Privacy Policy

This Privacy Policy (the “Policy”) describes how GCI Asset Management, HK Limited (“GCI”) collects, uses and shares the information you provide to us and the information we collect in the course of operating our business and our website.

In this Policy, when we refer to GCI or “we”/“us”/“our” we mean GCI Asset Management and its affiliates. We are incorporated under the laws of Hong Kong with company registration number 2664408 and our registered office is at 6/F Alexandra House, 18 Chater Road, Central, Hong Kong. Further, in this policy “investor” shall mean current professional investors (as defined under the Securities and Futures Ordinance Cap 571 of the laws of Hong Kong) of GCI funds and accounts, together with potential professional investors for such products.

We may revise this Policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are binding on you.

This Policy describes:

The information that we collect
How we use the information we collect
How we share the information with third parties
Keeping your information and information security
Your choices and rights
How to contact us and other important information

The information that we collect and where we get it from “Personal information” is any information that can be used to identify you or that we can link to you and which we have in our possession or control – i.e., data we collect from you, the way in which it is collected and the purposes for which it is collected and used. Information that you provide to us We will process personal information that you give to us including when you email us or contact us through various channels as follows:

Signing up for investor services: when you sign up for newsletters, calls, events or obtain other investor services from us or when you contact us with queries or respond to our communications, the personal information you provide may include your full name, job title, telephone number, email address and content, date and time of your correspondence and information about your firm or your business.
In connection with our provision of investor services: if you are an investor in a GCI fund or account, you will provide us with personal information when you or the firm you represent becomes an investor. If you are not an investor, we may collect or receive your personal information because you are involved in a fund or related marketing initiatives.

Information we otherwise collect about you We will also collect information about when you use our services or when we otherwise interact or correspond with you. We use various technologies to collect and store information when you visit our website. [We may, for example, collect information about the type of device you use to access the website, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our website, the web pages and the search terms you enter on our website.]

Information we obtain from other sources

If we collect or receive your personal information in the context of our provision of investor services, we might receive information from third parties such as your firm, other parties relevant to the services we are providing (e.g., a colleague might request sign-up for you for an event or web access) and others such as regulators and authorities. That information could include your name, contact details, employment details and other information relevant to the services that we are providing to our investors.

How we use the information we collect We may use your personal information for the following purposes:

to provide services to the relevant investor
to engage in activity in relation to our investor services. This may include sending you newsletters, updates, event invitations and other information that may be of interest to you
to comply with legal or regulatory obligations that we must discharge
to establish, exercise or defend our legal rights, or for the purposes of legal proceedings
[log your use of our website or our other online services for our own legitimate business purposes, which may include the analysis of usage, measurement of site performance, generation of reports,]
to look into any complaints or queries you may have
to prevent and respond to actual or potential fraud or illegal activities, and
[to collate, process and share any statistics based on an aggregation of information held by us, provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.]

Grounds for using your personal information We rely on the following legal grounds to process your personal information, namely:

Performance of a contract – we may need to collect and use your personal information to enter into a contract with you or to perform our obligations under a contract with you or your business.
Legitimate interests – we may use your personal information for our legitimate interests, some examples of which are given above.
Compliance with law or regulation – we may use your personal information as necessary to comply with applicable laws/regulations.
Consent -You may withdraw your consent for the use of your personal information by contacting us (see below).

How we share information with third parties We may share your personal information outside GCI. This may include:

Third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your personal information for the purposes described in this Policy. This may include, but is not limited to, IT and communications service providers.
Third parties relevant to the services that we provide. This may include, but is not limited to, fund administrators and custodians, other professional service providers, counterparties to litigation, regulators, authorities and governmental institutions.

Opt-Out Provisions It is not a policy of GCI to share non-public personal and financial information with affiliated or unaffiliated third parties except under the circumstances noted above. Since sharing under the circumstances noted above is necessary to service customer accounts or is mandated by law, there are no allowances made for investors to opt out.

Protecting your data outside Hong Kong The data that we collect from you may be held within, or transferred to, third-party data processors in countries that are outside Hong Kong, such as Japan or otherwise within Asia. If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside Hong Kong. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts, please contact us through our contact details below.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Policy.

Keeping your information and information security How long we hold your personal information for will vary and will depend principally on:

the purpose for which we are using your personal information – we will need to keep the information for as long as is necessary for the relevant purpose, and
legal obligations – laws or regulations may set a minimum period for which we have to keep your personal information.

We will ensure that the personal information that we hold is subject to appropriate security measures.

Your choices and rights You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.

These rights include:

Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you.
Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to the relevant investor and as authorised by that investor.
Requesting that we correct your personal information if it is inaccurate or incomplete.
Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally required or entitled to retain it.
Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request.
In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit such information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us.
Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so.
Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us.
We can, on request, tell you which data protection authority is relevant to the processing of your personal information.

How to contact us and other important information If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please contact us. You can do this by writing to us at ir@gciam.com

Website Terms of Use

You must read the following information before proceeding. By accessing this website (“Site“) and any pages thereof, you acknowledge that you have read the following information and accept the terms and conditions set out below and agree to be bound by such terms and conditions. If you do not agree to such terms and conditions, please do not access this Site and any pages thereof.

General

This Site has been prepared by GCI Asset Management, HK Limited (“GCI“) and is for information purposes only. The information on this Site is only intended for Hong Kong residents who are professional investors (as defined under the Securities and Futures Ordinance Cap 571) and is for reference only.

By accessing the Site, you have agreed to be bound by GCI’s (i) disclaimer; and (ii) Privacy Policy.

GCI reserves the right to grant or revoke your permission to access the Site in its absolute discretion. Whilst every reasonable precaution has been taken to ensure the accuracy, completeness, security and confidentiality of information available through the Site, GCI makes no warranty as to the accuracy, completeness, security and confidentiality of such information. GCI, its affiliates, directors, officers or employees accept no liability for any errors or omissions relating to information available through the Site. GCI cannot be held responsible for any consequences of any action carried out by any user authorized or unauthorized.

These Terms of Use are in addition to any other agreements between you and GCI, including any customer or account agreements, and any other agreement that governs your use of GCI products, services, content, tools and information available on this Site.

We reserve the right to change the Site and the Terms of Use at any time without notice. If you use the Site after the amended Terms of Use have been published, you will be deemed to have agreed to the Terms of Use, as amended.

Use of Website

By accessing the Site, including any password-protected are of this Site, you agree to immediately notify GCI in writing if there is any change in your status as a “professional investor”. All registered users, including individuals and entities, should communicate with their legal advisor if they believe that their status as a professional investor has changed. If a registered user’s status as a professional invest has changed, such registered user agrees to immediately notify GCI in writing of such change.

Confidentiality and Non-compete

By accessing the Site (including any password-protected are of the Site), you may receive non-public confidential information (the “Confidential Information“) relating to GCI, GCI funds or investment vehicles managed or advised by GCI (“GCI Funds“) and / or investments made, or to be made, by them (the “Investment“). By accessing the Site (including any password protected areas of the Site), you expressly agree:

to protect the Confidential Information and not disclose it to any third party (other than your director, officers and employees);
not to use the Confidential Information for any purpose other than to evaluate a potential investment in a GCI Fund; and
in respect of any Investment, not to directly or indirectly approach, negotiate with, or solicit any potential Investment (or any other investment or financing) from a Restricted Stakeholder for a period of 12 months following final receipt of any Confidential Information in relation to that Investment. For these purposes “Restricted Stakeholder” means, in relation to an Investment, any relevant buyer, seller, stakeholder, investor, shareholder, target, obligor or issuer (and / or their affiliates) under that Investment who is named or described in the Confidential Information.

Internet Communication

Messages sent over the Internet cannot be guaranteed to be completely secure. GCI will not be responsible for any damages incurred by you as a result of any delay, loss diversion, alteration or corruption of any message either sent to or received from GCI at your request, over the Internet. GCI is not responsible in any manner for direct, indirect, special or consequential damages arising out of the use of this Site.

Communication over the Internet may be subject to interruption, transmission blackout, delayed transmission due to Internet traffic or incorrect data transmission due to the public nature of the Internet or otherwise.

GCI does not represent or warrant that this Site will be available or that it will meet your requirements, that access will not be interrupted, that there will be no delays, failures, errors or omissions or loss of transmitted information, that no viruses or other contaminating or destructive properties will be transmitted or that no damage will occur to your computer system. You have sole responsibility for adequate protection and back up of data and / or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses or other destructive properties. GCI makes no representations or warranties regarding the accuracy, functionality or performance of any third party software or service providers that may be used in connection with the Site.

Intellectual Property

Copyright, trade marks, database rights, patents and all similar rights in this Site and the information contained in it are owned by GCI, its licensors or relevant third party content providers. You may use the information on this Site and reproduce it in hardcopy for your personal reference only. The information may not otherwise be reproduced, distributed or transmitted to any other person or incorporated in any way into another database, document or other material. Any copy of materials which you make from the Site must retain all copyright or other proprietary notices and disclaimers contained therein. Trade names referred to in this Site are trade marks owned by or licensed to GCI or other content providers. Trade marks owned by GCI or providers of content on the Site are used to act as indications of source or origin of associated services. Nothing on this Site should be considered as grating any license or right under any trade mark of GCI or any third party, nor should you attempt to use, copy, adapt or attempt to register any similar trade mark or any trade mark or logos appearing on this Site or in the information herein.

Governing Law

These Terms of Use shall be governed by the laws of Hong Kong.

Disclaimer

Legal Info

Please read this information carefully before using this website (the "Site"). By clicking the 'I Accept' button below you agree that you have read and accepted these terms and conditions (the 'Agreement') and the restrictions governing the use of the Site. GCI Asset Management, HK Limited ("GCI") may suspend your use of this Site immediately if you do not comply with this Agreement. The Site is published by and is the property of GCI, a company incorporated in Hong Kong with Company Registration number 2664408. GCI’s registered office is at Unit 08 44/F Champion Tower, 3 Garden Road, Central, Hong Kong. This Site and any documents or information contained in it do not constitutes investment advice, or an offer or solicitation to sell, or a solicitation of an offer to buy an interest in any funds and investment vehicles managed by GCI, or any other investment product (nor shall any such shares or product be offered or sold to any person) in any jurisdiction in which an offer, solicitation, purchase or sale would be unlawful under the securities law of that jurisdiction. All information contained on the Site is provided on an "as is" basis, and GCI expressly disclaims any express or implied warranties with respect to the fitness of the information contained herein for any particular use, its merchantability or its application or purpose. GCI is licensed and regulated by the Securities & Futures Commission Hong Kong (“SFC”) to conduct Type 9 (asset management) activities. However, GCI is not registered with the US Securities & Exchange Commission ("SEC") as a registered investment adviser and does not comply with the Investment Advisers Act of 1940. The information on the Site has not been reviewed by the SFC or any regulatory authority in Hong Kong. The information you are about to access is available in Hong Kong to "professional investors" only, and only such persons are eligible to receive and / or act on the information herein. As defined in the Securities and Futures Ordinance (Cap 571, Laws of Hong Kong) and its subsidiary legislation, "professional investors" include the following: 1) exchange companies and other automated trading facilities; 2) licensed financial intermediaries, their wholly-owned subsidiaries and holding companies; 3) licensed banks, their wholly-owned subsidiaries and holding companies; 4) licensed insurers; 5) authorised retail funds; 6) Hong Kong mandatory provident fund schemes or a trustee or an investment manager of any such scheme; 7) any government or central banking authority; 8) an individual with a portfolio of investments valued at no less than HK$8,000,000; 9) an investment holding company wholly-owned by an individual referred to in the preceding category 10) a trust corporation with total assets of at least HK$40,000,000; and 11) a corporation or partnership having a portfolio valued no less than HK$8,000,000 or total assets of no less than HK$40,000,000. Any GCI funds and investment vehicles managed by GCI is available only to professional investors, and any Hong Kong resident accessing the Site hereby certifies that he / it is a 'professional investor' as described above. Persons who access this Site are required to inform themselves of and to comply with all applicable sales restrictions in their home country or legal jurisdiction to which they are subject. Access to this Site and any information on the Site is not directed at any person in any jurisdiction where it is prohibited to access the Site or receive such information for any reason. If you are a person in a jurisdiction in which such prohibitions apply you must not access this Site. If you are a person located in any jurisdiction where there are restrictions on the type of person who may access such information relating to unregulated funds then, by selecting 'I AGREE', you will be undertaking, warranting and representing to GCI, that you are not causing GCI to breach any of those restrictions by your access to this Site.

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