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Hong Kong Exchanges and Clearing Limited and its affiliated companies as referred in the Annex (together "HKEX", "we", our” or "us") are committed to protecting all Personal Data under its custody, control or possession. Under the applicable data protection laws, HKEX is the “Data Controller”. “Personal Data” is any information that relates to an identifiable individual or can be used to identify an individual (“Data Subject” or “you”, if/where applicable).

This privacy notice (“Notice”) applies to our handling of Personal Data of Data Subjects for or in connection with human resources management-related purposes, including recruitment, onboarding, or employment-related processes, functions and activities (as the case may be), including any Data Subjects (a) who create an online account on our recruitment portal and/or apply for a role with HKEX; or (b) who have accepted an offer for a role from HKEX and are therefore subject to our onboarding process; or (c) who, after completion of the onboarding process, have successfully joined as an employee of HKEX (as the case may be). This Notice does not apply to individuals who complete our staff survey.

This Notice sets out the Personal Data that we collect, generate, and otherwise process, how we process it, to whom it might be transferred, how we protect it and Data Subjects’ rights under applicable data protection laws. For Data Subjects from certain jurisdictions specifically referred to in this Notice, there may be additional rights and provisions that apply depending on their location and status, which are further stated in the relevant Addendum to supplement the generally applicable provisions of this Notice. By engaging in the processes, functions and/or activities referred in this Notice (such as but not limited to creating an online account, submitting an application, accepting a job offer, or otherwise participating in HKEX’s recruitment, onboarding, employment and/or human resources management-related process (as the case may be)), you acknowledge that you have understood this Notice.

We will revise this Notice from time to time to reflect any relevant developments at HKEX relating to our business or operations that may impact our recruitment strategy/process, our onboarding process, processing of Personal Data by our human resources team and/or other relevant HKEX teams and third parties referred in this Notice, our performance of the relevant recruitment, onboarding, employment and/or human resources management-related processes, functions and activities, or due to changes in any applicable laws and regulations (as the case may be). To the extent required under the applicable data protection laws, we will notify Data Subjects of material changes and, where required, seek their consent.

If HKEX is not provided with correct or complete Personal Data, we may not be able to perform our relevant recruitment, onboarding or employment and/or human resources management-related processes, functions and activities that may be applicable to you (as the case may be) – for example, you may not receive updates on new roles and/or submit an application for a role, or we may not be able to process your application, or we may not be able to onboard you as an employee, or we may otherwise not be able to continue providing the necessary human resources operations to facilitate your continued employment at HKEX (as the case may be). We may also be unable to process requests relating to your rights as a Data Subject under the applicable data protection laws. HKEX is also required to perform certain regulatory functions that may not be possible if we are not provided with the requested Personal Data.

Sometimes we will aggregate information into aggregated data, but aggregated data will not necessarily constitute Personal Data. Any aggregated data that does constitute Personal Data will be processed in accordance with this Notice.

The Notice is available in English and Chinese versions. In the event of any conflicts or discrepancies between these different language versions, the English version shall prevail.

1. What Personal Data do we collect and how do we collect it?

2. Sensitive Personal Data

Some Personal Data that we process is classified as Sensitive Personal Data” under applicable data protection laws. What is considered Sensitive Personal Data varies by jurisdiction. If we are required to process Sensitive Personal Data, we will only do so in accordance with applicable laws, and with your consent to the extent required under applicable data protection laws.

Our processing of Sensitive Personal Data in certain jurisdictions for the purposes of the relevant recruitment, onboarding, employment and/or human resources management-related processes, functions and activities (as the case may be) require specific disclosure. Accordingly, for Data Subjects in Chinese Mainland, please see Addendum 1; for Data Subjects who are California residents, please see Addendum 2; for Data Subjects in the United Kingdom (“UK”) or European Union (“EU”), please see Addendum 3; and for Data Subjects in the Kingdom of Saudi Arabia (“KSA”), please see Addendum 4.

3. Legal Basis

The “Legal Basis” is what data protection laws set out as the lawful reasons for processing Personal Data, such as a legitimate interest to operate our business so long as it does not materially and adversely impact your interests, rights, and freedoms.

4. Do we disclose Personal Data to third parties or transfer it to another jurisdiction?

HKEX discloses Personal Data to third parties that provide services to assist in our recruitment, onboarding, employment and/or human resources management-related processes, functions and activities, and/or the operations and management of our business (as the case may be), including without limitation the following:

  • Affiliates of Hong Kong Exchanges and Clearing Limited;
  • Our HR-related vendors who provide services relating to recruitment, onboarding, employment and/or human resources management-related operations and activities;
  • Our general vendors who provide administrative, storage, insurance, technical infrastructure, event management, media, or other services in support of our general business operations;
  • Our compliance support vendors who provide services relating to personal account dealing;
  • Our technical contractors and vendors who provide products and/or services relating to telecommunications, IT infrastructure, and security for premises and systems;
  • Our business partners who support our business (if you are required to engage with them in your role with HKEX);
  • Our professional service providers such as legal advisors, tax consultants and auditors;
  • Any individual or entity acting on your behalf according to your authorisation;
  • Any regulator or other authority of HKEX or of our affiliates.

To fulfil our legal and regulatory obligations, we may also share your Personal Data with courts, regulatory authorities, government and law enforcement agencies, and other public authorities.

Further details about these third parties may be provided upon request to the address in the “Contact Us” section. We endeavour to provide such information to the extent we are required to do so under applicable data protection laws.

Where required under applicable data protection laws, HKEX will only disclose Personal Data to third parties with Data Subject’s prior consent. In certain jurisdictions, HKEX may also be required to take additional measures prior to giving effect to such transfers (e.g. carrying out privacy impact assessments prior to the transfer).

HKEX may process Personal Data outside of the Data Subject’s home jurisdiction, including sharing the Personal Data with third parties (such as but not limited to vendors). HKEX shall use reasonable endeavours to ensure that the laws and regulations of the destination jurisdiction shall offer the same or comparable level of protection for Personal Data. Where this is not the case, we shall ensure appropriate safeguards are in place at the time of the transfer by implementing standard contractual clauses or other data transfer mechanisms approved by the authorities of the relevant jurisdiction. Where required under applicable data protection laws, we shall also carry out additional measures for the offshore transfer such as carrying out a privacy impact assessment.

The regions where the Personal Data may be hosted or transferred to will vary from time to time, but typically include Hong Kong, the UK, US, EU, Switzerland, Singapore, Japan, India, and Chinese Mainland. Further details on the processing locations and our measures for safeguarding international transfers of Personal Data (including adequacy decisions) may be obtained upon request to the address in the “Contact Us” section.


5. How long do we keep the Personal Data?

Your Personal Data will be retained by us for as long as is necessary to fulfil the purposes required for the processing outlined in this Notice and, in any event, retained in accordance with applicable law. HKEX will refer to the following factors when determining or confirming the appropriate retention period of Personal Data:

  • original purpose of collection;
  • termination of any contract involving the Data Subject’s Personal Data;
  • limitation period as defined in the applicable law;
  • existence of any legal or regulatory investigations or legal proceedings;
  • specific laws or regulations setting out HKEX’s functions, obligations, and responsibilities;
  • retention period set out in non-statutory guidelines issued by our regulators or international bodies;
  • sensitivity of the Personal Data and the degree of risk from the associated processing activity.

We will retain Personal Data in accordance with our prevailing internal policies and/or standards, including our Group Personal Data Retention Standard. Further details of our Personal Data retention period may be obtained upon request to the address in the “Contact Us” section.

Where any Personal Data is no longer necessary for the purposes for which it is collected, we shall cease the processing of that Personal Data as soon as reasonably practicable (although all or part of that Personal Data may continue to be retained as necessary for archival purposes, for use in any actual or potential dispute, or for compliance with applicable laws, as the case may be), and take reasonable measures to delete or destroy the relevant Personal Data.


6. How do we keep your Personal Data secure?

We will take all practicable and reasonable steps to promote the security of Personal Data we process in a manner consistent with applicable data protection laws and established international security standards, including physical, technical and administrative safeguards to help prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, such as:

  • storage of Personal Data in a secure operating environment with restricted access;
  • relevant third parties being required to apply appropriate safeguards; and
  • rigorous verification of identity prior to access being granted to HKEX premises.

Where we occasionally provide links to any third-party websites, this Notice will not apply and we recommend that you check their respective privacy statements to understand how your Personal Data will be governed.


7. Rights over your Personal Data

As a summary, certain Data Subject rights may be exercised to the extent provided under applicable data protection laws that apply to you:

  • confirm whether we hold your Personal Data and the type of your Personal Data held by us;
  • access a copy of your Personal Data held by us;
  • delete your Personal Data held by us;
  • correct or supplement your Personal Data where it is found to be inaccurate or incomplete;
  • restrict the processing performed on your Personal Data in certain circumstances;
  • object to our use of your Personal Data for direct marketing purposes or processing carried out on a legitimate interests basis;
  • withdraw consent to the processing of your Personal Data in relation to consent-based processing;
  • transfer your Personal Data processed by us by automated means back to you or to another party in machine-readable format.

In certain jurisdictions, Data Subjects may also be provided with additional rights. For Data Subjects in Chinese Mainland, please see Addendum 1; for Data Subjects who are California residents, please see Addendum 2; for Data Subjects in the UK or EU, please see Addendum 3; for Data Subjects in the KSA, please see Addendum 4; and for Data Subjects in Singapore, please see Addendum 5.

Where these rights apply, we shall use reasonable endeavours to fulfil the request or provide an explanation. If you withdraw your consent to the processing of your Personal Data, this will not affect any processing which has already taken place on the basis of that consent. Please note that under the applicable data protection laws, we may be limited in what Personal Data we can disclose which is also for the protection of your Personal Data.

We will endeavour to respond to you as soon as possible and, in any event, within the timeframe stipulated under the applicable data protection laws. In the event of a potential delay, we will provide an explanation and expected timeframe for delivery. Under applicable data protection laws, we may also be required to charge a reasonable fee for the cost of processing the request.

Please note that we may need to seek confirmation of identity or clarification in order to fulfil the request. If you as the Data Subject would like to appoint an authorised agent to make a request on your behalf, we may require you to verify your identity with us directly before we provide any requested information to your authorised agent unless your authorised agent has power of attorney or acts as a conservator. Information collected for purposes of verifying your request will only be used for verification. For deletion requests under applicable data protection laws that apply to you, you will be required to submit a verifiable request for deletion and then confirm separately that you want Personal Data about you to be deleted.

If you would like to exercise your Data Subject rights, please contact the HKEX Group Data Protection Office under the “Contact Us” section.

8. Contact Us

If you have any questions or comments relating to the content of this Notice, report any concerns about our Personal Data processing, or if you would like to exercise your Data Subject Rights, please contact us through any of the channels below:

By post:  Group Data Protection Officer
HKEX Group Data Protection Office 
Hong Kong Exchanges and Clearing Limited
8/F., Two Exchange Square
8 Connaught Place
Central
Hong Kong
By email: dataprivacy@hkex.com.hk

 

Specifically, for Data Subjects in the UK or EU, please refer to the applicable contact channels as set out in Addendum 3.

Please include the following details in any request to exercise your Data Subject Rights (*required field):

Identity of Data Subject:
  • Full name*
  • Company name (if applicable)
  • Email address*
  • Address of principal residence
  • Identity particulars (if acting on behalf of a Data Subject)
  • Contact details held on file* 
Nature of the Request:
  • Specific Right*
  • Purpose of the Request
  • Preferred communication channel and address for receiving the results of the request*
  • Document(s) to support the rights request

Any Data Subject who has contacted us to express concerns about the way we manage their Personal Data and is of the view that we have not addressed the matter satisfactorily, may also contact the relevant privacy regulator to resolve the matter or seek assistance. If/where applicable, please see the relevant Addendum for further details.

Last Update: 19 December 2025

Annex: Affiliated Companies

This Notice relates to privacy practice of our group entities, including but not limited to those listed below. Further details of the full list of our group entities and their contact details may be obtained upon request to the address in the “Contact Us” section.

  • The Stock Exchange of Hong Kong Limited
  • Hong Kong Futures Exchange Limited
  • HKEX (Shenzhen) Holding Company Limited
  • HKEX Technology (Shenzhen) Limited
  • Ganghui Business Consultancy (Shanghai) Limited
  • Qianhai Mercantile Exchange Co., Ltd
  • The London Metal Exchange
  • LME Clear Limited
  • Hong Kong Futures Exchange Limited London Branch
  • The Stock Exchange of Hong Kong Limited London Branch
  • Hong Kong Futures Exchange Limited Singapore Branch
  • The Stock Exchange of Hong Kong Limited Singapore Branch
  • HKEX (U.S.) LLC
  • HKEX Arabia Limited
Addendum