Spread International Ltd' Customer Privacy Policy has been developed as an extension of our commitment to combine the finest quality products and services with the highest level of integrity in dealing with our customers. The Policy guides how we collect, store and use information about customers and prospects, and it will be periodically assessed against new technologies, business practices and our customers' changing needs.

Spread International Ltd may, from time to time, modify this Customer Privacy Policy to reflect legal, technological and other developments. In that event, the changes will appear at this location.

Please note that privacy notices advising customers and prospects as to the specific uses that are being made of their Personally-Identifiable Information by specific business units within Spread International Ltd may also be modified from time to time to reflect changes in business practices. In this event, those changes will appear in the relevant privacy notices.

Spread International Ltd will also comply with applicable non-HK laws that impose additional responsibilities on Spread International Ltd beyond those stated in this Policy in connection with the treatment of Personally-Identifiable Information about its customers and prospects.

Our Policy recognizes two kinds of personal data that deserve varying levels of protection. Personally-Identifiable Information includes, for example, e-mail addresses, billing information, employment status and "click stream" data that tracks user activity on a Web site or online service. A subset of that category, Sensitive Data, deserves additional safeguards. Sensitive Data includes, by way of example, Personal financial data (such as specific salary, net worth or individual portfolio information) and information about specific medical conditions.

Spread International Ltd is committed to using all reasonable efforts to abide by the following Policy statement:

1. Collection: Personally-Identifiable Information will only be collected to the extent that Spread International Ltd deems reasonably necessary to serve a legitimate business purpose. Please be aware that if you disclose Personally-Identifiable Information on Web site message boards or chat areas, that information may be collected and used by third parties without our knowledge and may result in unsolicited communications from third parties. Such activities are beyond the control of Spread International Ltd.
2. Notification: Customers and prospects will be notified (usually at the point where Personally-Identifiable Information is collected) as to the uses the business unit may make of the Personally-Identifiable Information collected from them.
3. Choice: Opt Out for External Distribution of Personally-Identifiable Information. Customers and prospects will be given the opportunity to refuse permission for External Distribution of their name, address or other Personally-Identifiable Information through an Opt Out mechanism. (External Distribution does not include certain limited distributions such as sharing Personally-Identifiable Information with an entity working on behalf of Spread International Ltd to serve our customers; transfer of Personally-Identifiable Information in conjunction with the sale or similar transfer of a business unit; or the disclosure of Personally-Identifiable Information in connection with legal proceedings, investigations of crimes or other wrongdoing. However, sharing Personally-Identifiable Information with an entity working on behalf of Spread International Ltd or transferring Personally-Identifiable Information in conjunction with the sale or similar transfer of a business unit is considered an Onward Transfer and will be handled as described below.)
4. Security: Appropriate safeguards will be implemented in an effort to ensure the security, integrity and privacy of Personally-Identifiable Information about our customers and prospects.
5. Access: Review and correction. Procedures have been developed through which customers and prospects can, upon request, review and correct the Personally-Identifiable Information that has been collected from them by Spread International Ltd. These procedures may not, however, compromise the security, integrity and privacy of either Spread International Ltd' own proprietary databases or databases licensed from third party companies.
6. Sensitive Data: The collection and use of Sensitive Data carries with it special obligations and responsibilities in order to maintain the data's security, integrity and privacy. Sensitive Data will not be rented or otherwise made available for External Distribution outside Spread International Ltd (although it may be made available through Onward Transfer as described below). Customers and prospects will be given the opportunity to refuse permission for their Sensitive Data to be distributed outside of the business unit that collected the Sensitive Data through use of an Opt Out mechanism for Internal Distribution within Spread International Ltd.