Thank you for visiting the website of SINO-CEEF Capital Management Company Limited (“SINO-CEEF”). By accessing our website, you (a) agree to abide by and (b) acknowledge that you understand the following terms, conditions and legal notices. If you do not accept these legal conditions, please do not use the website. SINO-CEEF may change these terms, conditions and legal notices at any time, and your continued use of the site after any such modifications shall constitute your acceptance of any amended legal notices and terms of use.

No advice or offer

This website is strictly for information purposes only. Under no circumstances should this website or information on it be understood to constitute or form part of any advertisement, advice or recommendation, or offer to issue or sell, or any solicitation of any offer to subscribe or purchase, any investment, nor shall it or the fact of its communication form the basis of, or be relied on in connection with, any contract therefor. The information contained on this website is for background purposes only, does not purport to be full or complete, and does not constitute investment advice, arranging deals in investments or making arrangements with a view to transactions in investments. If you require tax, legal, accounting, or investment advice, you must consult with your own advisors as pertains to your individual circumstances and needs.

Ownership and Restrictions on Use

All content included on this website, such as graphics, logos, articles and other materials, is the property of SINO-CEEF and is protected by copyright and other laws. All trademarks and logos displayed on this website are the property of SINO-CEEF or, as applicable, their respective owners (who may or may not be affiliated with SINO-CEEF).

The prior permission of SINO-CEEF is required for (i) any commercial use of materials on this website; (ii) making more than minimal copies of website materials; and (iii) copying large portions of our site, such as by bots, robots or spyders that “harvest” the website. Should you wish to seek permission for such use of our website, please contact us at webmaster at sinoceef.com. Otherwise, SINO-CEEF permits copying and printing individual website pages solely for non-commercial purposes. Any unauthorized use of images or information on this website may violate copyright laws, trademark laws, the laws of privacy and publicity, and communications regulations and statutes.

By using this website you warrant that you are not in violation of any applicable local or international law, statute, regulation, code or ordinance, including, without limitation, rules and regulations adopted by any national or other securities regulator or exchange. Your permission and license to use this site under these terms, conditions and legal notices will automatically terminate if you breach any of these terms, conditions and legal notices.

We suggest including a data protection provision:

Data Protection

You acknowledge and agree that SINO-CEEF may process personal data that has become available to SINO-CEEF in the process of you using this Site in accordance with SINO-CEEF's personal data privacy policy. Such data procession may include, among other things, the transfer of personal data to countries which may not have data protection laws equivalent to those in Hong Kong.

Linking and Framing

SINO-CEEF does not allow any third party to link to or frame this website or any portion thereof. Moreover, SINO-CEEF does not review or monitor any websites linked from or to this website and is not responsible for the content of any such websites, their terms of use or privacy policies. You are responsible for reviewing the terms of use and privacy policies of any website that you visit. SINO-CEEF disclaims responsibility for the policies and practices of any third-party websites linked from this website.

Submissions

Please note that any information or communication which you send through this website will not be deemed confidential, and SINO-CEEF will own and have the right to use, modify, reproduce and distribute such information or communication in our sole discretion without compensation to you.

Limitation of Liability

SINO-CEEF and its respective officers, directors, managers, partners, members, shareholders, employees, affiliates and agents are not responsible for any damage, loss, cost or other injury, including but not limited to special or consequential damages, that result from your use of (or inability to use) this website. This limitation of liability includes any damage, loss, cost or other injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction. This website and all information on it are provided on an “as is” basis with no warranties of any kind. Your use of this website and use or reliance upon any of the materials on it is solely at your own risk.

Disclaimers

If and to the extent provided, any performance information or commentary expressed on this website are solely an indication of past performance. Past performance is not indicative of future results. SINO-CEEF makes no representation that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.

This website may contain forward-looking statements concerning future financial and/or business performance. These statements represent the beliefs of SINO-CEEF concerning future operations, strategies, financial results or other developments, and contain words such as “may,” “should,” “believe,” “expect,” “potential,” “continue,” “seek,” “approximately,” “predict,” “intend,” “will,” “plan,” “estimate,” “anticipate” or other similar terms. As such forward-looking statements are based on assumptions that are subject to significant business, economic and competitive uncertainties, many of which are beyond the control of SINO-CEEF and/or are subject to change, actual results could be materially different. SINO-CEEF undertakes no obligation to publicly update or review any forward-looking statement, whether as a result of new information, future developments or otherwise.

Governing Law

These terms and any dispute or claim arising out of or in connection with them or their subject matter will be governed by and construed in accordance with Hong Kong law. The courts of Hong Kong will have exclusive jurisdiction to settle any dispute or claim that arises out of or in connection with these terms or their subject matter, save that SINO-CEEF may enforce its rights in the courts of any jurisdiction having competence to issue an injunction directly enforceable against you.

Privacy Notice （EU）

1. Purpose of this notice

SINO-CEEF Capital Management Company Limited, including its affiliates (together "SINO-CEEF",“We”or “us”), respects your concerns about privacy and is committed to protecting your personal information. This notice aims to give you information about how SINO-CEEF collects and processes your personal data. It is important that you read this notice together with any other notices we may provide on specific occasions when we are collecting or processing your personal data, so that you are fully aware of how and why we are using your personal data. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. "Personal Data" has the meaning given in the European General Data Protection Regulation (GDPR) and includes any information relating to an identifiable individual (such as name, address, date of birth or economic information).

2. The personal data we collect about you

When we use the term “Personal Data” we mean information that reasonably can be used to identify you as an individual person. In connection with our business, we collect various types of Personal Data, including, among other things:

• identification information (e.g., name, ID card and passport numbers, nationality, place and date of birth, gender, picture, IP address);
• contact information (e.g., postal address and e-mail address, phone number);
• financial data (e.g., bank account details, credit card number, money transfers including communications on bank transfers, assets, investor   profile, credit history, debts and expenses) ;
• family situation (e.g., marital status, number of children);
• tax status (e.g., tax ID, tax residence);
• education and employment information (e.g., level of education, employment, employer’s name, remuneration);
• Professional Information: including your job title, email address, phone number and addresses;
• Professional History: including your previous positions and professional experience;  
• Special Categories of Personal Data: including personal data listed above, which we process in limited circumstances, for example, where required to do so for legal or regulatory purposes or where you have provided us with such information as it is necessary for a specific service we are providing to you. We will process this personal data for the following reasons:

(i) for legal and regulatory purposes, for example, we may need to verify whether you are a politically exposed person; or

(ii) we may ask you for your dietary requirements if we are arranging catering for you.

• other background data (e.g. information on criminal history/unlawful conduct)

We collect this Personal Data in various ways, including:

Directly from the Data Subject (e.g., when you voluntarily submit information to the website, or send us an email or other written correspondence)

Indirectly from other sources (e.g., from public records or from a counterparty in possession of the data).

3. How we use your personal data

We may use the information described above for the following purposes to:

• operate, evaluate and improve our business (including managing our communications; and performing accounting, auditing and other internal functions);
• comply with and enforce applicable legal requirements, relevant industry standards and our policies;
• protect against, identify and prevent fraud and other unlawful activity;
• in some cases, in order to operate, administer and improve the user's experience of the website;
• send you promotional materials, newsletters and other communications;
• communicate with you about, and administer your participation in, special events, programs, promotions, offers, surveys and market research;
• respond to your inquiries;
• manage your employment application, assess your qualifications and manage your employment with us;
• verify your information; and
• perform data analyses (including market and consumer research, demographic analyses and anonymization and aggregation of information).

We may have to share your personal data with the entities and persons set out below for the purposes for which we collected the personal data.

Within SINO-CEEF. We share your Personal Data among SINO-CEEF entities and their representatives for the purposes set forth above. In general, our group entities and their representatives, in turn, are not permitted to share your information with other non-affiliates entities, except as described herein or otherwise permitted by applicable laws.

To Third Parties. We share your Personal Data with third parties in certain circumstances, including the following:

• Service providers. We share Personal Data with service providers that perform services to us or represent us (e.g., third-party service providers to operate the website). These companies may have access to your Personal Data but are permitted to use the information solely to provide the specific service or as otherwise permitted by law. We generally require these providers by contract to keep the information confidential.
• Transaction or other corporate event. Your Personal Data can be disclosed as part of a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could be transferred to a third party as one of the business assets in such a transaction. It also can be disclosed in the event of insolvency, bankruptcy or receivership. In such an event, we will post prominent notice of the change in ownership.
• As required by law. We also disclose your Personal Data if we are required to make disclosures by applicable law or to the government or private parties in connection with a lawsuit, subpoena, investigation or similar proceeding, or as part of our legislative or regulatory reporting requirements.
• Consent and explicit consent. Where you have provided your consent or explicit consent to processing your personal data.

We may transfer the Personal Data we collect about you to recipients in countries other than the country in which the information originally was collected. Where you are based in the UK (after it has left the EU) or the EU, this includes transfers outside of the UK and the European Economic Area ("EEA"). Those countries may not have the same data protection laws as the country in which you initially provided the information. Where we transfer Personal Data outside of the UK or the EEA to other members of the SINO-CEEF group or our service providers, we will ensure that our arrangements with them are governed by data transfer agreements, designed to ensure that your Personal Data is protected (including, where appropriate, under an agreement on terms approved for this purpose by the European Commission).

4. Lawful basis for processing your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances (each a lawful basis):

• where we need to perform the contract we are about to enter into or have entered into with you;
• where it is necessary for our legitimate interests (as further explained in the relevant section applicable to you above) and your interests and fundamental rights do not override those interests; or
• where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data.

5. How we secure your personal data

We maintain administrative, technical and physical safeguards designed to protect Personal Data we obtain through the website against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

6. Retention of your personal data

We intend to keep your Personal Data accurate and up-to-date. We keep your personal data for as long as it is required by us for our legitimate business purposes, to perform our contractual obligations and as is required by law or regulatory obligations which apply to us.

We will delete the information that we hold about you when we no longer need it.

Note that we may retain some limited information about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.

7. Your rights and complaints

We offer you certain choices in connection with the Personal Data we collect from you. To update your preferences or submit a request, please contact us as indicated in the "How to Contact Us" section of this Privacy Notice. To the extent provided by the law of your jurisdiction, you may request access to the Personal Data we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your Personal Data, and we will apply your preferences going forward. You can also lodge a complaint about our processing of your Personal Data with the body regulating data protection in your country.

Your specific rights where you are a user in the UK or the EU are as follows:

Rights of access, correction and deletion. You have a right of access to the Personal Data that we hold about you under European data protection legislation, and to some related information, including the purpose for processing the Personal Data, the recipients of that Personal Data to the extent it has been transferred internationally, and, where the Personal Data has not been collated directly from you, the source. You can also require any inaccurate Personal Data to be corrected or deleted.

Right to object. You can object to our use of your Personal Data at any time and you may have the right to object to our processing of some or all of your Personal Data (and require them to be deleted) in some other circumstances.

If you wish to exercise any of these rights, please Contact us as set out below.

Complaints. SINO-CEEF takes very seriously any complaints we receive about our use of your Personal Data. Questions, comments, requests or complaints regarding the Site, this Privacy Notice, the User Agreement and/or our use of your Personal Data should be addressed to dataprotection@sinoceef.com.

Any Personal Data we receive from you when making a complaint will be treated in accordance with this Privacy Notice and only to process the complaint and check on the level of service we provide. Similarly, where inquiries are submitted to us we will only use the information supplied to us to deal with the inquiry and any subsequent issues and to check on the level of service we provide.

8. How to contact us

If you have any questions or comments about this Privacy Notice, or if you would like us to update information we have about you or your preferences, please email us at dataprotection@sinoceef.com.