奥陆资本有限公司

PRIVACY POLICY

Oscar and Partners Capital Limited (“OP CAPITAL”) and its employees are committed to collect, use, retain, transfer and access customers' personal data in compliance with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 ("Ordinance") and Personal Data (Privacy) (Amendment) Ordinance 2012 (“Amendment Ordinance”) of the laws of the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"). We take the privacy of our customers very seriously and we are concerned to protect your personal data. We believe it is important that you know how we treat the information about you that we receive through this web site. Therefore we will only use your personal information as set out in this Privacy Policy.

Our Data Collection Methods

We may collect personal data pursuant to know-your-client and/or anti-money laundering related requests, a website or client account, any legal agreements, checklists, forms (including subscription forms and Foreign Account Tax Compliance Act / the Common Reporting Standard forms), and in any other documentation provided by us or OP CAPITAL’s service providers (including administrators and custodians) and completed by our customers in connection with or ancillary to asset management, investment advisory, registration, tax reporting, licensing or other related matters or services.

Legal Basis and Purposes for Collecting Your Personal Data

The primary legal basis for collecting your personal data is to enable us to provide asset management and advisory services to our clients in compliance with applicable legal and regulatory requirements. This includes complying with relevant customer or vendor due diligence, know-your-client or any anti-money laundering requirements, as well as any tax, regulatory codes of conduct, guidance or circulars published by regulatory authority with oversight over our operations.

Your Consent to Collection, Processing, Storage and Transfer to Third Parties

By providing personal data in connection with the foregoing Data Collection Methods, you are providing us with express consent to collect, process, store and transfer your data in accordance with this policy. In addition, for certain personal data, in particular for Foreign Account Tax Compliance Act or Common Reporting Standard forms, any information (including personal data) you provide in those forms will be reported to relevant tax authorities in compliance with our tax reporting obligations. We are also required to report breaches of personal data to regulatory authorities.

Sharing of Personal Data to certain Third Parties Which May be Located Outside Your Country / Region

OP CAPITAL is committed to the protection and privacy of personal data. OP CAPITAL may transfer your personal data outside Hong Kong, United States or European Union to Hong Kong (OP CAPITAL) or to the location where our data processors / service providers collect and process your personal data, which is primarily in Hong Kong.

OP CAPITAL will not share such information with any affiliated or non-affiliated third party except:-

• For the purposes of conducting customer or vendor due diligence, know-your-client or anti-money laundering checks;
• For the purposes of operating a customer relationship or risk management system with a third party vendor;
• When necessary to complete a transaction in a customer account, such as with the execution broker, trade counterparty, clearing firm or account custodians;
• When required to maintain or service a customer account, including sharing with a fund administrator or custodian;
• To resolve customer disputes or enquiries;
• With persons acting in a fiduciary or representative capacity on behalf of the customer;
• With rating agencies, persons assessing compliance with industry standards, or to the attorneys, accountants and auditors of OP CAPITAL;
• In connection with a proposed sale or merger of OP CAPITAL’s interests or business;
• To protect against or prevent actual or potential fraud, identity theft, unauthorized transactions, claims or other liability;
• To comply with country, federal, state or the laws, rules and other applicable legal requirements in any jurisdiction, or in connection with a regulatory request;
• In connection with a written agreement to provide services, including investment management or advisory services when the information is released for the dominant purpose of providing the products or services covered by the agreement; and/or
• In any circumstances with the customer’s instruction or consent, or ancillary to the above.

Data Minimization

We aim to collect personal data to the extent reasonably necessary to fulfil the Legal Basis and Purposes set out above.

Under and in accordance with the provisions of the Ordinance, any customer has the right:

a. to check whether the Company holds personal data about him/her and the right of access to such personal data;

b. to require the Company to correct any personal data relating to him/her which is inaccurate;

c. to ascertain policies and practices of the Company in relation to personal data and to be informed of the kind of personal data held by the Company; and/or

d. in relation to customer credit, to request the Company to inform him/her which items of personal data are routinely disclosed to credit reference agencies and debit collection agencies and to request the Company to provide him/her with further information to enable him/her to make an access request and/or correction request of the relevant credit reference agency or debt collection agency about his/her personal data.

Cookies

When a person visits the website(s) of the Company, the server will record his/her visit only and will not collect any personal data from him/her unless otherwise stated. “Cookies” used (if any) in any part of the website(s) of the Company will not be deployed for collecting personal data. “Cookies” are small computer files that can be stored in web surfers’ computers for the purposes of obtaining configuration information and analysing web surfers’ viewing habits. They can save web surfers from registering again when re-visiting a website and are commonly used to track their preferences in relation to the subject matter of the website. A person may refuse to accept “Cookies” (by modifying the relevant Internet options or browsing preferences of his/her computer system), but to do so such person may not be able to utilise or activate certain available functions in the website(s) of the Company.

Requests for access to or correction of personal data or for information regarding policies and practices and kinds of personal data held by the Company shall be addressed to Oscar and Partners Capital Limited, Unit 3103, Lippo Centre, Tower 2, No. 89 Queensway, Admiralty, Hong Kong(Attn. Compliance, Personal Data Protection).

Safeguarding your Personal Data

We endeavour to safeguard and protect your personal data from unauthorized access. OP Capital endeavours to prevent unauthorised disclosures of your personal information by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority.