Terms & Conditions

The following terms and conditions (“the Terms and Conditions”) apply to all information accessed from the www.asianprivatebanker.com web site (“the Site”). They should be read with great care. By registering with, using or accessing the asianprivatebanker.com web site you are agreeing to the terms that will appear below, whether you register as a user or whether you do not register as a user. By reading the below information, you confirm that all of the information that you may receive from the Site is for information purposes only and should be verified on your own responsibility before relying on the veracity of such information.

On 2 December 2023 these terms and conditions were last updated.


This Site is owned, updated and operated by Key Positioning Limited (“Key Positioning”). Key Positioning is a company registered in Hong Kong.

Users will be able to access some of the information and data on the Site without going through the registration process. However, certain areas of the site are only accessible if users register. Where additional material, that is not freely offered, is considered Subscriber Only content, users will be asked to pay. Key Positioning reserves the right to suspend or terminate entirely a user’s access to the Site at any time and may exercise this right with or without notice.


The Site and all information, material and reports pertaining to the Site are the property of and the copyright belongs to Key Positioning and/or its third party partners. Copying, reproducing, republishing, redistributing in any way, shape or form, or modifying the information without the prior written permission of Key Positioning is prohibited. The information contained on the Site should be used for personal non-commercial use only. All trademarks and logos appearing on the Site are Key Positioning’s or belong to those of its third party partners’.

They cannot be used without the written permission of Key Positioning.


The information available on the Site may contain information provided by third parties or from other sources or references. Key Positioning will try hard to ensure that such information is up to date and accurate at the time it is published on the Site, and although Key Positioning takes steps to make sure that such information and is as accurate as possible, care should be taken regarding the reliability and accuracy of the information.


Users may subscribe to the Asian Private Banker Newsletter. The use of the content in these newsletters is subject to these Terms and Conditions.


Third party partners of Key Positioning may offer reports, consultancy services, transactional services or other information and products (“Products”) for sale on the Site. When users purchase such Products on the Site their contract is with the third party. The user’s contract, in such cases, is NOT with Key Positioning.


When registering with the Site, users must provide accurate and complete registration information, in particular their email address. Notifying the company of changes to this personal information is the responsibility of the user. Each registration is for a single user only. Users may not share their name or password with another person or allow multiple users to log on to the Site using their identification. Users are responsible for all use of the Site made by themselves or anyone else using their identification. Use of the personal information gathered from users is covered in the Site’s Policy of Privacy.


Your use of any Software on the Site will be governed by the terms of the licence agreement that is included with that software.


The content of the information and reports contained on the Site are for general information purposes only and the information should be independently verified before relying on the same. The information does not constitute any form of advice by Key Positioning for users to act or refrain from making any specific decision. In particular, Key Positioning and its directors accept no responsibility for any loss resulting from any matter contained on the Site.


Key Positioning does not give any warranties including but not limited to any warranties in relation to the accuracy or completeness of any of the content, information or reports available in respect of the Site or in respect of any material and reports made available by any third party partners through the Site. The Site and the content, information and reports available on the Site are provided on an as is basis and Key Positioning hereby disclaims all warranties and duties of whatsoever nature express or implied including without limitation any implied warranties of merchantability or fitness for a particular purpose. In addition Key Positioning makes no warranty that the Site is free from any viruses.


Users of this Site agree that Key Positioning will not be liable to them or any third party for any damages that they may incur in relation to the use of the Site or any services available thereon.


Key Positioning reserves the right at its sole discretion to make changes to the Site and the Terms and Conditions. Any use of the Site after the Terms and Conditions have been amended will be in accordance with the new Terms and Conditions and use of the Site after the Terms and Conditions have been amended will confirm a user’s acceptance of the new Terms and Conditions.


These Terms and Conditions shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region.


If any provisions of these Terms and Conditions are found to be invalid by any court having jurisdiction then the invalidity of that provision will not affect the validity of the remaining provisions of these Terms and Conditions which shall remain in full force and effect.


You may be given the option to access or register for the Service through the use of your user name and passwords for certain services provided by third parties (each, an “Integrated Service”), such as through the use of your Google account, or otherwise have the option to authorize an Integrated Service to provide Personal Data or other information to us. By authorizing us to connect with an Integrated Service, you authorize us to access and store your name, email address(es), and basic profile information that the Integrated Service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings on each Integrated Service to understand what information that Integrated Service makes available to us, and make changes as appropriate. Please review each Integrated Service’s terms of use and privacy policies carefully before using their services and connecting to our Service.


Asian Private Banker – Published and owned by Key Positioning Limited

A Notice to Customers regarding the Personal Data (Privacy) Ordinance (“the Ordinance”)


Data Protection Principles – according to The Office of The Privacy Commissioner for Personal Data (Hong Kong), headed by the Privacy Commissioner of Personal Data

Principle 1 — Purpose and manner of collection. This provides for the lawful and fair collection of personal data and sets out the information a data user must give to a data subject when collecting personal data from that subject.

Principle 2 — Accuracy and duration of retention. This provides that personal data should be accurate, up-to-date and kept no longer than necessary.

Principle 3 — Use of personal data. This provides that unless the data subject gives consent otherwise personal data should be used for the purposes for which they were collected or a directly related purpose.

Principle 4 — Security of personal data. This requires appropriate security measures to be applied to personal data (including data in a form in which access to or processing of the data is not practicable).

Principle 5 — Information to be generally available. This provides for openness by data users about the kinds of personal data they hold and the main purposes for which personal data are used.

Principle 6 — Access to personal data. This provides for data subjects to have rights of access to and correction of their personal data.

1. You are in no way obliged to provide Asian Private Banker (owned by Key Positioning Limited) with your personal data. However, such provision may be necessary so as to allow Key Positioning Limited to deliver news products or other services which you have requested.

2. The purposes which we may use your personal data are as follows:

  • the daily operation of the content, services and products provided to you;
  • meeting the requirements to make disclosure under the requirements of any law binding on Key Positioning Limited;
  • informing you of any products or services (including products and services of Key Positioning’s business partners) which Key Positioning Limited deems to be of interest to customers;
  • making services or products for customers’ use;
  • marketing and/or cross-marketing services or products;
  • conducting surveys, polls and/or other such market research; and
  • purposes relating to the above.

3. Your personal data held by Key Positioning Limited will be kept confidential but Key Positioning Limited may disclose and move such information to the following parties, whether within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), for the purpose as set out in clause 2 as mentioned above:

  • any agent, contractor or third party service provider who provides administrative, telecommunications, market research, cross-marketing, survey computer and technical support, printing, payment or other services to Key Positioning Limited in connection with the operation of its business;
  • business partners or certain third parties in order for customers to be kept informed of products or services which Key Positioning Limited believes may be of interest to customers (including products and services of those business partners and third parties);
  • any other person or organization under a duty of confidentiality to Key Positioning Limited which has undertaken to keep such information confidential; and
  • any party to whom Key Positioning Limited is required or permitted by law or any regulatory authority to make disclosure.

4. Where the party as stated in Clause 3 above is situated outside Hong Kong in a place that does not have data protection laws in Hong Kong. In any case, Key Positioning Limited will remain responsible for ensuring the confidentiality of your personal data which will be subject to appropriate security measures.

5. You have the right to:
(a)access to personal data held by Key Positioning Limited about you or your account and update or correct such data;
(b)request for information on items of personal data about you which Key Positioning Limited may routinely disclose to its business partners of cross marketing and administrative purposes;
(c)access to personal data about you so held by those service providers and/or business partners and update and correct such data;
(d)request Key Positioning Limited to stop sending marketing information to you; and
(e)ascertain Key Positioning’s policies and practices in relation to personal data and be informed of the kind of personal data held by Key Positioning Limited.

6. Key Positioning Limited reserves the right to charge a reasonable fee for the processing of any request(s) made under Clauses (5)(a) and (5)(b).

7. Your personal data will only be retained by Key Positioning Limited for as long as necessary for the needs of its business or is permitted by local legislation.

8. You shall promptly notify and contact Key Positioning Limited as set out below of any change in your personal data or other information supplied to Key Positioning Limited.

9. The person requesting access to personal data or correction of such data or for information regarding Key Positioning Limited’s policies and practices and kinds of personal data held or regarding receipt of marketing materials or otherwise is to be addressed as follows:

Key Positioning Limited

13/F Greatmany Centre
111 Queen’s Road East
Hong Kong
Tel: +852 2529 5977 Fax: +852 3013 9984