A50 Real Assets/ A50 Real Assets Limited (collectively “A50 Real Assets Group”, “we”, “us” or “our”), recognize the importance of protecting your privacy. Our Privacy Policy (“Policy”) applies to your use of our websites (collectively, the “Site”), as well as your professional interactions with our employees. This Policy is provided to you pursuant to the Personal Data (Privacy) Ordinance of Hong Kong (“Ordinance”) and is designed to assist you in understanding how we collect, use, safeguard and disclose your personal information and your choices in making informed decisions when using the Site. 

 

 

1. Your Acceptance Through Use

 

This Policy describes how A50 Real Assets Group collects, uses, and discloses certain personal information obtained through this Site. Please note that, to the extent permitted by applicable law, your use of this Site signifies your understanding and acceptance of the terms of the Policy. This Policy is incorporated into, and is part of, the Terms and Conditions, which govern your use of this Site in general. 

 

2. Purpose

 

In general, we collect your personal information for the particular business function or activity to which the collection of the data concerned is considered directly related. The personal information must be necessary in order to carry out that function or activity, and serve a legitimate business interest. 

 

3. The Types of Information We Collect

 

The types of personal information we may collect from you include, but is not limited to, name and address, occupation, and contact details. 

 

Depending on the nature of your relationship with A50 Real Assets Group and the nature of transaction, we may require additional information from you, such information may include, but is not limited to, date and country of birth, nationality, identity card, country of tax residence, tax reference numbers, and details of financial status. 

 

 

A50 Real Assets’ Group’s Sites may also collect information from you, in particular:

 

• The IP address of the visitor’s personal computer, the country from which the inquiry is made, the pages visited, the time at which a visit is made and the browser type

 

• Your professional information, for example, your business email, business phone, business address, country in which you do business, your industry, job title or role

 

• Account information, for example, username and password. 

 

• Whether the visitor wishes to receive information and, if so what kind of information

 

 

 

A50 Real Assets Group may also collect information about you from third parties, in particular:

 

• Your social media interactions with us (for example, when you “like” a post on social media platforms) 

 

• Technical information from advertisements we place on third party websites (such as your IP address, browser type and version, device identifiers, location and time zone setting)

 

 

4. How We Use Your Information

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The information for which information will be used will vary depending on the nature of your relationship with A50 Real Assets Group. We intend to use your information (including any third party information provided by you) for any or all of the following purposes: 

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• The processing of an application for an account with A50 Real Assets Group including confirming and verifying your identity 

 

• Assessing your status as a “Professional Investor” as defined in the Securities and Futures Ordinance  (Cap.571 of Hong Kong Laws)

 

• Any purpose related to the administration of the services offered by A50 Real Assets Group

 

• Researching, designing and launching financial, investment services or related products for clients

 

• Complying with the disclosure, reporting and compliance requirements (including but not limited to tax reporting) under Hong Kong laws or regulations, codes, guidelines.

 

• Direct Marketing. We may not use your personal information for direct marketing unless we received your consent (which includes an indication of no objection to the intended use). If you elected to opt-in to our direct marketing list but later decided that you do not want us to use this information to have any further contact with you, we will respect your wishes. 

 

• Newsletters and Marketing Purposes. we may send e-mails and marketing communications to the email address provided to us while registering on our Site or requesting information from us. If you elected to opt-in to any of our email lists, newsletters or other promotional offerings and later decide that you no longer wish to receive such newsletters or promotional e-mail from us, you may unsubscribe by following the instructions contained in each email we send to you.

 

• Customer Relationship Management. We may provide you with services you requested and manage our relationship by using your client relationship data (for example, collected via a business card with an A50 Real Assets Group employee or when you communicate with A50 Real Assets Group employee via phone or email). We may also use de-identified and aggregated data about our clients for our internal data analytics purposes. With your consent, we may send you information or services or a promotional nature that we consider may be relevant to you. 

 

 

5. Third Parties with Whom We Share Your Personal Information

 

We may share your personal data with our affiliates and subsidiaries. Depending on the nature of our relationship with you, we may also share personal data with service providers who perform services on our behalf, our financial and transaction counterparties, our professional advisors, and your agents and representatives, subject to your consent. We do not authorize these persons to use or disclose the information except as necessary for the purposes for which it is provided or to comply with legal requirements. 

 

We may also disclose information about you, 

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• If we are required to do so by law or legal process

 

• To law enforcement authorities, regulators and/ or other government entities and/ or other competent authorities based on a lawful disclosure request

 

• When we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity

 

We reserve the right to transfer personal data we have about you in the event that we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, spin-off, dissolution or liquidation)

 

Anonymous or aggregated information may also be shared with third parties such as service providers to facilitate our business operation. 

 

 

 

6. Retention and Access

 

The information collected may be maintained for such period of time required under Hong Kong Laws and as otherwise needed to fulfill the purposes set out above. A50 Real Assets Group will take all reasonable measures to ensure the information is kept secure against unauthorized access, loss, disclosure and destruction. 

 

Under the Ordinance, you have the right to:

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• Check whether A50 Real Assets Group holds information about you, and access to such information

 

• Require A50 Real Assets Group to correct any information relating to you which is inaccurate

 

• Ascertain A50 Real Assets Group’s policies and practices in relation to data and to be informed of the kinds of information held by A50 Real Assets Group. 

 

• Object to the use of your information for direct marketing purposes and A50 Real Assets Group will cease any use of your information for direct marking purposes after your communication of objection to A50 Real Assets Group. 

 

In accordance with the terms of the Ordinance, A50 Real Asset Group has the right to charge a reasonable fee for the process of any information request.