Please read the following terms and conditions that apply to this website (“Site”).

“We”, “us” or “Vellum” is a reference to Vellum Limited (CR No. 2742805) A references to “you”, “your”, “I” or “their” is a reference to people who visit this Site.

This Site is owned and operated by Vellum. These Terms and Conditions must be read in conjunction with Vellum’s Privacy Policy and Cookie Policy and are in addition to, and do not nullify or supersede any other agreement that you have signed with us to govern our relationship.

Vellum has expressed its own views and opinions on this Site, and these may change without notice including but not limited to Terms and Conditions, the Privacy Policy and the Cookie Policy. Your continued access to, or use of, the Site means that you agree to and accept the changes we make. You may want to periodically review these Terms and Conditions, the Privacy Policy and the Cookie Policy for changes.


The documents on this Site are only intended for use by residents of Hong Kong SAR. Subject to the laws of Hong Kong and the laws of the country and/or territories in which you are located, if you are a non-resident of Hong Kong, please contact us on +852 3643 1168 if you require information from us.

Nature of Information on this Site

Vellum believes the information on the Site and their sources to be reliable, the Information’s accuracy and currency cannot be assured. The Information (including opinions and estimates) is subject to change from time to time. Your use of this Site is at your own risk.

You agree that you will not rely on the Information, and you acknowledge that, to the extent permitted by law including any guarantees or warranties implied by any consumer protection law, we DO NOT:

•warrant or guarantee the timeliness, currency, accuracy, completeness, merchantability or fitness for a particular purpose of the Information;
• take responsibility for any error, omission or defect contained in the Information; and
• are obliged to update the Information or correct any inaccuracy which may become known to us.

General information only

The information on this Site is of a general nature only. It is not professional advice, and you and any user of this site must not rely on it. Users of this site must rely on their own independent enquiries and seek their own advice. It has been prepared without taking account of any investor’s objectives, financial situation or needs. Before acting on anything on this Site, you should consider its appropriateness having regard to your objectives, financial situation or needs and also consider seeking professional financial, taxation or legal advice (Professional Adviser) before making any decision.


We, our related bodies corporate and our officers, employees and agents are indemnified against all actions, claims and demands (including the cost of defending or settling any action, claim or demand) which may be instituted against us arising out of a failure by you to comply with these Terms and Conditions.

Access by you to the Site

You must ensure that your access to this Site is not illegal or prohibited by laws which apply to you. You must take your own precautions to ensure that the process which you employ for accessing this Site does not expose you to the risk of viruses, malicious computer code or other forms of interference, which may damage your own computer system. To avoid any doubt, we do not accept responsibility for any interference or damage to your own computer system which arises in connection with your use of this Site or any linked site.

Copyright, trademarks and intellectual property rights

Unless expressly stated, Vellum is the owner of the copyright and any intellectual property rights in any material, design, technology or concept contained on this Site. All rights are reserved. You may use the information for your own personal reference only. You may reproduce the information in hard copy solely for your personal use. Except as permitted under the Copyright Ordinance(Cap.528) or other applicable laws, this Site or any portion of this Site may not otherwise be reproduced, adapted, distributed, displayed, or transmitted to any other person or incorporated in any way into another document or other material, without the express consent of Vellum.

Linked Sites

This Site may contain links to other websites (“linked sites”). Vellum does not control or endorse and is not responsible for the contents of these third party linked sites, and provides hyperlinks or redirects you to third party websites for your convenience only. Any information, opinions, representations or offers made in those linked sites or redirected third party websites are solely the responsibility of the third parties operating those websites and not of Vellum. Vellum makes no representation or warranty as to the accuracy or reliability of the information on those websites.

Principles of Privacy Policy

Privacy Policy of the Site explains how we will handle your personal information according to the Personal Data (Privacy) Ordinance (Cap. 486) and the other Hong Kong privacy principles, as applicable.

Personal Information and Collection

Vellum will collect information only where necessary for the primary purpose of:

– providing you with our services and products or with information you have requested
– notifying you about other Vellum services or promotions from time to time
– identification purposes as required for anti-money laundering and counter-terrorism financing purposes or other Hong Kong or extraterritorial taxation, legal or regulatory obligations
– meeting our obligations under laws and regulations
– managing our relationship with you.

We endeavor to collect personal information in a lawful and non-obtrusive way.

The types of personal information that Vellum collects and maintains generally comprises:

– your name
– contact details such as telephone numbers, address and e-mail address
– birth date
– tax file number
– bank account details
– citizenship
– other information that may be required for identification, product design and distribution or taxation purposes.

Unless require by law, we DO NOT collect your sensitive, such as information about your religion, race, political views, criminal convictions, health information or membership of professional or trade associations or unions.

How we collect Personal Information

We will normally collect your personal information directly from you, unless you have appointed a person, agent or broker to act on your behalf.

The ways we may collect your personal information include:

– direct from you when you complete an application form in relation to our service(s) (either hard copy or on-line application forms)
– when you contact us via email or telephone
– when you participate in surveys or competitions or promotions or add your name to any mailing lists.
– From third parties when you have provided authority for us to do this, e.g. from attorneys, financial advisers, platform providers, brokers, lawyers, identification verification service providers.
– From public or commercially available sources for the purposes of complying with customer due diligence obligations, product design and distribution obligations or to ensure contact details are up to date and accurate.

Vellum may record and monitor telephone calls for security, training and compliance purposes.

Use and Disclosure of the Personal Information

Vellum will typically use personal information for the following purposes:

– to comply with applicable laws and regulations, including anti-money laundering, product design and distribution, taxation and associated laws
– to process and verify your application for our products and/or service(s)
– to inform you of other products or services or offers that may be of interest to you and to improve and customise our products and services
– to manage your investment with us
– to conduct product and market research, including product suitability assessments.

We will only use and disclose personal information about you for the purpose for which it is collected, unless consent has been obtained to use the information for additional purposes. Exceptions to this include where disclosure is:

– required by law(s) and/or regulation(s)
– reasonably necessary to assist a law enforcement agency
– reasonably required by a third party service provider to meet their legal or regulatory obligations
– required by external companies for the purposes of issuing statements and handling mail.

Vellum may disclose your personal information to:

– your attorney, financial adviser, platform provider, broker or any other person you have authorized
– professional services firms that have a legitimate need to access this information, such as lawyers, auditors
– electronic identification verification providers.

Storage, Access and Change of Your Personal Information

We take reasonable steps to protect the personal information that we hold from misuse and loss and from unauthorised access, modification and disclosure.

From time to time, Vellum or its third-party providers may store your information in hard copy(ies), in cloud or other types of networked systems. Information stored in cloud or network-based systems can be accessed from and transferred between, various countries over the internet, and as such, it is not always practicable to know in which country your information may be held. By providing your personal information to us, you acknowledge that countries in which your information may be held will have privacy and data protection laws that may differ from those of Hong Kong and overseas organisations may be required to disclose information that Vellum has shared with them, under foreign laws.

You may request details of personal information which we hold about you under the The Personal Data (Privacy) Ordinance (Cap. 486). If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.

Cookie Policy

How do we use cookies?

This website uses cookies. Cookies are tiny text files which identify your computer to our server as a unique or regular user when you visit certain pages on this website and they are stored by your Internet browser on your computer’s hard drive.

Once you confirm that you agree to this website’s Terms and Conditions, we will place a cookie on your computer to recognise you. We use cookies for collecting user information from this website which may include personal information about you when you use and access this website. While we do not use browsing information to identify you personally, we may record certain information about your use of this website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your activities on this website or to your account (if account functionality is available), it will be considered personal information under the Personal Data (Privacy) Ordinance(Cap. 486).  We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in our Privacy Policy.

We do not use cookies to obtain or use other information about you (for example targeted advertising).

The cookie will expire 30 days after the end of your session or sooner if there is a change to these Site Terms and Conditions. Your browser can be set to disable cookies, but this may restrict your use of this Site. If you want to find out more information about cookies, go to or to find out about disabling them from your browser, go to

Here are some links to instructions for the most common browsers:

Microsoft Internet Explorer

Mozilla Firefox

Google Chrome


For other browsers, try searching for “managing cookies in (browser name)”.

The cookie is used to:

Help you save time while on or accessing this Site. As a result, these Site Terms and Conditions will not reappear if you access this Site in future from your computer.
Help identify when you are accessing a part of this Site which is not intended for you.

Please contact us if you:

– have any questions about this Site including its Terms and Conditions, Privacy Policy, or Cookie Policy;
– wish to access or correct your personal information that we hold; or
– you would like to make a complaint about the way in which we have handled your personal information.

Important Information