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Privacy Policy

Seagrand Capital (hereinafter referred to as "we," "us," or "our") is committed to protecting your privacy. This policy explains how we collect, use, and protect your personal data when you visit our website. Please read this Privacy Policy carefully to understand how we handle your personal data. By using this website, you agree to the practices described in this policy. In accordance with Chapter 486 of the Personal Data (Privacy) Ordinance of Hong Kong (hereinafter referred to as "PDPO") and other applicable laws, your use of this website constitutes your consent to our processing of your personal data when required by law. As the data controller, we will ensure that your personal data is processed in accordance with the principles of fairness, transparency, and security, and for the specific, explicit, and lawful purposes described below.

Collection of Personal Data

You can browse our website without providing any personal data. However, when you contact us or request specific services, we may ask you to provide certain personal information. This information may include your name, email address, telephone number, organization name, etc., or any other information you voluntarily provide through forms, emails, or other means. If you choose not to provide the requested information, we may be unable to respond to your inquiries or provide the services you require. When you browse our website, we may collect information about your device, such as your IP address, operating system, and browser type. This data helps us manage website performance and improve functionality. While this information has the potential to identify you, we will not use it for this purpose unless permitted by law. We will maintain control over your personal data and ensure it is used solely for its intended purposes. Except where disclosure is required by law, your data will always be securely stored by us or third-party service providers acting on our behalf.

How We Use Your Personal Data

We may use the personal data you provide for the following purposes:

• Responding to your inquiries or requests;
• Processing job or internship applications;
• Handling complaints and follow-up actions;
• Processing administrative or operational matters related to your requests, including communication in investor relations management and owner representative services;
• Seeking feedback on our services or activities;
• Complying with legal obligations, including but not limited to compliance requirements such as anti-money laundering (AML), counter-terrorist financing (CTF), and KYC;
• Contacting you based on the information provided, particularly regarding issues such as inappropriate or harmful content that may violate laws or terms of service.

In general, we use the personal data collected through this website for lawful purposes. We intend to use your name and contact information to send you information regarding asset management, market insights, strategic consulting, industry research reports, or our events. As required by the PDPO, we will not use your personal data for this purpose unless we have obtained your explicit consent (or an indication of no objection). If you subscribe to information via forms on this website and voluntarily check the consent box, it indicates your agreement to our use of your data in this manner. You have the right to request, free of charge, to stop receiving such direct marketing materials at any time by using the contact information provided below. Where required by law, we may obtain your consent before using your data for specific purposes.

Location of Your Data

Our website is hosted in Hong Kong, and your personal data may be transferred to, stored, or processed in regions outside of Hong Kong. Prior to any transfer, we will obtain your explicit consent or confirm that the recipient has adopted protection mechanisms that comply with PDPO requirements, and we will inform you of the general data protection framework of the recipient's country/region. The level of data protection in some countries/regions may not be equivalent to that of Hong Kong or other jurisdictions with stricter data protection laws. However, we will take appropriate measures to ensure that your personal data is handled securely and in compliance with this Privacy Policy, and that any data transfer complies with applicable legal requirements.

Disclosure of Information

We may share your personal data with third parties under the following circumstances:

• 1、Legal Requirements – When required by law, including responding to requests from public authorities.
• 2、Service Providers – We partner with third-party service providers or agents who support the operation of our website or assist us in managing our business. We ensure that these partners implement appropriate security measures to protect your data.
• 3、Affiliated Entities – In order to provide you with more comprehensive asset management or consulting services, we may share necessary information among affiliated companies within Seagrand Capital.

We will not sell or rent your personal data to any third party for their marketing purposes.

Data Security

We retain control over your personal data. If we outsource personal data processing to third-party service providers, we will monitor their compliance with the security and confidentiality requirements of the PDPO through contractual or other necessary means. At the same time, we will take reasonable measures to protect the personal data you provide to us from loss, misuse, or unauthorized access. We will regularly evaluate the effectiveness of our security measures to guard against unauthorized access, disclosure, or destruction. However, no method of data transmission over the Internet or system of storage is absolutely secure; please be aware of the associated risks when providing your information. Therefore, we cannot guarantee the absolute security of your personal data, and you provide your data at your own risk. In the event of a data breach, we will notify you and the relevant regulatory authorities in a timely manner as required by applicable laws.

Data Retention

We will retain your personal data for the period necessary to fulfill the purposes for which it was collected or as required by applicable laws.

Your Rights

Under Chapter 486 of the Hong Kong PDPO, you have the right to:

• Request access to the personal data we hold about you;
• Request correction of inaccurate or outdated personal data;
• Request that we cease using your data for direct marketing purposes;
• Withdraw your consent to the processing of your personal data (where consent serves as the legal basis for processing).

If you are subject to certain data protection regulations (such as the General Data Protection Regulation (GDPR)), you may also possess additional rights, such as the right to object to our processing of your personal data, request the deletion of your data, or request that we restrict the manner of processing. In accordance with the PDPO, you have the right to request access to and correction of your personal data held by us. We reserve the right to charge a reasonable administrative fee for processing such data access requests.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. If the changes have a material impact, we will notify you through appropriate means, such as announcements on our website or via email. Any changes will be posted on this page. Please check this page frequently to stay informed of any updates or changes to our Privacy Policy.

Contact Us

If you have any questions or concerns regarding this Privacy Policy or our practices in handling your personal data, please contact us using the information below.

• Phone Number: 070-4068-6645
• Email: contact@seagrandcapital.com