Updated: August 10, 2022

(The official Chinese website of Crowder Securities Limited)

The official website of Crowder Securities Limited in Japan is Crowdersl.com.

Crowder Securities Limited Aviation Partners (Crowder Securities Limited)

The locations of authorized Crowder Securities Limited offices are listed in the “Offices” section of the “Contact Us” page.

Please email us at info@Crowdersl.com if you have any queries concerning the aforementioned or if you would want to alert us to any alleged unauthorized conduct with Crowder Securities Limited.

Privacy is a priority for The Crowder Securities Limited.

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 (please see Annex A below for a list of specific entities that may act as a data controller with respect to personal data) 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, etc.), as well as certain regions and legal systems.

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 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, whether you freely send us an email, post information on the website, or otherwise textual communication).
• Indirectly from other sources (such 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. In order to accomplish this, the appropriate group entity will utilize data gathering technologies (or “Cookies”) on its website to track usage statistics such 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. For more information on how we use cookies on the Sites, please read our separate Cookies Policy.

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 or that of which you are a citizen. As needed by relevant legislation, we’ll make sure the right protections are in place to effectively protect your personal information.

What criteria and methods do we employ to 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: (i) giving you information about Crowder Securities Limited products or services; (ii) assisting you and responding to your inquiries; (iii) determining whether we can provide you with a Crowder Securities Limited product or service and under what terms; and (iv) responding to counterparty-presented know-your-client and anti-money laundering information requests.

on your behalf or in your favor;

• Additional lawful goals, such as:

o Speaking to data subjects;

o Engaging in client management, financial management, and administrative tasks;

o Developing, enhancing, and creating new goods and services;

o Carrying out market research, surveys, and other comparable projects to better understand client and site visitor needs and trends;

o 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;

o 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 won’t 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?

Crowder Securities Limited, inside.  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 other non-affiliates 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.  Your Personal Data may be accessible to these businesses, but they are only allowed to use it to provide the requested service or in any other way that is allowed by law.  We Typically stipulate in the contracts with these providers 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, and it might be given to a third party as one of the business assets in that transaction. Additionally, it may be made public if there is a receivership, bankruptcy, or insolvency. We shall prominently display notice of the ownership change in such a case.
• As Permitted By Law. In addition, we may divulge your Personal Data if forced to do so by law, or if we are required to do so by a court order, subpoena, investigation, or other similar procedure, or if we are obliged to do so by law or regulation in order to comply with reporting requirements.

How are your Personal Data protected by us?

We take seriously our responsibility to protect your personal information.  In compliance with relevant Crowder securities limited rules and procedures, we’ll 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.  We make every effort to ensure that any personal data we hold is stored.

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 get in touch with us using the information provided under the “Contact and Complaints” column below, or by sending an email to 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 reasons for which we collect and use the Personal Data (we refer to the purposes as described above). Your Personal Data will be kept on file by Crowder Securities Limited in compliance with our Books & Records Policy. Please feel free to get in touch with us if you have any special questions in this regard.

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.

You can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, www.autoriteitpersoonsgegevens.nl/en), or for other European entities with the relevant local Data Protection Authority, if your inquiry relates to data protection.

Any Personal Data we obtain from you in connection with a complaint will be handled in accordance with this Privacy Notice and used solely to address the complaint and evaluate the quality of our services. In a similar vein, if you contact us with a question, we’ll only use the information you give us to respond to your question, address any related concerns, and evaluate the level of service we offer.

Websites

Our websites, which include the following, are hosted on servers in Hong Kong:

Crowdersl.com

YOU AGREE TO THE TRANSFER AND PROCESSING OF YOUR PERSONAL DATA IN THE HONG KON BY USING OUR WEBSITES AND GIVING US INFORMATION.

Please be aware that connections to other websites hosted by third parties may be present on a Site. The Crowder Securities Limited Group 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, especially if it collects Personal Data about you, and being mindful when you leave a Site.

Additional Information for Crowder Securities Limited 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/or how we utilize your Personal Data.

Additional Information for Residents of the United Kingdom (“UK”) and the European Economic Area (“EEA”)

Additional Information for Crowder Securities Limited 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/or how we utilize your Personal Data.

Additional Information for Residents of the United Kingdom (“UK”) and the European Economic Area (“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 of the European Parliament and of the Council of April 27, 2016 (together referred to as the “GDPR” herein):

For the Sites, the following data controllers will be responsible:

Regarding crowdersl.com

• The Crowder Securities Limited, has its head office in Hong Kong • The decision on how we store and utilize Personal Data about you rests with the data controller.

Data Protection Principles under GDPR

Regarding the acquisition, custody, maintenance, use, and processing of your personal data:

• The data will be processed legally, fairly, and openly.
• We will only collect the data for legitimate, previously communicated to you purposes, and we won’t use it for any other reason.
• The information we gather will be pertinent to the goals we’ve discussed with you and will be used only for those goals.
• We’ll 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.

as long as is required.

• To maintain proper protection of the data, we will take suitable technical and/or organizational steps.

Personal Data Transfers Outside the UK/EEA

Data transfer agreements, which take the form of standard contractual clauses approved by the European Commission, govern the transfer of personal data from the UK/EEA to the Crowder securities limited entities outside the UK/EEA (a copy of which can be obtained from us via the contact information below).

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. If the recipients are not situated in a nation with sufficient data protection laws (as determined by the European Commission), we may execute the standard contractual clauses mentioned above.

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 in order 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
• In cases where it is 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 in cases where you may have given it in order for it to be collected, used, or transferred for a particular purpose. Unless we have another legal basis for doing so, we will no longer handle your information for the purpose(s) you first consented to after we get notification that you have withdrew it.

You also have the right to revoke your consent for any processing of your Personal Data at any time in cases where you may have given it in order for it to be collected, used, or transferred for a particular purpose. Unless we have another legal basis for doing so, we will no longer handle your information for the purpose(s) you first consented to after we get notification that you have withdrew it.

Complaints” item above in order to exercise any of these rights.

Making Decisions Automatically

We recognize your legal right to be free from judgments that are purely based on automated processing of your personal data, including profiling, especially when those decisions could have serious implications for you in terms of law or other matters.  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 by us with the aim of determining certain features of your personality (profiling), for example, to satisfy legal or regulatory requirements to prevent money laundering, financing of terrorism, and crimes that endanger assets.  As well

Utilize assessment techniques so that marketing and communications can be adjusted as necessary.

Local Authorities About Complaints

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 won’t be charged anything to access your personal data or use any of your other rights. However, if your request for access is obviously excessive or unwarranted, we have the right to impose a reasonable cost.

Rights of California’s Data Subjects

California individuals are entitled to yearly requests and free access to information regarding the Personal Information that was released to third parties for direct marketing purposes during the previous calendar year under the state’s “Shine the Light” law. Please get in touch with us using the information provided under the “Contact and Complaints” category above if you have any questions about these disclosures.

Additionally, Data Subjects in Hong Kong may be able to request the deletion of their personal data or access to personal data that we have gathered over the previous twelve (12) months in accordance with the California Consumer Privacy Act (“CCPA”).

You can reach us at info@crowdersl.com or by dialing +852-0000-0000 to make requests for access to or erasure of your personal data.

Requesters of access or erasure of personal information 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 with us, or our systems or networks as a result of the disclosure, we might not be able to comply with your access request for certain pieces of personal information.

Before we can respond to your request for erasure, we will need you to confirm that you still want us to delete your personal information.

By giving that agent your written consent, you can appoint an authorized agent to submit a request on your behalf. We may still require you to confirm your identification directly with us before we can honor a request made on your behalf via an agent.

Requests made by agents on behalf of people must be verified by providing a letter of consent from the person making the request. Agent requests won’t be honored by us until authorization is confirmed.

You are not allowed to face discrimination under the CCPA if you exercise your right to access or ask for the deletion of their 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”). For additional information on how Chinese data subjects’ personal information is processed and transferred across international borders, please see Annex B.