Terms and conditions

By accessing this website and any of its pages, you agree to accept the terms and conditions set out below, and continuing to use this website following the posting of any changes to these terms and conditions will signify your consent to the changes made.


The website is primarily intended for those who access it from within Hong Kong. The Tracker Fund of Hong Kong  (“Fund”) referred to on this website are offered only in jurisdictions where and when they may be lawfully offered by Hang Seng Investment Management Limited ("Manager"). The information on this website is not intended for use by persons located in or resident in jurisdictions which restrict the distribution of such information by the Manager. You are required to inform yourself about and observe any relevant restrictions when accessing this website.


This website is not and should not be regarded as an offer, solicitation or recommendation to any person in a jurisdiction to buy or sell any product if it is unlawful to make such an invitation, offer, solicitation or recommendation in such jurisdictions.


The information contained in this website is not, and is not intended to provide, professional investment or other advice. When accessing this website, you should obtain appropriate professional advice where necessary.


Any information contained in this website may be withdrawn or amended at any time without advance notice at the discretion of the Manager. The eligibility of visitors to this website for access to any particular information herein is subject to the final and absolute discretion of the Manager.


It is your sole responsibility to prevent, safeguard and ensure that no computer virus enters your system and this website.


These terms and conditions shall be governed by and construed in accordance with the laws of the Hong Kong SAR. By accessing this website and any of its pages, you agree to submit to the non-exclusive jurisdiction of the courts of the Hong Kong SAR and acknowledge that you understand that these terms and conditions may be enforced in the courts of any competent jurisdiction.

No Warranties

The Manager endeavours to ensure the accuracy and reliability of the information provided herein but does not guarantee its accuracy or reliability, and accepts no liability (whether in tort or contract or otherwise) for any loss or damage arising from any inaccuracies or omissions. Where the information related to the Fund is sourced externally (as disclosed), the Manager has reasonable belief that such information is accurate, complete and up-to-date.


No warranty or representation regarding non-infringement, security, accuracy, fitness for a particular purpose or freedom from computer virus, Trojan horses, worms, software bombs or similar items is given in conjunction with such information. The Manager shall not be liable for any loss or damage whatsoever and howsoever arising as a result of your use of the information contained in this website. The Manager does not represent or warrant that this website will be available and meet your requirements, that access will not be interrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system. You have sole responsibility for adequate protection and back up of data and/or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses or other destructive properties. The Manager makes no representations or warranties regarding the accuracy, functionality or performance of any third party software that may be used in connection with this website.

Linked Websites

Use of hyperlinks to other websites or resources is at your own risk. The content, accuracy, opinions expressed, and other links provided at these websites are not investigated, verified, monitored, or endorsed by the Manager. The Manager expressly disclaims any responsibility for the accuracy, content, availability or omission of information found on other websites that link to or from this website. You are solely responsible for making all enquiries and investigation before proceeding with any online or offline access or transaction with any of these third parties. The Manager emphasises that all activities conducted by you via or at this website are at your own risk. The Manager does not warrant the security of any information you may forward or be requested to provide to any third parties. You are deemed to have irrevocably waived any claims against the Manager for any loss or damage suffered as a result of any access to or interaction with any other websites via this website.


This website may include hyperlinks to other Hang Seng Bank Group websites for your convenience. The products and services offered on these websites may be limited only to persons located or residing in a particular jurisdiction. In addition, the content on these linked websites may not be intended for persons located or residing in jurisdictions that restrict the distribution of such content. The terms and conditions governing the use of the website of each Hang Seng Bank Group entity may differ and you should consult and carefully read the applicable terms and conditions before using the website.

Security Reminder

The Manager maintains strict security standards and procedures to prevent unauthorised access to information about you. The Manager will never contact you by email or otherwise and ask you to validate personal information such as your ID, account number or password information. If you receive such a request, you should contact the Manager at 2198 5890. Please communicate with the Manager through its official website domain address (www.trahk.com.hk) and not through hyperlinks embedded in e-mails.

Copyright and Trademarks

The Manager and other parties own the trademarks, logos and service marks displayed on this website and you are prohibited from using them without written permission of the Manager or such other parties.


All content on this website, including but not limited to the text, graphics, links and sounds, is protected by copyright and no part of such information may be modified, reproduced, stored in a retrieval system, transmitted (in any form or by any means), copied, distributed, reused, reposted, reverse engineered, decompiled, used for creating derivative works or used in any other way for commercial or public purposes without the Manager's prior written consent.


  • Android, Google Play and the Google Play logo are trademarks of Google LLC.
  • Apple, the Apple logo, and iPhone are trademarks of Apple Inc., registered in the US and other countries. App Store is a service mark of Apple Inc.

Privacy Policy

The Manager builds its business on trust between you and itself. To preserve the confidentiality of all personal data you provide, the Manager maintains the following privacy principles:


  1. Transparency: The Manager will be clear and transparent as to how it collects and uses data, including providing data subjects (including personal customers, corporate customers, representatives and non-affiliated third parties (such as vendors and their representatives)) with a statement of how it may use their data where required.
  2. Fair and lawful usage: The Manager will only collect, process and store data lawfully and where it has a legitimate reason to do so.
  3. Limited purposes: The Manager will collect and process data for specified and lawful purposes, and will not use it for further, incompatible purposes without first taking all steps necessary under applicable data privacy laws and regulations.
  4. Data minimisation and adequacy: The Manager will ensure its collection, retention and processing of data is proportionate. The Manager will strike an appropriate balance to ensure that it processes sufficient data to carry on its business and achieve any specified lawful purposes, while making sure that it does not collect, retain or process excessive amounts of data.
  5. Data quality and accuracy: The Manager will maintain appropriate standards of data quality and integrity, and will implement policies in respect of data accuracy, including taking steps where appropriate to avoid data becoming out of date.
  6. Data security and retention: The Manager will retain data securely, implement appropriate data retention policies, and will dispose data securely once it is no longer required. The Manager will ensure that appropriate processes are put in place so only those acting on its behalf with a business requirement to access such data are authorised and able to do so.
  7. Training and awareness: The Manager will ensure that those acting on its behalf with access to data are trained appropriately on their obligations regarding those data.
  8. Data subject rights: The Manager will ensure that data subjects’ rights are observed in accordance with applicable data privacy laws and regulations, including any timeline established thereby.
  9. Third parties: Where the Manager appoints a vendor or agent, it will require them to apply standards equivalent to these Data Privacy Principles. The Manager will only disclose data to governmental or judicial bodies or law enforcement or agencies or regulators where this is allowed by applicable Data Privacy Laws and Regulations, or otherwise required by applicable laws and regulations.
  10. Data transfers: Where the Manager voluntarily transfers data to another HSBC Group entity, third party or to another jurisdiction, the Manager will ensure that the data transfer is lawful and that the recipient is required to apply the same, or equivalent, standards as these Data Privacy Principles.


By maintaining commitment to these principles, the Manager will ensure that it respects the inherent trust that you place in it.


In addition to the Manager’s duty of confidentiality to you, it shall at all times observe the above privacy principles and the Personal Data (Privacy) Ordinance ("the Ordinance") of the Hong Kong SAR in collecting, maintaining and using the personal data of customers in accordance with the Notice to Investors, Distributors, Discretionary Mandate Clients (collectively "Clients") and Other Individuals relating to the Personal Data (Privacy) Ordinance (the "Ordinance") (the “Notice”).

Use of cookies

The Manager may gather the following information through the use of cookies. Cookies are text files with small pieces of data that are automatically stored on your web browser in your computer, mobile phone or other device for accessing the Internet that can be retrieved by this website. Cookies will:

  • Record your visit to this website for analysing the number of visitors to this website and users’ general use patterns.
  • Record your personal use patterns, profile, preferences and interests through your use of this website to improve your experience.
  • Allow this website to recognise your device, and store information about your personalised settings (such as language preference, and useful links settings) and your use of this website (such as visits, as well as your behaviour, pattern and footprints regarding the use of this website). This will allow the Manager to provide more useful features to you by customizing this website content to suit your interests.

The Manager has the ability to access the information stored incookies. These data obtained through cookies may be combined and  compared with your personal data collected and used (or to be collected and used) by the Manager in accordance with the Notice. This includes but is not limited to your demographic data, transaction details and transaction patterns, and product holdings for analytical, direct marketing, and fraud detection and fraud prevention.  If you’ve given permission based on your marketing preferences, the Manager may also use this data and your personal information to provide you with promotional materials or direct marketing.

Most browsers are initially set to allow cookies. If you prefer, you can set your browser to disable cookies – you can do this through your browser setting (your browser’s “Help” function should tell you how to do this).

By disabling cookies, you may not be able to take full advantage of this website.

If you have not disabled cookies during your use of this website or continue to use this website, you will acknowledge that your information and personal data (if any) is being collected, stored, accessed and used as above.

The Manager may also work with third parties (as listed below) to research certain use and activities on this website on our behalf. They use technologies such as tracking tags, cookies spotlight monitoring (managing tagging which is used for example, to track which advertisement users clicked on to take them to a site) and web beacons (monitoring the behaviour of the user, for example whether they scroll down a page) to collect information for this research. They use the information collected through such technologies:

  • to find out more about users of this website, including the number of the visitors, user demographics, preferences, interests, behaviour and usage patterns.
  • for internal reporting.
  • to improve the effectiveness of the Manager’s marketing.

They collect information and then share it with the Manager but these information may possibly be combined and matched with your personal data collected or to be collected by the Manager in accordance with the Notice to enable your identity to be directly or indirectly ascertained. As part of the information that the Manager shares with them, the Manager may share your information including but not limited to advertising identifier, "installation event" (which means the data in relation to when you first install or use this website) and digital footprint. Personally identifiable information about you may be collected or shared by the third-party agencies with the Manager as a result of this research.

To find out more about the use of cookies and the information-collecting practices and opt-out procedures of third parties research agencies, please visit:

  • Bing’s website at  https://privacy.microsoft.com/en-us/privacystatement
  • Google Campaign Manager (DoubleClick Campaign Manager)/ Google Display & Video 360 (DoubleClick Bid Manager)/ Google Webmaster’s website at http://www.google.com/intl/en/policies/privacy/
  • Yahoo’s website at https://legal.yahoo.com/us/en/yahoo/privacy/topics/cookies/index.html
  • Appier website at https://www.appier.com/en/about/privacy-policy
  • Optimizely’s website at https://www.optimizely.com/legal/opt-out/
  • Brightcove’s website at https://www.brightcove.com/en/legal/cookie-policy/
  • Biocatch’s website at https://www.biocatch.com/privacy-policy
  • Threatmetrix’s website at https://risk.lexisnexis.com/group/privacy-policy
  • Adobe’s website at http://www.adobe.com/privacy
  • LivePerson LiveEngage 2.0’s website at https://knowledge.liveperson.com/security-regulations-liveperson-cookies.html/
  • Qualtrics’s website at https://www.qualtrics.com/privacy-statement/
  • The Trade Desk’s website at https://www.thetradedesk.com/us/privacy
  • Tealium’s website at https://tealium.com/cookie-policy/
All of these links are external to Hang Seng Investment and so the Manager is not responsible for the content of these links.

Cross Border Disclaimer

This website is provided by the Manager. The Manager is regulated and authorised to carry out investment management activities in the Hong Kong SAR. The products and services represented within this website are intended for Hong Kong investors.


The information on this website is not intended for distribution or use by any person in any jurisdiction, country or region where the distribution or use of such information is restricted and would not be permitted by any applicable law or regulation.

Language Version

In the event of any inconsistency between the Chinese translation and the English version of these terms and conditions, the English version shall prevail.

Governing Law

These terms and conditions are governed by and interpreted in accordance with the laws of the Hong Kong SAR.

Contact Us

Hang Seng Investment Management Limited

83 Des Voeux Road Central

Hong Kong


Request for access to personal data or correction of personal data or for information regarding policies and practices on personal data and kinds of personal data held should be addressed to:


Data Protection Officer

Hang Seng Bank Limited

83 Des Voeux Road Central

Hong Kong

Fax : (852) 2868 4042

Investment involves risk and past performance is not indicative of future performance. Please refer to the offering document for further details including the risk factors. The website has not been reviewed by SFC. Issued by Hang Seng Investment Management Limited.