Privacy Policy

In this Policy, "personal data" has the meaning given to it under the Personal Data (Privacy) Ordinance and refers to any data that can directly or indirectly identify an individual, including but not limited to: (a) name; (b) contact information; (c) identity document information; (d) financial information; (e) investment preferences and risk tolerance; (f) device information; (g) IP address; (h) Cookie data; (i) account information; (j) AI interaction data; and (k) other data held by the Company from time to time.

The Company may collect personal data through the following methods:

(a) when you submit forms, enquiries, applications or registrations;

(b) when you use this website, digital platforms, AI features or other services;

(c) when you communicate with the Company by phone, email, instant messaging, social media or other channels;

(d) through Cookies, web beacons, pixel tags or other technologies;

(e) from third-party service providers, partners, regulators or public sources; and

(f) from information obtained under applicable legal, regulatory or compliance requirements.

The Company may use personal data for the following purposes, including but not limited to:

(a) providing, maintaining, managing, improving or developing products and services;

(b) providing fund distribution services, digital platform services, AI services, research services or other financial technology services;

(c) verifying identity and conducting KYC, CDD, AML/CFT or sanctions screening procedures;

(d) fulfilling legal, regulatory, risk management, internal control and compliance obligations;

(e) handling enquiries, applications, complaints or customer support;

(f) improving websites, systems, AI models, product features or user experience;

(g) website analytics, data analytics, technical optimisation and information security management;

(h) preventing fraud, unauthorised use, cyberattacks or other illegal activities;

(i) communicating with you;

(j) conducting marketing after obtaining consent; and

(k) other purposes related or incidental to any of the above.

Some products or services of the Company may involve artificial intelligence models, automated tools, algorithms or related technologies.

You acknowledge and agree that the Company may collect, use and analyse technical data, interaction data or usage patterns relating to AI features or digital platform usage in order to: (a) improve AI models and system performance; (b) enhance product features; (c) improve service quality; (d) support risk management and information security; and (e) fulfil legal and regulatory obligations.

Except where otherwise required by applicable law, the Company will take reasonable measures to avoid making decisions through AI features that are fully automated and have a significant legal effect on you.

The Company may disclose, transfer or provide personal data to the following persons:

(a) any subsidiary, holding company, affiliate or associated company of the Company;

(b) directors, officers, employees, representatives, agents or advisers of the Company;

(c) third-party service providers providing cloud, information technology, data processing, payment, analytics, security, administrative, professional advisory or other support services;

(d) partners assisting the Company in providing products or services;

(e) regulators, courts, law enforcement agencies, government authorities or persons in Hong Kong or overseas who are legally entitled to request data;

(f) any actual or proposed assignee, transferee or participant of the Company; and

(g) persons to whom data must be disclosed under applicable laws, regulations, regulatory requirements, court orders or other legal proceedings.

You acknowledge and agree that the Company may transfer personal data outside Hong Kong for processing, storage, backup, analysis, technical support or other purposes.

The personal data protection laws of those jurisdictions may not be the same as those in Hong Kong.

The Company will take reasonable measures to protect the security of personal data.

The Company retains personal data only for a reasonably necessary period, including: (a) the period required to provide services; (b) the period required by legal, regulatory or compliance obligations; (c) the period required for handling disputes, risk management or enforcement needs; and (d) any reasonable period related to any of the above purposes.

The Company will adopt reasonable technical and administrative measures to protect personal data, including but not limited to: (a) access controls; (b) encryption technologies; (c) identity authentication; (d) system monitoring; (e) cybersecurity measures; and (f) data security management procedures.

However, internet transmission and electronic storage are not completely secure, and the Company does not guarantee absolute security of data transmission or storage.

This website may contain links to third-party websites or platforms.

The Company does not control the content, privacy policies or data handling practices of such third-party websites and is not responsible for them.

You should read the relevant third-party policies independently.

Under the Personal Data (Privacy) Ordinance, you have the right to: (a) enquire whether the Company holds your personal data; (b) request access to personal data; (c) request correction of inaccurate data; (d) request that direct marketing cease; and (e) exercise other statutory rights to the extent permitted by applicable law.

The Company may charge a reasonable administrative fee in accordance with law.

The Company may amend this Policy from time to time without prior notice.

The revised version will take effect when published on this website.

Your continued use of this website constitutes acceptance of the revised Policy.

If you have any questions about this Policy or wish to exercise related rights, please contact:

Fundamental Technology (Hongkong) Co., Limited

Address: Unit 2962, 29th Floor, Infinitus Plaza, 199 Des Voeux Road Central, Sheung Wan, Hong Kong

Email: privacy@fundamental.com.hk

Tel: +852-66415338

This Policy may be available in Chinese and English versions. In the event of any inconsistency between the Chinese and English versions, the Chinese version shall prevail.