NEXTRATE cares about your privacy and your family’s. This policy is written under Hong Kong’s Personal Data (Privacy) Ordinance. It explains what personal data we collect through our website, our wealth-planning consultation questionnaire (“the questionnaire”) and our official LINE and WhatsApp accounts, what we use it for, who we share it with, how long we keep it, and how you can access and correct it. It is also our Personal Information Collection Statement.
01 Who we are and how to reach us
This website and the questionnaire are operated by Nextrate Co., Limited (“we”), which uses the brand NEXTRATE. Under the Personal Data (Privacy) Ordinance, we are the data user of your personal data: we decide how it is collected, used and protected.
Our Data Protection Officer handles enquiries about personal data, data access requests and data correction requests. You can reach the Data Protection Officer:
- on our official LINE account: tap the LINE icon at the bottom of any page on this website to add us, then send a message;
- on WhatsApp: +852 5249 3381.
Please start your message with “Personal data enquiry” so that we can pass it to the Data Protection Officer.
02 What we collect
We only collect what we need to understand your needs and provide our services. Apart from LINE Login data and website and messaging records, everything below comes from your answers in the questionnaire:
| Category | What it includes |
|---|---|
| LINE Login data | Your LINE user ID, display name and profile picture, and whether you have added our official LINE account as a friend |
| Basic and contact details | Name or how you would like to be addressed, mobile number, email address (optional), age, place of residence (country or city) |
| Work | Work status (e.g. employed, self-employed, business owner) and industry |
| Family | Marital status, number and ages of children, family members you care for, and whether you or your family hold another nationality or permanent residence (e.g. US citizenship or a green card) |
| Finances | Ranges of annual income and net worth, main types of assets and where they are held, property overview |
| Existing arrangements | Overview of existing insurance policies and planning tools (e.g. wills, trusts, overseas accounts, offshore companies), and the kinds of professionals you work with |
| Your thoughts | Topics you would like to discuss, your goals and timing, the people you most want to provide for, questions you have, how you heard about us, and the name of a referrer or adviser (optional) |
| Website and messaging records | Progress through the questionnaire (including answers not yet submitted), time of completion, IP address, device and browser information; your phone number and display name when you contact us on WhatsApp; your conversations and booking records with our official LINE or WhatsApp accounts |
We do not ask for ID card numbers, bank account numbers, or health or medical records, and we do not need your family members’ names or ID numbers.
Once you appoint us, some services (such as setting up a company or opening an account) need identity documents and other information. We will tell you at that time what is needed, why, and who will receive it.
03 How we use your data
We use your data for the following purposes and for purposes directly related to them:
- preparing an analysis report from your answers and sending it to your LINE (see section 5);
- understanding your needs, answering your enquiries, handling your consultation booking, and contacting you through our official LINE or WhatsApp accounts, including reminders to finish an incomplete questionnaire;
- providing and managing our services when you appoint us, including working with professional partners with your agreement (see section 6);
- with your consent, sending you news of talks, courses and planning information (see section 11, “Direct marketing”);
- LINE Login and account linking, and keeping the website running and secure;
- statistics that do not identify you, to improve the questionnaire, the website and our services;
- complying with applicable laws and regulatory requirements.
Before using your data for any new purpose, we will ask for your consent.
04 What you must provide
Providing data is your choice. However:
- The online questionnaire requires LINE Login and adding our official LINE account as a friend, because your report and later notices are sent to you there. Without logging in, you cannot use the online questionnaire.
- Questions marked as required must be answered before you can submit. Optional questions may be left blank, but your report will then be more limited.
- If you prefer not to use LINE, you can contact us on WhatsApp instead.
05 About the analysis report
The system prepares an analysis report from your answers, sends it to your LINE and shares it with the adviser handling your enquiry, as a reference for any follow-up discussion with you.
The report is a preliminary overview based on the information you provided. It is not investment, tax or legal advice. Specific recommendations are those your adviser gives after confirming the full details with you.
06 Who we share data with
We share your data only with the following classes of recipients:
- Our advisers and staff: only those who need it to handle your enquiry or service.
- Service providers that store, process or transmit data for us: Google (questionnaire back end), LINE, WhatsApp (Meta) and Cloudflare (website hosting and visitor statistics).
- Professional partners: accountants, lawyers, trust companies, banks and registered agents for offshore companies. Only when you appoint us and their help is needed will we tell you who they are and why, and share your data with your agreement. We never pass your data to a partner at the questionnaire stage or when you first contact us on LINE or WhatsApp.
- Government or law enforcement authorities: where the law requires.
We do not sell your personal data, and we do not provide it to anyone else for their direct marketing.
07 Transfers outside Hong Kong
The service providers above may store or process data outside Hong Kong, where data protection laws may differ from Hong Kong’s. We use contractual or other means to require providers that process data for us to protect it and not to keep it longer than necessary.
If you appoint us for cross-border work (such as setting up a company or opening an account elsewhere) and your data needs to go to an institution outside Hong Kong, we will first tell you where it will go and to which institution, and send it only with your agreement.
08 How long we keep data
- If you have not appointed us: 3 years from your last interaction with us (completing the questionnaire, or messaging us on LINE or WhatsApp).
- If you are a client: for as long as we serve you and 5 years after the service ends, or longer where the law requires.
- When the period ends, we delete your data or anonymise it so that it can no longer identify you.
09 Keeping data secure
- The website uses encrypted connections (HTTPS) throughout.
- Only the advisers and staff who need your data to handle your enquiry or service can see it.
- We use contractual or other means to require service providers to protect data against unauthorised or accidental access, processing, erasure, loss or use.
- We will never ask you for a password or verification code. If anyone asks for one in the name of NEXTRATE, please do not give it, and tell us on LINE or WhatsApp.
If a data breach occurs, we will act promptly to contain it and find the cause, and where appropriate notify the people affected and the Office of the Privacy Commissioner for Personal Data.
10 Cookies and similar technologies
- Visitor statistics: we use Cloudflare Web Analytics to understand how the website is used overall, such as how often each page is viewed. It does not use cookies or your browser’s local storage, and it does not identify individual visitors from their IP address or browser information. We do not use Google Analytics, or cookies for advertising or cross-site tracking.
- Language: the website remembers the language you choose in your browser. If you have not chosen one, the first time you open the home page it uses the country or region detected by Cloudflare to take you to a suitable language version; the result is used only in your browser.
- Questionnaire: your progress is saved in your browser so that you can continue later. You can clear it at any time in your browser settings.
- Calculators: they run entirely on your device, and the figures you enter are not sent to us. So that you do not have to re-enter them when you come back to a page, they are kept in that browser tab and cleared when the tab is closed.
- Third-party services: the fonts on this website come from Google Fonts, so your browser connects to Google’s servers to fetch them. When you use LINE Login or open WhatsApp, those services may use cookies under their own policies.
11 Direct marketing
With your consent, we may use your name or how you would like to be addressed, LINE account, WhatsApp or mobile number, email address and the topics you are interested in to send you the following, through our official LINE or WhatsApp accounts or by email:
- news of talks, courses and events;
- information about our advisory services, including cross-border wealth planning, offshore company set-up, support with opening overseas bank accounts, family trusts and legacy planning, and residency planning;
- practical information on legacy, tax and retirement planning.
We will not use your data in this way without your consent. You can give your consent by replying on our official LINE or WhatsApp accounts, free of charge.
You can change your mind at any time: reply “STOP” on LINE or WhatsApp, tell your adviser, or block our official LINE account, and we will stop using your data for direct marketing, free of charge. The first time we send you a marketing message, we will also tell you how to opt out.
12 Accessing and correcting your data
Under the Personal Data (Privacy) Ordinance, you may:
- make a data access request: ask whether we hold your personal data and obtain a copy of it;
- make a data correction request: ask us to correct data that is inaccurate;
- ask about our policies and practices on personal data and the kinds of personal data we hold.
How to make a request
Contact our Data Protection Officer on LINE or WhatsApp (see section 1) with proof of identity, so that we can confirm the request comes from you or someone you have authorised. For a data access request, please use the form specified by the Privacy Commissioner for Personal Data (form OPS003, available on the Commissioner’s website).
How we respond
- We will respond within 40 days of receiving your request. If we cannot comply, we will tell you why in writing within the same period.
- We may charge a fee for supplying a copy of your data. The fee will not be excessive and reflects only the direct cost of handling your request. There is no charge for correcting your data.
13 Family members and minors
The questionnaire asks about your family, such as the number and ages of your children and the family members you care for. We only need the overview required for planning, not your family members’ names or ID numbers. When you mention family members in a free-text answer, a description such as “my wife” or “my eldest son” is enough. Before you share information about your family, please let them know and point them to this policy.
This website and the questionnaire are intended only for adults aged 18 or over. Information about your children is provided by you as their parent; we do not collect personal data directly from anyone under 18.
14 Links to other websites
This website links to other websites and services, such as LINE, WhatsApp or our partners’ websites. They are run by others and their own privacy policies apply, so please read them before you provide any information.
15 Changes to this policy
We may update this policy to reflect changes in the law, our services or the way we work. The updated version will be published on this website with a new version number and date at the top of this page. We will tell you about significant changes through our official LINE or WhatsApp accounts, and we will ask for your consent before using your data for a new purpose.
16 Questions and complaints
If you have any question or concern about how we handle your personal data, please tell our Data Protection Officer first (see section 1) so that we can look into it. You also have the right to complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk).