Privacy Policy

To: Clients or potential clients of Infore Capital Management (Hong Kong), or investors or potential investors in one or more funds managed or advised by Infore Capital Management (Hong Kong).

Infore Capital Management (Hong Kong) may collect and use certain personal data. To the extent your details are provided to Infore Capital Management (Hong Kong) as a result of your existing or proposed investment in a fund or receipt of investment management or advisory services, Infore Capital Management (Hong Kong) (or through third party service providers) may process your personal data or that of your directors, officers, employees and/or beneficial owners ("your personal data") in accordance with Hong Kong's Personal Data (Privacy) Ordinance and other applicable data protection laws ("Data Protection Laws").

Please ensure that you provide a copy of this notice to any third parties whose personal data you provide to Infore Capital Management (Hong Kong). This notice may be updated at any time and Infore Capital Management (Hong Kong) will provide you the updated version in writing.

1. Types of Personal Data

Infore Capital Management (Hong Kong) or its service providers may collect the following categories of personal data: names, residential or business addresses, email or contact details, signature, nationality, tax identification or ID number, date and place of birth, copies of identification documents, bank account details, information about assets or net worth, and other information as may be required for AML/KYC compliance or as specified under applicable Data Protection Laws.

Your personal data may be collected through (i) information provided directly by you or on your behalf, or (ii) information obtained in relation to any transactions between you and Infore Capital Management (Hong Kong). Infore Capital Management (Hong Kong) may also receive your personal data from third parties such as affiliates, publicly accessible databases, tax authorities, governmental agencies, and credit agencies.

2. Purposes of Processing

Infore Capital Management (Hong Kong) processes your personal data for the following purposes:

(a) Contractual Necessity: To manage and administer your service relationship with Infore Capital Management (Hong Kong), including assessing and processing you as a client or investor, issuing and redeeming shares/interests, receiving payments from and making payments to you, and communicating with you about your holdings and account-related activities.

(b) Legal and Regulatory Compliance: To comply with applicable legal, tax and regulatory obligations, including AML and counter-terrorist financing checks, know-your-client procedures, tax reporting (including under automatic exchange of information regimes), and responding to requests from competent authorities.

(c) Legitimate Business Interests: To monitor and improve services, perform accounting and audit functions, communicate with clients and investors, facilitate business development, and protect our legal rights and interests.

This use of your data is necessary for the performance of our contract with you, compliance with legal obligations, and our legitimate business interests.

3. Disclosure and Transfer of Personal Data

Infore Capital Management (Hong Kong) may disclose your personal data to its affiliates and third party service providers engaged for the above purposes, competent authorities (including tax authorities), courts and regulatory bodies as required by law, and in connection with any sale or acquisition of Infore Capital Management (Hong Kong)'s business or assets.

Such disclosure may involve the transfer of data to jurisdictions outside Hong Kong. Infore Capital Management (Hong Kong) will ensure that any such transfer is conducted in accordance with applicable Data Protection Laws.

4. Retention Period

Infore Capital Management (Hong Kong) will retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and regulations.

5. Consequences of Not Providing Personal Data

Where Infore Capital Management (Hong Kong) requires your personal data to establish or maintain a business relationship, issue or redeem shares, or comply with legal or regulatory requirements, failure to provide such information may result in Infore Capital Management (Hong Kong) being unable to accept you as a client or investor, process transactions, or continue its relationship with you.

6. Your Rights

Under applicable Data Protection Laws, you have the right to request access to and correction of your personal data. You may also request erasure or restriction of processing in certain circumstances. To exercise these rights, please submit a written request to the Compliance Officer at the contact details below.

Infore Capital Management (Hong Kong) will respond to your request as soon as practicable and in any event within the timeframes prescribed by applicable regulations. We may request proof of identification to verify your request.

7. Protection of Personal Data

Infore Capital Management (Hong Kong) has implemented appropriate administrative, physical and technical measures to safeguard your personal data from unauthorized access, collection, use, disclosure, modification or disposal.

While Infore Capital Management (Hong Kong) strives to protect your personal data, no method of transmission over the Internet or electronic storage is completely secure. Infore Capital Management (Hong Kong) constantly reviews and enhances its information security measures.

8. How to Contact Us

If you have any questions about the use of your personal data, please contact:

Chief Compliance Officer

Email: jiangl1@inforecapital.com

Address: Rm 3906, Tower 6, The Gateway, Harbour City, 9 Canton Road, Tsim Sha Tsui, Hong Kong

9. Changes to This Notice

Infore Capital Management (Hong Kong) may revise this notice from time to time. The updated version will be provided to you in writing. Your continued relationship with Infore Capital Management (Hong Kong) constitutes your acknowledgement and acceptance of such changes.

This Privacy Notice was last updated on July 2026.