Privacy Policy

Updated: August 10, 2022

Privacy is a priority

The Crowder Securities Limited, also known as “Crowder Securities Limited,” “we,” and “us,” is the provider of this privacy notice. This Privacy Notice also applies to the affiliates of Crowder Securities Limited for administrative convenience only and not as a result of regulatory requirements, as the technology platform used by these entities operates on an integrated basis. This privacy notice broadly extends to all of our business interactions with people (sometimes referred to as “Data Subjects”), including but not limited to current Crowder Securities Limited personnel, as well as certain regions and legal systems.

The locations of authorized Crowder Securities Limited offices are listed on the Contact Us page. Please email us at info@crowdersl.com if you have any queries concerning the above or if you would want to alert us to any alleged unauthorized conduct with Crowder Securities Limited.

What information do we gather, and how?

Personal information. The term “Personal Data” refers to information that could be used to reasonably identify you as a specific individual. We gather many kinds of Personal Data in connection with our business, including, among other things:

• Identifiers such as your name, address, tax ID, passport number, email address, internet protocol address, account name, social security number, driver’s license number, mail address, phone number, or other comparable identifiers.
• Information identified by state, federal, or other applicable law as being personal or protected information, such as your nationality, birthplace and date, gender, photograph, marital status, number of children, and details of any past criminal activity.
• Business-related data, such as tax information, bank account information, credit card number, and information on money transfers, as well as information on assets, investor profiles, credit histories, debts, and expenses.
• Information on a user’s interactions with websites, apps, and advertisements on the internet or other electronic networks, including but not limited to browsing and search histories.
• Visual data, such as your photograph.
• Information pertaining to your career or employment, such as your job title, employer name, and compensation.
• Details about your schooling, such as your grade point average.

We gather this Personal Data in a variety of ways, such as:

• Directly from the Data Subject (for instance, when you freely send us an email, post information on the website, or otherwise communicate with us in writing).
• Indirectly from other sources (such as public records or a counterparty who has the data in their possession).

Tools for automatic collection. Additionally, when Data Subjects visit websites run by companies under the Crowder Securities Limited umbrella (each a “Site”), we automatically gather some information from them. To accomplish this, the appropriate group entity will utilize data gathering technologies (or “Cookies”) on its website to track usage statistics such as the volume and regularity of visits. The websites you visit immediately before and after visiting the Site, as well as the Internet browser you are using, may be included in this information.

If you reside outside of Hong Kong, please be aware that the Personal Data we collect will be processed and stored there. As a result, the level of protection provided by the data protection and privacy laws in Hong Kong may differ from that of your home country. As needed by relevant legislation, we will make sure the right protections are in place to effectively protect your personal information.

How do we use your personal data?

We utilize your personal information for a range of practical and acceptable business needs, including but not restricted to the following:

• Abiding with any legal or regulatory requirements, such as those relating to our know-your-client and anti-money laundering due diligence duties.
• Fulfilling a contract with you or acting on your behalf prior to a contract, such as giving you information about Crowder Securities Limited products or services; assisting you and responding to your inquiries; determining whether we can provide you with a Crowder Securities Limited product or service and under what terms; and responding to counterparty-presented know-your-client and anti-money laundering information requests.
• Speaking to data subjects.
• Engaging in client management, financial management, and administrative tasks.
• Developing, enhancing, and creating new goods and services.
• Carrying out market research, surveys, and other comparable projects to better understand client and site visitor needs and trends.
• Enforcing our Terms of Use and other agreements, as well as looking into and resolving disputes and security issues.
• Monitoring and auditing internal rules and procedures, legal duties, and compliance with regulatory agencies’ demands and orders.
• Processing and taking into account job applications, including determining your suitability for the job and verifying the correctness of any information provided.

Without your consent, we will not use your personal information for any purposes that conflict with the terms of this privacy notice. We do not currently sell any personal information and have never done so.

Who do we share your personal information with?

Within Crowder Securities Limited. For the reasons outlined above, we distribute your Personal Data to affiliates and businesses of Crowder Securities Limited. In general, unless specifically stated above or as otherwise permitted by applicable legislation, our group entities are not allowed to disclose your information to non-affiliated entities.

To unrelated parties. We may disclose your personal information to third parties in the following situations:

• Service providers. We disclose Personal Data to service providers who work for us (such as third-party service providers running a website) as well as to service providers and other counterparties to our clients and investors. These businesses may only use it to provide the requested service or in any other way that is allowed by law, and our contracts typically stipulate that the information must be kept private.
• A corporate transaction or other event. Your personal information might be shared as part of a corporate business transaction, such as a merger, acquisition, joint venture, financing, sale of company assets, bankruptcy proceedings, or other investment activity. We shall prominently display notice of the ownership change in such a case.
• As permitted by law. We may divulge your Personal Data if required to do so by law, court order, subpoena, investigation, or other similar procedure, or to comply with reporting requirements.

How are your Personal Data protected?

We take seriously our responsibility to protect your personal information. In compliance with relevant Crowder Securities Limited rules and procedures, we will maintain the confidentiality of any of your Personal Data that we have on file. All reasonable measures will be taken by us to protect all Personal Data against loss, theft, and unauthorized access, disclosure, or use. Only our authorized employees and transferees have access to it, which is kept in a secure location.

Updating your personal information

In general, we make an effort to maintain the accuracy and timeliness of your personal data. However, you are in charge of any changes to your personal data, including those that might affect your contact information, and we respectfully ask that you let us know about them. Please email info@crowdersl.com to amend or edit your Personal Data that we have on file, including your communication preferences.

How long will we retain your personal information?

In general, we will handle and retain your Personal Data for no less than the time required to enable us to comply with our legal, contractual, and regulatory requirements, which may vary based on the specific group company or jurisdiction. In accordance with those restrictions, we aim to store this information for no longer than is necessary in relation to the purposes described above. Your Personal Data will be kept on file by Crowder Securities Limited in compliance with our Books & Records Policy.

Complaints and contact

Any concerns you may have regarding the way in which Crowder Securities Limited uses your Personal Data will be taken very seriously. Contact info@crowdersl.com with any inquiries, requests, or complaints regarding the Site, this Privacy Notice, the User Agreement, or our use of your Personal Data. If your inquiry relates to data protection in Europe, you may also contact the relevant local Data Protection Authority.

Any Personal Data we obtain from you in connection with a complaint or question will be handled in accordance with this Privacy Notice and used solely to address it and evaluate the quality of our services.

Websites

Our websites, including crowdersl.com, are hosted on servers in Hong Kong. By using our websites and giving us information, you agree to the transfer and processing of your personal data in Hong Kong.

Please be aware that connections to other websites hosted by third parties may be present on a Site. Crowder Securities Limited has no control over and assumes no liability for the privacy practices and policies, content, or other elements of such third-party websites. We advise reading the privacy policies of every third-party website you visit.

Additional information for job applicants

The Crowder Securities Limited Applicant Privacy Notice applies to everyone submitting an application to join or work for Crowder Securities Limited as an employee or member. Contact info@crowdersl.com with any inquiries, requests, or complaints regarding this Privacy Notice and how we utilize your Personal Data.

Residents of the United Kingdom and the EEA

Any data subject who resides in the EEA or the UK is subject to the following information, for the purposes of the UK Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (together the “GDPR”). For crowdersl.com, the data controller is Crowder Securities Limited, which has its head office in Hong Kong and decides how we store and utilize Personal Data about you.

Data protection principles under GDPR

• The data will be processed legally, fairly, and openly.
• We will only collect the data for legitimate purposes previously communicated to you, and we will not use it for any other reason.
• The information we gather will be pertinent to the goals we have discussed with you and will be used only for those goals.
• We will make a reasonable effort to keep the data current and correct.
• We will only keep the data as long as necessary to comply with relevant legal and regulatory requirements.
• To maintain proper protection of the data, we will take suitable technical and organizational steps.

Personal data transfers outside the UK/EEA

Data transfer agreements, in the form of standard contractual clauses approved by the European Commission, govern the transfer of personal data from the UK/EEA to Crowder Securities Limited entities outside the UK/EEA. When your Personal Data is processed by third parties outside the UK/EEA, we will make sure the necessary protections are in place, as required by applicable law.

Data subject rights under GDPR

An EEA resident Data Subject has certain individual rights under the GDPR with regard to the Personal Data we may hold about them. You might, in particular, be entitled to:

• Request any data that is kept about you.
• Request that erroneous data be corrected.
• Request that any information held on you be erased, provided that Crowder Securities Limited does not need the information to complete a contract, assert a legal claim, or comply with any laws or regulations.
• Stop or limit the processing of data that is no longer necessary.
• Where technically possible, request the transfer of pertinent data to a third party.

You also have the right to revoke your consent for any processing of your Personal Data at any time where you gave it for a particular purpose. Use the details under “Complaints and contact” to exercise any of these rights.

Automated decision-making

We recognize your legal right to be free from judgments that are purely based on automated processing of your personal data, including profiling. In accordance with the GDPR, we typically do not employ any automated decision-making while establishing and carrying out a business relationship. Some of your Personal Data may be processed automatically to satisfy legal or regulatory requirements to prevent money laundering, financing of terrorism, and crimes that endanger assets, and to adjust marketing and communications as necessary.

Complaints to local authorities

You have the right to complain to your local or national data protection supervisory body about how we processed your personal data if you live in the EEA or the UK. You will not be charged anything to access your personal data or use any of your other rights, although we may impose a reasonable cost if a request is obviously excessive or unwarranted.

Rights of California data subjects

California individuals are entitled to yearly requests and free access to information regarding Personal Information released to third parties for direct marketing purposes during the previous calendar year under the state’s “Shine the Light” law, and may request access to or deletion of personal data gathered over the previous twelve months under the California Consumer Privacy Act (“CCPA”). You can reach us at info@crowdersl.com to make such requests.

• Requesters will have to provide identification proof by responding to a series of questions. Until identity is confirmed, no information will be released or deleted.
• If there is a substantial, articulable, and unjustified risk to the security of your personal information, your account, or our systems, we might not be able to comply with certain access requests.
• Before we can respond to a request for erasure, we will need you to confirm that you still want us to delete your personal information.
• You can appoint an authorized agent to submit a request on your behalf with your written consent; we may still require you to confirm your identity directly with us.
• You will not face discrimination under the CCPA for exercising your right to access or delete your personal data.

Data subject rights in China

When sharing or transferring Personal Data of Data Subjects in China outside of China, we will do so in accordance with the applicable obligations and guidelines in the Personal Information Protection Law of China (the “PIPL”).