use or transfer your personal information for Direct Marketing purposes, you can opt out by contacting us using the contact details below the section entitled “Contact us”.

CONTACT US

In connection with your access rights or Direct Marketing opt-out rights as well as any queries about our privacy policy and procedures, you may notify our Data Protection Officer in writing via email at info@sorrento.com.hk or at 11/F, The Wellington, 198 Wellington Street, Central, Hong Kong or contact your Account Manager. For joint accounts, an-opt out election made by one account owner will be applicable to all owners on the Account. Please allow approximately 30 days from our receipt of your request for your instructions to become effective.

CHANGES TO THIS PRIVACY STATEMENT

In the event any material changes are made to this statement, the revised statement will be posted on our website as soon as reasonably practical. By your continued use of the website and/or by opening an Account with us, you hereby agree to accept this as notice provided to you.

Any dispute over this statement is subject to the terms of this statement and our Terms. If you have any questions that this statement does not address, please contact our Data Protection Officer or a support representative.

* Should there be any inconsistencies between the English and the Chinese version of this Statement, the English version shall prevail.