To better protect your personal data, we provide this notice explaining our online information practices. CSpro is committed to the full implementation and compliance with the six data protection principles and the requirements of the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) to safeguarding your personal data.
By visiting or accessing this Site, or by registering for our Site, or by using this Site or the Security Token Offering (“STO”) related services made available through the Site (“Services”), you thereby agree to this Policy. In providing investment opportunities to Professional Investors (“PI”), as defined by the Securities and Futures Ordinance (Cap. 571, Laws of Hong Kong), we will gather personal data from the prospective PI to assess both the PI’s suitability and risk profile. In providing STO opportunities to a STO issuer who has signed the relevant STO Distribution Agreement with CSpro (Hong Kong) Limited (“CSpro”), we will gather personal data from the CSpro’s shareholders, directors, officers, senior managers and employees to allow CSpro and potential investors to review, assess and conduct checks on the CSpro’s business. Save for those expressly provided in this Policy, we will not use this personal data for any other purpose nor disseminate this personal data to any third parties.
In connection with the Services, you will be signing additional agreements with CSpro or its affiliate(s) or other third parties. In the event of conflicts between the terms of such agreements and the terms of this Policy, the terms of this Policy will prevail insofar as it relates to CSpro’s commitments related to protection of your personal data collected through this Site.
The terms of this Policy have been drafted solely in accordance with the laws of Hong Kong and are therefore subject to Hong Kong law. We do not represent or warrant that this Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Policy as such.
Personal Information Collection Statement
CSpro will use, share, transfer and disclose such personal data for the purposes and in the manner described in this Policy.
Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. We respect your personal data. CSpro collects personal data you provide or upload through the Site. There are portions of our online Services where we may collect personal data for identification purposes, to fulfill your online requests, or where we believe it is reasonably required for provision of our Services. The information we collect varies based on our Services you choose to use through the Site.
Examples of personal data CSpro may collect include, without limitation, the following information:
- postal or email address;
- telephone, fax, mobile numbers;
- account number, username and password;
- residential or other correspondence addresses;
- identity card, passport and visa details;
- nationality or residency status;
- age and gender;
- details of your spouse, children or other beneficiaries (if any);
- education level and details (where applicable);
- employment information (where applicable);
- details of regulatory registration and disciplinary or court actions (if any);
- financial statements or reports and financial status, intention or goals (where applicable);
- income or assets information (where applicable);
- bank account details (where applicable);
- facebook ID and first name displayed in facebook;
- LinkedIn ID and related information;
- preferences related to any investment, products or services;
- communications between you and CSpro; and
- data regarding your visits to and use of the Site.
When you visit the Site or use our Services through the Site, we may automatically collect certain data which may, when combined with other information about you, be personal data, including but not limited to:
- attributes of the computer or other device you are using, such as the operating system, hardware version, device settings, software and device identifiers;
- computer or other device locations, including specific geographic locations identified through GPS, Bluetooth or WiFi signals or other means;
- connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
- the website from which you have reached the Site;
- the pages on our Site you viewed or visited, average time spent on these pages and when they were viewed or visited;
- details of the information and Services on the Site that you look at, information, tools and content available on the Site that you use; and
- links from the Site that you click on.
Upon performing the registration process, you will be asked to provide certain information (including but not limited to personal data), such as your first and last name, residence, Hong Kong identity card or passport and other identifying information, email address, gender and birthday, proof of address as well as a username and password and certain financial information. The username and password are used to ensure that no user other than yourself will have access to such information you have provided. You are solely responsible for maintaining the secrecy of any password you use to register, and you should always be careful whenever disclosing information online.
In addition, we receive and store any information you enter on our Site or give us in any other way (for example, in the course of subscribing for particular investments, otherwise using the Site or other communications with us (through the Site or any other social networks, or otherwise), or as contained in written documents you provide). This includes information that can identify you. The amount of personally identifying information you provide is up to you, and you are not legally obligated to provide such information. However, your use of the Site or the Services may be curtailed if certain of such information is not provided.
We may use third party contractors to collect and aggregate this information. For more information, please see Information Collected by Means of Technology below.
The Site and Services may only be used by individuals over the age of 18.
Use of Personal Data
Personal data collected will be used by CSpro, and its employees and consultants and may be transferred by CSpro to CSpro Affiliates and their respective service providers, legal advisers, BVI registered agents (where applicable), banks, accountants and auditors in connection with the operation and management of the Site and provision of the Services, or to any other users who are registered with us as “startup” or “professional investor” in accordance with your instructions, to enhance performance of the Site, to tailor the Site to users’ preferences, and to analyse trends, including, without limitation, as follows:
- To enable us to verify your credentials, in order to maintain reasonable security, provide developers with the information that is useful in developing new features and Services for our users, enable us to develop and improve the features, contents, and Services available, fulfil your requests for our products and Services, in connection with your use of the Site or Services, to respond to your inquiries about our Services, to offer you our products or Services that we believe may be of interest to you, to carry out transactions which you have requested, to enforce our rights and resolve disputes.
- We will retain information transmitted to us in the context of use of Services for further internal use in connection with our efforts to improve our Services and products.
- Newsletters: If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your personal data, we provide you a way to unsubscribe by following the unsubscribe link located at the bottom of each newsletter communication or by emailing us at [email protected].
- We may use non-personally identifying information that we collect to provide statistical information about users of the Site or Services, to improve the quality, design and content of our Site, to analyse the use of our Site and to cooperate with law enforcement.
We cannot use your personal data for marketing or offering our products or Services to you unless we have received your consent or indication of no objection to such marketing or offering.
We may provide your personal data to other third parties, such as advertisers or business partners within our Site. Where we provide such information to third parties, other than for use on our behalf, it will be provided either in aggregated form that does not identify your identity, or in a form that does not link the information to any PII. In other words, we will only provide to such third parties non-personally identifiable identification (for example, gender) in connection with an IP address.
We will not sell, share (other than sharing with CSpro Affiliates and third party service providers as described in this Policy), rent or trade your personal data or information with third parties unless we have your consent.
We may disclose or transfer your personal data or information to:
- Third-party vendors who provide services or products to us for operation of the Site or provision of our Services or facilitate or evaluate the Sites or Services, such as e-mail service providers sending emails on our behalf
- CSpro Affiliates that are involved in operating or providing the Services. We may share your personal data or information with CSpro Affiliates. CSpro Affiliates will follow practices that are at least as restrictive as the practices described in this Policy, including requests that personal data or information will only be used to provide you with Services.
- We may share aggregated or anonymous data with third parties for any use whatsoever without restriction.
We also may share or provide your personal data or information:
- In response to subpoenas, court orders, or other legal process or in response to a law enforcement agency’s request; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe appropriate to comply with applicable laws, regulations, orders, legal processes or government or regulatory requests, as well as in order to comply with anti-money laundering laws and regulations. In such cases we reserve the exclusive right to raise or waive any legal objection or right available to us.
- In the event that CSpro goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your PII will likely be among the assets transferred. You will be notified via email or prominent notice on our Site for 30 days (or such longer period as may be required by applicable law) before any such change in ownership or control of your personal information.
Other than as set out above, you will be notified when your personal data or information will be shared with third parties, and you will have an opportunity to choose not to have any of them shared.
By using our Site or Services, you consent to transfer PII to CSpro Affiliates or such third party vendors (as described in this Policy) outside your country but only for purposes of performing the Services for which you provided your PII, even to countries that might not offer a level of protection for your PII that is equivalent to the one offered in your country of residence. We will obtain your express consent, however, before using your PII for any purposes other than performing the Services for which you provided the PII.
Notifications & Direct Marketing
The Site sends new registered users a welcoming email to verify password and username. After you register with the Site, subject to your consent to direct marketing services, we may send you on a regular basis via emails information on other services or products (other than the updates on the Site or the Services) that we believe may be of interest to you. Out of respect for your personal data, we give you the option at all times to opt-out of these types of communications. By choosing not to opt out, you consent to these communications.
The Site may also send you notifications regarding updates to the Site and Services. We may also communicate with you to provide requested Services and with respect to issues relating to your account via email or phone. You will not be able to opt-out of service announcements that contain important information about the Service.
You may ‘opt-out’ of having your personal data or information used for any purpose not directly related to the Site upon registration to the Site. You may not opt out of administrative emails (for example, electronic delivery of financial information, or emails about your transactions or our policy changes). However, if you no longer wish to receive additional information or promotional materials from CSpro, you may opt-out of receiving these communications by sending an email with the word ‘unsubscribe’ in the subject line or otherwise sending a request to [email protected], or using the opt-out mechanism described in the relevant email.
Access & Correction of Personal Information
Under the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong), you have the right: (a) to check whether CSpro holds personal data about you and to access such data; and (b) to require CSpro to correct, amend or update your personal data. CSpro encourages you to review your information regularly to ensure that it is correct and complete. As a registered user, you can access to and correct, change or update your personal data or information by emailing us at [email protected]. In accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong), we have the right to charge a reasonable fee for the processing of any data access request.
We take appropriate precautions to protect users’ personal data or information by using physical as well as technological security devices. Additionally, we have implemented physical, electronic and procedural safeguards that are designed to protect the security of your personal data or information in compliance with Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong). These include advanced firewall and password protection for our databases, physical access controls to our buildings and files, and restricted access to your personal data or information to employees that need to know that data or information to provide, operate, maintain, develop or improve our Services. We have invested in leading-edge security software, systems and procedures to offer you a safe and secure investing Site and protect your personal, financial and investment information. While no security system is absolutely impenetrable, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available. CSpro’s employees are kept up-to-date on security and privacy practices. As the use of internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data or information which is transferred from you or to you via the internet. You should also be mindful that you are responsible for keeping your access rights confidential and secure at all times. If you have any questions about the security measures we use on the Site please contact us by sending an email to [email protected].
Personal data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law. We will retain your data or information for as long as your account is active or as needed to provide you Services or as required in accordance with applicable law.
CSpro shall cease to retain personal data/information or remove the means by which personal data/information can be associated with particular user, as soon as it is reasonable to assume that the purpose for which that personal data/information was collected is no longer valid and retention of such personal data/information is no longer necessary for legal or business purposes.
Notification of Changes
This Policy may change from time to time and we will post the amended terms on the CSpro Site and notify you by email of major changes. Amended terms will take effect immediately for new users, and 30 days (or such longer period as may be required by applicable law) after they are posted for existing users. You should review our Policy periodically to ensure that you have received the latest version and our updates. You agree to accept posting of a revised Policy as actual notice to you.
Your continued use of the Site after any changes to this Policy have been posted (or, if applicable, notified) signifies your acceptance of those changes.