Privacy Policy

Personal Information

By entering into a business agreement or investing with or alongside MWD Capital Limited (collectively, “MWD”), you may be required to provide us with Personal Information about yourself, your legal and beneficial owners, your directors, officers, employees, and agents, which may be subject to applicable data protection laws and regulations. For the purposes of data protection laws and regulations, we are the data controllers or data users of your Personal Information.

This policy sets out the basis on which Personal Information will be processed by MWD. We ensure that Personal Information is collected, processed, and maintained in accordance with applicable laws and regulations. Please read the following carefully to understand our views and practices regarding Personal Information and how we treat it.

We maintain strict security standards, policies, and procedures for the prevention of unauthorized access to Personal Information. We require our directors, officers, employees, and third parties with whom we share Personal Information in connection with our services to observe and comply with this policy and applicable laws and regulations.

Personal Information Collection

In the course of our business relationship with you, we may collect and process Personal Information from you, other persons related to you, and/or third parties, relating to you, your accounts, investments, transactions, or fund transfers.

We may collect and maintain such Personal Information through physical or electronic means, from our website, during any account opening, customer or investor servicing, complaints handling process, or through other means. This includes, but is not limited to:

Name;

Phone number;

Email address;

Postal address;

Company name;

Country of residence;

Client relationship data (e.g., products held and services rendered);

Securities and payment transaction data and other financial information;

Information collected or generated to comply with our obligations under the anti-money laundering regulatory framework;

Information collected or generated for risk management purposes such as client due diligence data, client risk profiles, data to assess suitability/appropriateness, client qualifications data, screening alerts, tax data, or complaint information;

Marketing and sales information (e.g., newsletters, documents received, event participation, personal preferences and interests, opt-in and opt-out declarations);

Your comments/questions;

We may also collect Personal Information from you at trade shows/events, from telephone calls, and/or other correspondence with you.

Personal Information Use

We may collect, hold, use, disclose, and process your Personal Information for any of the following purposes, as applicable:

Ensuring the material on this website is presented to you in an effective manner;

Providing you with alerts, bulletins, newsletters, and other information you have requested or signed up to;

Taking steps to enter and entering into any business agreement between you and us;

Performing obligations under any business agreement between you and us;

Providing you with and improving our services;

Informing you about any investment opportunities with or alongside us, to the extent permitted by law and regulation and subject to your preferred mode(s) of contact;

Ensuring the protection of your vital interests;

Complying with any laws and regulations applicable to us;

For our or a third party’s legitimate interests where your interests do not override such legitimate interests;

In connection with any legal or regulatory proceedings or investigations;

Any other legitimate business purposes ancillary to the above or which you have specifically consented to.

Due to legal and regulatory obligations, you may be required to provide us with your Personal Information or the Personal Information of your legal and beneficial owners, directors, officers, employees, and agents. Failure to do so may prevent us from dealing or entering into a business agreement with you.

If you have given us consent to inform you of any investment opportunities and would like to withdraw such consent, please send us a written request at the contact mentioned at the end of this policy. If you are unsure if you have given such consent and would like to do so, please send us a written request with your explicit consent.

Where a right of objection is available under applicable laws and regulations, you have a right to object to us processing your Personal Information where such processing is done for our legitimate interests or direct marketing, as applicable.

Personal Information Disclosure and Transfer

Except as specified below, we do not disclose your Personal Information to any other person unless we have received your permission to do so. We may disclose and transfer Personal Information to any of our affiliates and third parties anywhere in the world:

If we consider it necessary for our business purposes, including to enter into a business agreement with you, to facilitate the review, acceptance, administration, and management of your investment, to perform our services, and, to the extent permitted under applicable laws and regulations, to provide marketing services on our behalf;

To comply with any law, regulation, judgment, order, requirement, guideline, code, standard, policy, circular, notice, or any other document of a similar nature issued by any legal, regulatory, statutory, listing, supervisory, law enforcement, prosecuting, tax, or any other authority or body of a similar nature in any jurisdiction;

Such third parties may include:

Our officers, directors, and employees;

Our banks, securities brokers, auditors, attorneys, and other service providers;

Our business partners and counterparties;

Persons to whom we are required to make disclosure under applicable laws and regulations;

Actual or prospective transferees or participants in our services.

Personal Information Retention

If we collect and process Personal Information in connection with preparing to enter into or entering into a business agreement with you, we will retain the Personal Information for as long as it is required to fulfill our contractual obligations to you and for such other period reflecting the legal statutory limitation period under applicable laws and regulations.

If we collect and process Personal Information in connection with a legal or regulatory obligation, we will retain the Personal Information for as long as it is required under applicable laws or regulations.

If we collect and process Personal Information with your consent, we will retain the Personal Information for as long as it is necessary and for a reasonable period after you ask us to stop doing so.

Personal Information – Other Persons

If you provide us with Personal Information relating to another person, or you authorize someone to do so, you agree to inform that person that you have provided such Personal Information to us and provide them with this policy. You should seek the consent of that person before providing their Personal Information to us. You agree to provide any further data protection information and/or obtain any consents from that person in relation to our use of such Personal Information as may be requested by us.

Your Rights in Relation to Personal Information

You may have a right to access your Personal Information held by us, a right to amend and/or rectify any inaccuracies in your Personal Information, a right to erase your Personal Information, a right to cease processing, or a right to obtain your Personal Information in a structured, commonly used, and machine-readable format. These rights can be exercised by writing to us with your request. You may also have the right to lodge a complaint with a national data protection authority. These rights are subject to availability, exceptions, and conditions under applicable laws and regulations.

If you wish to exercise your rights or have any queries on your Personal Information held by us, please send us a written request at the contact mentioned at the end of this policy.

Personal Information Security

We are committed to the safety and security of your Personal Information. We use a world-class cloud information storage system.

We employ appropriate physical, electronic, and procedural safeguards to ensure your Personal Information remains confidential and secure under our control or in our possession.

We restrict access to your Personal Information to relevant and required parties on a need-to-know basis for the purposes specified above.

Where required by applicable data protection laws, we will notify you of any data breach incidents.

Privacy Policy Changes

We may revise this policy at any time to comply with applicable data protection laws and regulations. In the event of any queries or requests in connection with this policy or data protection matters generally, please contact us.

Definitions

Personal Information means any information relating to your identity, or the identity of another person, which could be used to directly or indirectly identify you or such person. Such information includes, without limitation, names, addresses, dates of birth, identification numbers, telephone numbers, nationalities, tax residencies, assets, incomes, bank account details, details of regulatory registrations, details of legal and/or regulatory actions, and any other information by which you or such person may be personally identified.

‘Service’ means any advisory, asset management, and/or other service(s) provided by us to you.

‘We’ means MWD and any of its delegates and agents, and the phrases "us" and "our" have corresponding meanings.

‘You’ means any person accessing our website, including in its capacity as our actual or potential investor, customer, or user, and the phrase "your" has a corresponding meaning.

For further information or any queries regarding this policy, please contact us: info@mwdcapitalhk.com.