Privacy Policy and Cookie Notice.

Data controller

For the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO"), the data user (controller) of personal data collected through this website and through our business activities is:

Benson Industries Limited
Office 3856C, Level 38, Infinitus Plaza,
199 Des Voeux Road Central, Sheung Wan, Hong Kong
Telephone: +852 3796 3119
Email: Loading…

Scope of this policy

This policy applies to personal data collected, used and stored by the Company in connection with:

• your access to and use of this website;
• communications with the Company by email, telephone or other means;
• onboarding, due diligence and ongoing relationship management with corporate counterparties, their principals, beneficial owners, directors, officers and authorised representatives;
• interactions with intermediaries, advisors, lenders, service providers and competent authorities;
• recruitment and applications for employment.

Personal data we collect

The categories of personal data the Company may collect include:

• Identification data, name, date of birth, nationality, identification document numbers, photograph, signature.
• Contact data, business and personal address, email address, telephone numbers.
• Professional data, employer, role, professional qualifications, business relationships and authorities.
• KYC and AML data, source of funds, source of wealth, beneficial ownership information, sanctions screening results, politically exposed person status, adverse media information.
• Transaction data, records of communications and decisions in connection with prospective or actual transactions.
• Technical data, IP address, browser type and version, operating system, device information, referring URL and pages viewed on this website (see Cookie Policy below).

The Company does not knowingly collect personal data from children. This website is not directed at retail consumers and is not designed for use by minors.

How we use personal data

The Company uses personal data for the following purposes:

• onboarding, identification and verification of corporate counterparties and connected persons;
• conducting customer / counterparty due diligence and ongoing review;
• sanctions screening, AML / CFT compliance and meeting other legal and regulatory obligations;
• credit analysis, structuring, documentation and execution of transactions;
• monitoring of transactions, covenants and counterparty risk;
• internal recordkeeping, audit and risk management;
• responding to enquiries, requests and legal process;
• protecting the legitimate interests of the Company, including detection and prevention of fraud, abuse and unauthorised use of this website;
• recruitment and assessment of applicants for employment;
• improving the security and functionality of this website.

Legal basis for processing

Under the PDPO, personal data must be collected for a lawful purpose directly related to a function or activity of the Company. The Company processes personal data on the following bases:

• Performance of a contract or pre-contractual steps with the data subject or with the entity the data subject represents.
• Compliance with legal and regulatory obligations (including AML / CFT obligations, sanctions, tax reporting and recordkeeping requirements).
• Legitimate business interests of the Company, including risk management, security and the protection of the Company’s assets and reputation, where these are not overridden by the data subject’s interests or fundamental rights.
• Consent, where required by applicable law and where given by the data subject.

Sharing & transfers

The Company does not sell personal data. We may share personal data with the following categories of recipients, in each case subject to appropriate confidentiality and data protection arrangements:

• professional advisors (legal, accounting, audit, tax) acting for the Company;
• banks and other financial counterparties, in connection with onboarding and ongoing relationship management;
• technology and service providers acting on our instructions (including IT hosting, document management, sanctions screening providers and similar);
• regulators, tax authorities, law enforcement and other competent authorities, where required by law or appropriate regulatory request;
• actual or potential successors in connection with a corporate reorganisation or transaction involving the Company.

Where personal data is transferred outside Hong Kong, the Company takes reasonable steps designed to ensure that the recipient is contractually obliged to provide a level of protection comparable to that required under the PDPO.

Retention periods

The Company retains personal data only for as long as necessary for the purposes for which it was collected, or as required by law. In particular:

• KYC and AML records are retained for the periods required by applicable Hong Kong legislation and FATF-aligned guidance, typically at least seven years following the end of the relevant relationship or transaction;
• contractual and transaction records are retained for the period required to evidence the transaction and to comply with applicable limitation periods;
• recruitment data is retained only for as long as required to assess applications and as permitted thereafter under applicable law.

When personal data is no longer required, it is securely deleted, destroyed or anonymised.

Information security

The Company implements technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These include access controls, network security, encryption in transit, secure document handling, staff confidentiality obligations and ongoing security training.

Despite these measures, no method of transmission over the internet or electronic storage is completely secure. The Company cannot guarantee absolute security and disclaims any liability for unauthorised access that occurs despite the implementation of reasonable safeguards.

Your rights

Under the PDPO, you have the right, subject to the conditions set out in the Ordinance:

• to be informed whether the Company holds personal data of which you are the data subject;
• to request access to a copy of such personal data;
• to request the correction of personal data that is inaccurate;
• to be informed of the policies and practices of the Company in relation to personal data;
• to opt out of any direct marketing use of your personal data (the Company does not currently use personal data for direct marketing purposes).

The Company may charge a reasonable fee for compliance with a data access request, as permitted under the PDPO. Requests will be processed within the timeframes prescribed by the Ordinance.

Contact us

Requests under this policy, and any questions or complaints relating to the Company’s handling of personal data, should be addressed to:

If you are not satisfied with the Company’s response, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

Cookie policy

This website uses a minimal set of cookies and similar technologies. Cookies are small text files stored on your device by your browser when you visit a website. They allow the website to remember your actions and preferences over time.

Cookies used on this website

This website does not use third-party advertising or tracking cookies. The technologies used are limited to:

• Strictly necessary cookies / local storage, required for core website functionality (for example, remembering navigation state and language preference). These do not require your consent under applicable law.
• Embedded map (Google Maps). The Contact section of the website embeds a Google Maps frame from www.google.com. Google may set cookies and process technical data when this frame is loaded. Please refer to Google’s Privacy Policy and Google Maps Terms of Service for details.

The Company does not use Google Analytics, Facebook Pixel, advertising trackers or behavioural targeting cookies on this website.

Managing cookies

You can control or delete cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be alerted when a cookie is set. Disabling cookies may affect the functionality of this website and of third-party services such as the embedded map.

Server logs

Like most websites, our hosting infrastructure may log technical information automatically transmitted by your browser, such as IP address, request timestamps, browser type and pages viewed. This information is used for security, integrity and operational purposes and is retained only for the period reasonably required for those purposes.

Changes to this policy

The Company may update this policy from time to time to reflect changes in our practices, legal or regulatory developments, or technological changes. The "Last updated" date at the top of this page indicates when the policy was last revised. We encourage you to review this policy periodically.