Privacy Policy

Introduction

Beijing Caiyu Asset Management Enterprise (Limited partnership) (hereinafter, "Caiyu Asset" or "we") highly value your privacy and data security. We may collect and/or retain certain data when you accept our services through this website, or when you invest in the private funds that Caiyu Asset manages (hereinafter, "Caiyu Funds"). In this Privacy Policy (hereinafter, this "Policy"), we describe how we collect, process, disclose and protect your information.

This Policy does not apply to the services provided to you by other organizations. This website may contain links to other websites, and we cannot guarantee that the operators of such websites will take the protective measures as we require. Therefore, we suggest that you check the privacy policies of such websites from time to time to understand how they will handle your information in order to make prudent decisions.

By visiting or using this website, clicking "I agree" or other buttons that indicating the acceptance of this Policy, or otherwise providing data to this website, you acknowledge that you agree to the provisions in this Policy about how we process your information. Any disputes arising regarding your privacy in using this website shall be governed by this Policy and the Terms of Use of this website. If you do not understand or disagree with the contents of this Policy, you should immediately stop using this website and related services, and contact us via the contact information as set out in this website.

This Policy will help you understand the following content:

I.What personal data we collect?

II.How do we use your personal data?

III.To whom do we disclose your personal data?

IV.How do we retain and protect your personal data?

V.How do we protect minors?

VI.Marketing and your right to unsubscribe our marketing

VII.Your rights and complaints

VIII.How do we update this Policy?

IX.Notice on handling of IT incidents

X.Cookie

I.What personal data we collect?

Personal data is data relating to individuals, that is, the data related to the identified or identifiable persons recorded by electronic or other ways. Personal data does not include anonymized data. When you use this website, we need to collect some of your personal data to ensure the operation of relevant functions. If you choose not to provide such data, you may not be able to use some products or services, but it will not affect your use of other products and services of Caiyu Asset. The data you authorized Caiyu Asset to collect includes:

• According to the laws, regulations, rules, self-regulatory rules and other rules, when invest in Caiyu Funds, you need to provide and update your personal information in a timely manner, including but not limited to your name, ID number and type of certificate, validity and expiration period, deposit bank, bank account number, correspondence address, phone number, employer, email address, postal code, de facto controller of your account, actual beneficiary, any negative credit records, tax resident status, educational background, annual income, and source of income.
• When you use our online services, you need to provide us or allow us to collect necessary personal information, including your name, date of birth, ID number and certificate type, mobile phone number, and email address.
• You can provide to us by yourself or allow us to collect your other personal information. Such information is not necessary for us to provide you our services, but is of great significance for us to improve our services and develop new products or services. We do not mandatorily require such information, and your refusal of providing will not adversely affect your use of our services.
• If we collect your personal information or request system access beyond the scope of information as set out in this Policy, we will seek your prior consent.

II.How do we use your personal data?

The personal and other information we collect will be used for (i) the purposes/uses as specified in this Policy; (ii) the purpose/use directly related to the collection of such data; (iii) purposes/uses as stipulated by laws and rules; and (iv) business-related purposes/uses, including:

• Using your personal data to provide you the products and services related to this website, and to maintain and improve these products and services.
• Using your personal data under the relevant laws, regulations, departmental rules, self-regulatory rules and other rules to comply with anti-money laundering, investor appropriateness, and tax residence status identification and report rules.
• We highly value the security of your personal data, therefore, before we provide the online services to you, we may need you to provide your name, ID number and mobile phone number so that we can verify the consistency, among this three. If the afore-mentioned consistency verification is infeasible, we may need to verify your name, date of birth and email address with the information you provided when investing in Caiyu Funds.
• In order to complete the relevant identity verification procedures, we may store, process, use, analyze, query, check and/or verify your personal information on our own or through third parties. Such third parties include our affiliates, agents, service organizations, outsourcing agencies and other business cooperation organizations that we consider necessary.
• In order to facilitate your understanding of our services, we will send you necessary notice or other electronic message. If you do not want to receive such message, you may request us to stop sending such messages to you by unsubscribing through text messages or by following the instruction in the specific service or setting, this will not affect your use of our other services.
• In order to optimize your experience, provide better service, or mitigate security risk, we may consolidate, summarize, analyze and/or process your personal information. We may also use your personal information to maintain, improve, and/or develop our services.
• If we use your personal information for purposes beyond what’s described this Policy, or if we use your personal information beyond the scope as specified in this Policy, we will seek your prior consent.

III.To whom do we disclose your personal data?

For the purposes set out in the previous section, we may disclose your personal data to the following:

• Professional consultants, third-party service agencies, agents or independent contractors (such as IT system providers, platform providers, financial consultants, brokers, lawyers and accountants) who provide services to Caiyu Asset;
• Merchant or service providers, intermediaries, brokers and other individuals and entities we work with;
• Regulatory bodies (including any national or international regulatory or enforcement institutions, authorities, courts or other forms of tribunals or tax institutions) and its agents as stipulated in laws and regulations;
• Potential purchasers, acquirers, merger partners or sellers and their advisers in the process of the transfer, merger and acquisition of the business, assets or other equities of Caiyu Asset;
• Credit investigation agencies or other organizations that assist us in anti-money laundering or anti-terrorist investigations, and detection of fraud and other criminal activities;
• Entities allowed by relevant laws and regulations; and
• Other subjects you agreed to.

Apart from the above, we will not disclose your personal data to third parties for their marketing purposes.

IV.How do we retain and protect your personal data?

We collect, process and store your personal data in the People's Republic of China. If overseas business is involved, your personal data may be transferred overseas with your consent and the approval from relevant authorities (if applicable), and we will implement corresponding security measures as required by laws, regulations, and relevant requirement of authorities under such circumstances.

The duration of retaining your personal data will be limited to the length to meet the collection purposes and will be subject to the relevant requirements of this Policy and applicable laws and regulations.

As required by relevant laws and regulations, we will protect your personal data from loss, misuse, unauthorized access, leak, alteration, and destruction through physical and electronic methods and internal procedures. We cannot guarantee the absolute security of our protection measures. If you can login on the website, we suggest that you take reasonable protection measures, including logging out of your account after using a shared computer, choosing a password that is of high security level, not known by others and hard to guess, keeping your password properly and keeping it confidential, to protect your data security.

Caiyu Asset has established relevant data security policy and has assigned personnel to handle data protection matters. We also request third parties that process information on our behalf to comply with the appropriate security standards to protect the data from unauthorized accessing, destructing and losing.

V.How do we protect minors?

Our services are mainly aimed at adults. Minors who use our services should obtain prior consent from their parents or legal guardians.

When collecting personal information of minors with the consent of parents or legal guardians, we will only use or disclose such information as permitted by laws and regulations, with the explicit consent of parents or guardians, or as necessary for the protection of minors.

If we find that we have collected personal information of a minors without the prior consent of a parents or guardians, we will try to delete such data as soon as possible.

VI.Marketing and your right to unsubscribe our marketing

If there are any products or services that you may be interested in, we may contact you by text message, email, or phone call to the extent permitted by law. We will seek your prior consent before using your personal data for marketing purposes to the extent required by laws and regulations.

If you have notified us that you do not want to receive such marketing materials, we will no longer use your personal data for marketing purposes. You may request us to stop using your personal data for marketing purposes at any time by clicking the “Unsubscribe” link in the message or contacting us via contact information as set out in this website.

VII.Your rights and complaints

To the extent permitted by laws and regulations, you have the right to (i) request access to, review, copy, rectify, supplement or delete your personal information; (ii) limit our usage of your personal information; (iii) advise on the treatment of your personal information; (iv) request for the measures and rules of us dealing your personal information; (v) withdraw your authorization to the information usage subject to relevant laws, regulations and the Terms of Use of this website. If you wish to exercise your right, or you believe that our treatment of your information violates laws, regulations and regulatory requirements, please contact us. For security purpose, you may need to provide your valid identification to help us protect your rights. We will process your request in a timely manner as requested by laws.

We reserve the right to charge proper fees as permitted by laws and regulations if you require access to your personal data, and we will notify you of such charge in advance.

If you have any complaints about how we process your personal data, please contact us. We will process your complaint in a timely manner as requested by laws If you are not satisfied with our resolutions, you may escalate to the relevant authorities.

VIII.How do we update this Policy?

We may change or update the contents of this Policy as we see fit. Please review this Policy as published on this website from time to time to stay informed of any change or update. If the content of this Policy is changed, we will publish it on this website for your easy reference.

IX.Notice on handling IT incidents

We will do our best to ensure the normal operation of this website and the related systems. In case of service interruption caused by external causes such as communication line or equipment malfunction, hacker attack, virus invasion or force majeure, Caiyu Asset will open emergency service channel and provide manual service for funds business. You can contact us via contact information as set out in this website and submit the relevant business application under the assistance of our customer service personnel.

X.Cookie

Caiyu Asset can obtain your general Internet usage information through the use of Cookie documents stored on the hard drive of your computer for system administration and statistical analysis. Cookies contain information transmitted to the hard drive of your computer, and they can help Caiyu Asset improve the website and provide you with better services, including storing information about your preferences and identifying you when your return to this website.

You may refuse to accept cookies by enabling a setting on your browser; however, if you choose this setting, you may not be able to access certain parts of this website. Cookies may be offered by the system automatically when you login this website unless you adjust your browser settings to reject.