By visiting this Website, you are accepting the practices described in this Privacy Policy. If you do not agree to this policy, please do not use this Website. Please review the Terms and Conditions to learn of other terms and conditions applicable to your use of this Website.

Changes to this Privacy Policy

Zhong Ou Asset Management International Limited (the “Zofund Intl.”) reserves the right to change, modify, add, or remove portions of this Privacy Policy at any time for any reason. With respect to any expansion of the purposes of using your personally identifiable information received by us from the purposes as stated in this Privacy Policy, prior notice will be given to you and you have the right to decline acceptance of such expansion however in such circumstances our provision of continuing services to you may be limited.

Information Collection and Use 

Methods of Information Collection

We may receive personally identifiable information you submit to or through our Website. Failure to provide such per sonally identifiable information may result in Zofund Intl. being unable to provide you with the services or information requested. Separately we use "cookies" to collect and store information about your internet connection when you visit our Website. Cookies or other technology help us to provide customized services and information. "Cookies" are small files placed on your hard drive. Each website that you visit can send its own cookie to your browser if your browser preferences allow it. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Website. In addition, a number of companies offer utilities designed to help you visit websites anonymously.

Information Collected and Purpose of Information Collection 

The types of personally identifiable information that may be collected at our Website include information you provided to us through the "Contact" page (e.g. your name and email address).

Separately the "cookies" may track and record information of your activities on our Website (including user's preference and behaviour, navigation on the Website, logged-on identity, etc.). When you are navigating our Website, we record your IP address.

Opt-out

If you would prefer not to accept cookies from us, you may set your browser accordingly. If you choose to disable cookies in your browser, you may not be able to access all pages on our Website. 

Use of Personally Identifiable Information

The person ally identifiable information you submit to or through our Website is used only for responding to your inquiry sent to us, for business administration, business reporting and statistical analysis purposes. We will not sell, share, rent or otherwise disclose or transfer your personally identifiable information to others for monetary gains.

With respect to your information collected through cookies, we will use such information to assess how and when pages in our Website are visited, what our users' technology preferences are (such as what type of video player they use), whether our Website is functioning properly and for systems, trouble shooting, administrative and reporting purposes.

Additionally, you may encounter cookies or other similar devices on our Website that are placed by third party website tracking companies. In such circumstances the purpose and means of collection and retention policy of your personal identifiable information is the same as stated in this Privacy Policy and such information will not be transferred to any third parties except as provided under this Privacy Policy.

Affiliates and Service Providers: We may provide your personally identifiable information to our Affiliates and other third party service providers (including information technology service providers) for the Purposes. By disclosing your personally identifiable information to us via our Website, you consent to our disclosing of your personally identifiable information to such parties both in your country of residence and outside your country of residence. These persons may have access to the personally identifiable information you submit through our Website, but only for the purpose of performing their duties specified in this paragraph. These persons may not use your personally identifiable information for any purpose other than those stated above.

Compliance with Laws: Except as otherwise provided in this Privacy Policy, Zofund Intl. does not automatically collect personally identifiable information from visitors to our Website, except to the extent we are required to do so pursuant to any law or regulation binding on us. We will (and you authorize us to) disclose your personally identifiable information if we are required to make such a disclosure under applicable law or regulation, or where requested to do so by the police or by regulatory bodies, or where we wish to do so in relation to any suspected misuse by you of our Website, or of any of our Website services.

Business Transfers: If the business, stock or assets of Zofund Intl. are acquired or merged with another business entity, we will share all or some of your information (including your personally identifiable information) with this other entity to continue to provide services to you. You will receive notice of such an event and the new entity will inform you of any changes to the practices in this Privacy Policy. If the new entity wishes to make additional use of your information, it will inform you beforehand and you may decline such use at that time. 

For Hong Kong residents–your rights under PDPO: Under and in accordance with the terms of the Personal Data (Privacy) Ordinance ("PDPO") of Hong Kong and codes and guidelines issued pursuant thereto, any individual: 

1. may check whether Zofund Intl. holds personally identifiable information about him/her and may request access to such information;
2. may request Zofund Intl. to correct any personally identifiable information relating to him/her which is inaccurate;
3. may request Zofund Intl. to specify its policies and practices in relation to personally identifiable information and to be informed of the kind of personally identifiable information held by Zofund Intl.; and
4. may object to the use of his/her personally identifiable information for marketing purposes; Zofund Intl. will not use his/her personally identifiable information for these purposes if he/she communicates his/her objection to Zofund Intl..

In accordance with the terms of PDPO, Zofund Intl. has the right to charge a reasonable fee for the processing of any request for access or correction mentioned above.

The person to whom requests for (i) access to or correction of personally identifiable information or (ii) information regarding policies and practices and kinds of information held by Zofund Intl. should be sent is our Data Protection Officer. Contact details of this Officer are set out below in the section headed "Contact Us".

Nothing in this Privacy Policy shall limit your rights of under the PDPO.

Security

Zofund Intl. endeavours to prevent unauthorised disclosures of your personal information by other people, but we are not responsible for any unauthorised disclosures or other breaches of security or for the actions of others if the information was passed to them with your authority. 

The General Data Protection Regulation (“GDPR”) 

This Privacy Policy explains, where the relevant requirements of GDPR applies, how we use the personal information that Zofund Intl. collects or generates both in relation to this Website and our products and services.

1. “Personal Data”

means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Zofund Intl. (or its representatives or service providers).

2. THE TYPES OF PERSONAL DATA WE COLLECT

• Information that you provide to Zofund Intl.. This includes information about you that you provide to us, which may include: basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country), etc
• Cookies. When you visit Zofund Intl.’s Websites, cookies are used to collect technical information about the services that you use, and how you use them.

3. HOW WE USE YOUR INFORMATION

3.1. Your Personal Data may be stored and processed by us in the following ways and for the following purposes: 

• for ongoing review and improvement of the information provided on Zofund Intl.’s Website
• to ensure they are user friendly and to prevent any potential disruptions or cyber attacks;
• to allow you to use and access the products provided by Zofund Intl.;
• to assess your application for Zofund Intl., where applicable;
• to set up customers to use Zofund Intl.’s products
• to conduct analysis required to detect malicious data and understand how this may affect
  your IT system;
• for statistical monitoring and analys is of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
• to understand feedback on Zofund Intl.’s products and to help provide more information on the use of those products and services quickly and easily;
• to communicate with you in order to provide you with services or information about Zofund Intl. and Zofund Intl. products;
• for in-depth threat analysis;
• to understand your needs and interests;
• for the management and administration of our business;
• in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
• for the administration and maintenance of databases storing Personal Data.

3.2. However we use Personal Data we make sure that the usage complies with law and the law allows us and requires us to use Personal Data for a variety of reasons. These include:

• we need to do so in order to perform its contractual obligations with its customers;
• we have obtained your consent;
• we have legal and regulatory obligations that we have to discharge;
• we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
• the use of your Personal Data as described is necessary for our legitimate business interests, such as:
  • allowing us to effectively and efficiently manage and administer the operation of our
    business;
  • maintaining compliance with internal policies and procedures;
  • monitoring the use of our copyrighted materials;
  • enabling quick and easy access to information on Zofund Intl.’s products;
  • offering optimal, up-to-date security solutions for mobile devices and IT systems; and
  • obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.

3.3. We will take steps to ensure that the Personal Data is accessed only by employees of Zofund Intl. that have a need to do so for the purposes described in this Privacy Policy.

4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

4.1. We may share your Personal Data within the Zofund Intl. group of companies for the purposes described above.

4.2. We may also share your Personal Data outside of the Zofund Intl. group for the following purposes:

• to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
• if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
• if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer

5. HOW WE SAFEGUARD YOUR INFORMATION

5.1. We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.

5.2. As a condition of employment, Zofund Intl. employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by a Zofund Intl. employee is prohibited and may result in disciplinary measures.

5.3. When you contact a Zofund Intl. employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised
by you, has access to your file.

6. HOW LONG WE KEEP YOUR PERSONAL DATA

6.1. How long we will hold your Personal Data for will vary and will be determined by the following criteria:

• the purpose for which we are using it–Zofund Intl. will need to keep the data for as long as is necessary for that purpose; and
• legal obligations–laws or regulation may set a minimum period for which we have to keep your Personal Data.

7. YOUR RIGHTS

7.1. In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

• the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
• the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
• in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Zofund Intl.;
• the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
• the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
• the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
• the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.

7.2. You can exercise your rights by contacting us using the details listed in paragraph 8 below.

8. DESIGNATED REPRESENTATIVE

8.1. Zofund Intl.’s registered office may be contacted using the following contact information:

Data Protection Officer
Zhong Ou Asset Management International Limited
Suites 1701-1702, 17th Floor, Two Exchange Square, 8 Connaught Place, Central, Hong Kong