Privacy Statement and Personal Data Collection Statement

(collectively referred to as the Privacy Policy)

This Privacy Policy sets out how we collect, use, process, disclose, share, transfer and protect personal data. The terms and definitions used in this Privacy Policy shall have the same meanings as those given in the Terms of Service of Beacon AMC, unless otherwise defined herein. We request certain personal data from users either because applicable laws or regulations mandate such collection, or because the data is relevant to our specific purposes. Provision of your personal data is voluntary; however, failure to provide such data may result in our inability to provide services to you and to accept and/or process your investments.

We fully recognize and respect the importance of your personal data, and shall implement appropriate security measures to protect your personal data in accordance with applicable laws and regulations. We are committed to safeguarding the privacy, confidentiality and security of personal information in our possession, in compliance with the requirements of the Personal Data (Privacy) Ordinance (the PDPO). We are also committed to ensuring that all our employees and agents fulfill these obligations. This Privacy Policy applies to all services provided by us. In the event of any inconsistency between this Privacy Policy and any other policies specifically applicable to any products or services we provide to you, such other policies shall prevail; in all other circumstances, this Privacy Policy shall govern.

Please ensure that you have carefully read and fully understood this Privacy Policy before using our services. By using our services, you agree to be bound by this Privacy Policy. If you do not agree with any of the terms or conditions set out in this Privacy Policy, you must immediately cease using our services. If you have any questions, comments or suggestions regarding this Privacy Policy, you may contact our Data Protection Officer.

Clause 1: Personal Data

If you are a user of services provided by Beacon AMC, the data we may collect (Customer Personal Data) includes, but is not limited to, your:

a) Full legal name (including any former names and names in both Chinese and English, as applicable); gender; date of birth; nationality; country of residence; contact telephone number; email address; residential address; passport number; other identification documents; tax residency; and tax identification number;

b) Identity verification data and facial recognition data;

c) Proof of residence;

d) Employment information (including details of your occupation, such as employer’s name, nature of business, position held, length of service and office contact information);

e) Financial information;

f) Transaction information, such as your historical transaction records with us; and

g) Proof of source of funds and/or financial resources.

Clause 2: Collection, Use and Disclosure of Customer Personal Data

We generally collect Customer Personal Data during your registration application process with us, or in connection with such registration application, or receive disclosure of your Customer Personal Data from your authorized signatories or authorized dealers (collectively referred to as Authorized Representatives), provided that (i) we have informed you (or your Authorized Representative) of the purposes for collecting the data; and (ii) you (or your Authorized Representative) have given written consent to the collection and use of Customer Personal Data for such purposes. You confirm that you or your Authorized Representative are providing Customer Personal Data to us with full knowledge of the relevant purposes. We shall seek your consent prior to collecting any additional Customer Personal Data and prior to using your Customer Personal Data for any purposes not previously disclosed to you (except where permitted or authorized by law).

We will collect and use Customer Personal Data for the following purposes, and may, where necessary, disclose the collected Customer Personal Data to our affiliates, group companies, advisors, entities that provide products and/or services to us (including, but not limited to, information technology system providers, customer due diligence and anti-money laundering compliance service providers), government authorities, regulatory bodies and associated companies for such purposes:

a) To ensure compliance with legal and regulatory requirements; for example, adherence to anti-money laundering and counter-terrorist financing laws in various jurisdictions (you acknowledge that we may share your Customer Personal Data with our affiliates and group companies for customer due diligence and anti-money laundering purposes, and that you may or may not be required to provide additional Customer Personal Data if you choose to use services provided by our affiliates or group companies), and conducting relevant checks, including determining whether you qualify as a Professional Investor under the Securities and Futures Ordinance (as amended from time to time);

b) To maintain investor registers;

c) To collect fees and charges;

d) To enforce the terms and conditions of this Privacy Policy and other agreements (as applicable);

e) To assess your eligibility for registration with us;

f) To fulfill our obligations arising from or in connection with the provision of goods or services to you;

g) To improve our products/services, marketing efforts or customer relationships;

h) To conduct direct marketing and send you updates on our products/services, benefits, promotions and rewards via the short message service (SMS), email addresses and/or contact numbers you provide to us from time to time; and

i) To facilitate our compliance with any applicable laws, customs and practices. If you are acting on behalf of the beneficial owner of an entity or another individual, you must inform them of the above purposes. We may require you to provide evidence of such notification.

The purposes set out in the above clauses may continue to apply for a reasonable period of time even after the termination or change of your relationship with us (e.g., this Privacy Policy), including, where applicable, a period sufficient to enable us to enforce our rights under any agreement entered into with you.

We will only process, use or disclose Customer Personal Data if:

a) It is solely for the purpose of fulfilling our obligations and providing the services under this Privacy Policy, as well as the purposes disclosed above; or

b) We have obtained your prior written consent; or

c) Required by applicable laws or regulations, in which case we shall notify you where such laws or regulations permit.

Clause 3: Information from Third-Party Sources

From time to time, we may obtain information about you from third-party sources as permitted or required by applicable laws and regulations (e.g., public databases, credit reference agencies, identity verification partners, distributors and channel partners, co-marketing partners and social media platforms). We may obtain information about you from public databases and identity verification partners for the purpose of verifying your identity. Identity verification partners verify your identity by cross-referencing government records and publicly available information about you. Such information includes your name, address, job title, public employment information, credit history, status on any sanctions lists maintained by public authorities and other relevant data. We obtain such information to comply with our legal obligations (e.g., anti-money laundering laws).

Clause 4: Sharing Personal Data with Third Parties

We shall ensure that access to Customer Personal Data is restricted to persons who need such information to perform their duties and responsibilities, and that Customer Personal Data is shared with third parties who have a legitimate purpose for accessing the same. We will only share such information in the following circumstances:

a) We may share Customer Personal Data with third-party identity verification service providers to fulfill our obligations under applicable laws, regulations and policies;

b) We may share Customer Personal Data with service providers who assist in our day-to-day business operations, as stipulated by contract. This may include (but is not limited to) payment collection, marketing, customer support and technical services;

c) We may share Customer Personal Data with other members of our group, trustees, service providers, agents, contractors, data processors, fund managers, telecommunications companies or professional firms, and their duly authorized representatives (including their employees, directors or agents), for the purpose of processing your investments; and

d) We may share Customer Personal Data with law enforcement agencies, government authorities, regulatory bodies or other third parties when required to do so under applicable laws, regulations and policies, or when we in good faith believe that such disclosure is necessary to prevent personal injury or financial loss, report suspected illegal activities, or investigate violations of this Privacy Policy or any other agreement.

Clause 5: Retention of Personal Data

We may retain Customer Personal Data for such period as is necessary to fulfill the purposes set out in this Privacy Policy or as required or permitted by applicable laws. When we reasonably determine that retaining Customer Personal Data is no longer necessary for the purposes for which it was collected or for any legitimate purposes, we will cease retaining such data or expeditiously delete information that can be associated with the data subject.

Clause 6: Protection of Personal Data

To protect Customer Personal Data against unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented appropriate administrative, physical and technical measures, such as up-to-date anti-virus protection, encryption and the use of privacy filters to safeguard all storage and transmission of Customer Personal Data, as well as restricting disclosure of Customer Personal Data internally or to our authorized third-party service providers and agents on a need-to-know basis. However, you should be aware that no method of internet transmission or electronic storage is completely secure. While absolute security cannot be guaranteed, we shall endeavor to protect the security of Customer Personal Data and continuously review and enhance our information security measures.

Clause 7: Access to and Correction of Personal Data

You have the right to request access to and correction of your Customer Personal Data in accordance with the provisions of the PDPO. If you wish to make (a) an access request to obtain a copy of the Customer Personal Data we hold about you or information about how we use or disclose your Customer Personal Data; or (b) a correction request to amend or update the Customer Personal Data we hold about you, you may submit your request in writing or via email to our Data Protection Officer, whose contact details are set out below. Please note that a reasonable fee may be charged for processing access requests. If a fee is applicable, we will notify you of the relevant amount before processing your request. We will respond to your access request as soon as reasonably practicable. If we are unable to respond to your access request within a reasonable time after receipt, we will notify you in writing of the time frame within which we can respond.

Clause 8: Transfer of Personal Data Outside Dubai

Customer Personal Data provided by you, or copies thereof, may be disclosed or transferred to entities relevant and necessary for the purposes set out in Clause 2 above. We generally do not transfer Customer Personal Data to countries outside Hong Kong. However, certain of our service providers, affiliates and group companies may store, transfer and otherwise process Customer Personal Data outside Hong Kong for the purposes stated above. Where such storage, transfer and processing take place, we will implement measures to ensure that your Customer Personal Data continues to be protected to a standard at least equivalent to that provided under the PDPO. If you are entering into this Privacy Policy on behalf of an entity, you confirm that all beneficial owners of the entity consent to the transfer of Customer Personal Data outside Dubai for the purposes set out above. We may require you to provide evidence of such consent.

Clause 9: Accuracy of Personal Data

We generally rely on the Customer Personal Data provided by you (or your Authorized Representative) being complete, accurate and up-to-date. To ensure that the Customer Personal Data you have provided remains current, complete and accurate, you shall notify our Data Protection Officer of any changes to such data via email, using the contact details set out below.

Clause 10: Consent and Withdrawal of Consent

By providing Customer Personal Data to us during registration and/or entering into this Privacy Policy, you confirm that you have read, understood and agreed to all the terms and conditions of this Privacy Policy, and consent to the collection, use, disclosure and/or processing of Customer Personal Data for all the purposes set out herein. Such consent shall remain in effect until you withdraw it in writing. You may withdraw your consent to the collection, use, disclosure and/or processing of Customer Personal Data at any time by sending a written notice via email to our Data Protection Officer at grayscalehk@gmail.com. Upon receipt of your request, we will notify you of the potential consequences of withdrawing consent within 30 days from the date of receiving your withdrawal request. Following your withdrawal, we will cease collecting, using or disclosing Customer Personal Data (as the case may be), except where collection, use or disclosure of Customer Personal Data without consent is required or authorized under the PDPO or any other applicable laws or regulations.

Clause 11: Use of Cookies

A cookie is a small file (or record within a file) that a website may send to your browser, which your browser may then store on your computer’s hard drive. We use cookies to track your visits to our website and identify your web browser upon your return visits, thereby improving our website to enable us to gather statistics on new and returning visitors, as well as process transactions and services conducted through the website. Cookies also allow us to store registration and subscription information or passwords, eliminating the need for you to re-enter such information each time you visit our website, thereby enhancing the user-friendliness of our website. Notwithstanding the above, you are not obligated to accept cookies. You should refer to the information provided with your web browser to learn how to configure your browser to notify you when you receive a cookie, giving you the opportunity to decide whether to accept or reject it. If you choose to block the use of cookies, certain features of our website may not function properly.

Clause 12: Third-Party Links

We may provide hyperlinks to other internet locations or websites (Third-Party Websites). Any links you establish with or from Third-Party Websites shall be at your own risk. Use of Third-Party Websites shall be subject to the terms and conditions of such websites, and any information you provide shall be governed by the terms of such websites, including those relating to confidentiality, data privacy and security. Unless otherwise expressly agreed in writing, we shall have no liability or responsibility for any goods or services provided on Third-Party Websites. We do not advertise, endorse, approve or warrant the content of Third-Party Websites, nor make any representations or warranties whatsoever in respect thereof. We disclaim all liability for any losses, damages and any other consequences arising directly or indirectly from your access to Third-Party Websites, any information you provide on or through Third-Party Websites, any transactions you conduct thereon, any issues with the information, goods or services published or provided on Third-Party Websites, any errors, omissions or misrepresentations on Third-Party Websites, any computer viruses originating from Third-Party Websites, or any system malfunctions related to Third-Party Websites. We shall not be a party to any contractual arrangements between you and the providers of any Third-Party Websites, unless otherwise expressly stated or agreed.

Clause 13: Data Protection Officer

We may update this Privacy Policy from time to time by publishing the revised version on our website. If you have any inquiries or feedback regarding our data protection and privacy policies and procedures, you may contact our Data Protection Officer via email at grayscalehk@gmail.com.

Clause 14: English Version Prevails

The Chinese translation of this Privacy Policy is provided for reference purposes only. In the event of any inconsistency or conflict between the Chinese and English versions of this Privacy Policy, the English version shall prevail.