Personal Data Privacy Statement

We understand that you and website visitors are concerned about the privacy of information. By visiting this Website, you are accepting the practices described in this Personal Data Privacy Statement. If you disagree with the statement below, please do not use this Website.

The following Personal Data Privacy Statement is provided to you pursuant to the Personal Data (Privacy) Ordinance of Hong Kong (“Ordinance”) in connection with your dealings with, and provision of personal data or information (“Data”) to, Capstone Capital Management Limited or its affiliates (together “Capstone”) from time to time. Capstone is fully committed to protecting the privacy interests of individuals who provide us with information about themselves and to comply with the requirements of the Ordinance. In doing so, Capstone instructs its staff to comply with the strict internal standards of security and confidentiality.

A. Collection:

1. From time to time, it is necessary for you to supply Capstone with Data in connection with various matters such as account opening or continuations, provision of services to you or compliance with any laws or guidelines issued by regulatory or other authorities. It is not a statutory requirement for you to provide personal data to us. However, we will not be able to provide you with the services and products you may require unless you provide us with the necessary personal data or information.

2. The kinds of Data that may be collected includes, but is not limited to, name and address, occupation, contact details, date and country of birth, nationality, identity card.

3. Additional Data may also be collected at Capstone’s websites which include, but is not limited to:

3.1 the IP address of the visitor’s personal computer, the country from which the inquiry is made, the pages visited, the time at which a visit is made and the browser type;

3.2 certain personal details of the visitor(these may for instance include his/her name, age, sex, profession), client identification details, electronically encrypted security passcodes, information regarding holdings in any funds offered or distributed by Capstone. Whether the visitor wishes to receive information and, if so, what kind of information.

Apart from any security passcode, the Data collected at any Capstone website is not electronically encrypted.

We or our third-party partners may use software tools to gather information about site visitors' browsing activities. The information collected may be processed by us, our agents or any other third parties which provide services to Capstone.

B. Purpose and use:

The purposes for which Data may be used will vary depending on the nature of your relationship with Capstone. Capstone intends to use your Data (including any third party Data provided by you) for any or all of the following purposes:

1.1. any purpose related to the administration of the products and services offered by Capstone;

1.2. researching, designing and launching financial, investment services or related products for clients;

1.3. meeting the disclosure, reporting and compliance requirements (including but not limited to tax reporting) under any laws or regulations, codes, guidelines or internal Capstone compliance policies applicable to Capstone in Hong Kong or elsewhere;

1.4. any other purpose directly related to any of the above.

C. Retention and Access:

1. The Data collected may be maintained for such period of time required under applicable law and as otherwise needed to fulfil the purposes set out above.

2. Data held by Capstone relating to you will be kept confidential and Capstone will take all reasonable measures to ensure that Data is kept secure against unauthorised access, loss, disclosure and destruction. Capstone may provide such information to the following parties, whether inside or outside of Hong Kong, for the purposes set out in the “Purpose and Use” and “Direct Marketing” sections above:

2.1 the ultimate holding company of Capstone, its subsidiaries, representative offices, associated companies and/or affiliates;

2.2 any agent, contractor, subcontractor, consultant, insurer, or third party service provider who provides administrative, research, design, launch, digital or telecommunication, clearing and settlement or other services to Capstone in connection with the operation of its business;

2.3 the employees, officers, directors of Capstone;

3. Capstone’s policy is to restrict access to Data concerning individuals to those persons who have a need to use that Data and who have been instructed to handle such information properly and observe confidentiality. Security passcodes used by clients with on-line dealing privileges are electronically encrypted.

Please note that the Data transferred outside of Hong Kong may be subject a lower level of protection and/or cease to be protected by any relevant banking secrecy, client confidentiality or data protection laws of Hong Kong.

4. Under the Ordinance, you have the right to:

4.1 check whether Capstone holds Data about you, and access to such Data;

4.2 require Capstone to correct any Data relating to you which is inaccurate;

4.3 ascertain Capstone’s policies and practices in relation to data and to be informed of the kinds of Data held by Capstone; and

4.4 object to the use of your Data for direct marketing purposes and Capstone shall not use your Data for direct marketing purposes after you communicate your objection to Capstone.

In accordance with the terms of the Ordinance, Capstone has the right to charge a reasonable fee for the process of any data request.

For access to your Data held by Capstone, correction of such Data, objection to use of your Data for direct marketing purposes or for information regarding policies and practices and kinds of Data held, please contact:

Capstone Capital Management Limited

Address: Room 4713, 47/F, The Center, 99 Queen's Road Central, Central, Hong Kong

Email: compliance@capstone-funds.com

Tel: +852 3912 9951

In order to deal with any such request, Capstone may require evidence from you that you are the individual in respect of whom the request is made or a person permitted under the Ordinance to make the request on that individual's behalf.

Nothing in this statement shall limit your rights under the Ordinance.

D Changes to this Privacy Policy

This Privacy Policy may be updated by Capstone from time to time to comply with applicable data privacy laws or to reflect changes to Capstone’s practice. You are advised to visit this Website regularly to check for any amendments. Such amendments shall apply from the time that we post the same on this Website.

E Disclaimer

This Website may contain links to other websites for your convenience and information only. Please note that Capstone is not responsible for the content of any other websites linked by or linking to this Website and the privacy practices of such other websites. You are advised to check the privacy statement of each website you visit which may collect your personal data.

TERMS AND CONDITIONS

By accessing this (“Website”), you agree to be bound by the following terms and conditions, as may be revised by Capstone Capital Management Limited (“CAPSTONE” or “we”) from time to time in their discretion (“Terms”). If you do not agree to these Terms, please do not access this Website.

Should there be any inconsistencies between the English and Chinese versions of these Terms, the English version shall prevail.

Access

This Website is intended for those who access it from within Hong Kong. The availability of this Website and the distribution of the information contained in this Website in certain countries may be prohibited or contrary to local law or regulation. Accordingly, we do not guarantee nor provide any assurance whatsoever that this Website or the information therein complies with the local laws or regulations of, or is appropriate for use in, any other jurisdiction from which you access it. If you choose to access this Website from a jurisdiction other than Hong Kong, you do so at your own risk and CAPSTONE shall not be liable for your breach or contravention of any local law or regulation as a result of doing so.

The information provided on this Website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation. This Website is not directed to any person in any jurisdiction where the publication or availability of this Website or the information therein is prohibited, by reason of that person’s nationality, residence or otherwise, and persons under any such restrictions must not access this Website but can contact their advisor or intermediary for advice. All persons and entities accessing this Website do so on their own initiative and are responsible for their compliance with applicable local laws and regulations.

All copyright, patent, intellectual and other property rights in connection with the information contained in this Website are owned by CAPSTONE unless otherwise attributed to third party owners. No rights of any kind are licensed, assigned or shall otherwise pass to persons accessing this information. You may not copy, reproduce, duplicate, modify, adopt or lend, sell, disseminate or otherwise transfer, in whole or in part, any of the information contained in this Website, except for the purpose of accessing this Website and producing print-outs for personal use, or making a reasonable number of copies of such pages for internal use within your organization without any modification in any way. CAPSTONE (and any identified contributors), as the authors of material on this Website, must always be acknowledged.

No Offer/Local Restrictions

Nothing contained in or on this Website should be construed as a solicitation of an offer to buy or offer, or recommendation, to acquire or dispose of any security, commodity, investment or to engage in any other transaction. CAPSTONE offers a number of products and services designed specifically for various categories of investors in various countries and regions. Not all products will be available to all investors. These products or services are only offered to such investors in those countries and regions in accordance with applicable laws and regulations.

No information included on this Website is to be construed as investment advice or as a recommendation or a representation about the suitability or appropriateness of any advisory product or service; or an offer to buy or sell, or the solicitation of an offer to buy or sell, any security, financial product, or instrument; or to participate in any particular trading strategy. Investors should seek independent financial and tax advice before making any investment decision.

All products and services provided by CAPSTONE have their own terms and conditions (“Product Terms”). You must read both the Product Terms and these Terms. Other websites owned by CAPSTONE may have their own terms and conditions which may be different from these Terms. To the extent that the Product Terms conflict with these Terms or any CAPSTONE websites' terms and conditions then the Product Terms will prevail.

Investment Performance and Risk Warnings

Investment involves risks and past performance is not a reliable indicator of future performance. The value of investments and the income from them can go down as well as up and investors may not get back the amount originally invested and may lose all of their investment. Exchange rate changes may cause the value of overseas investments to rise or fall. Investors should read the offering documents for details and risk factors.

Information on this Website

CAPSTONE has taken reasonable care to ensure that the information contained on this Website is accurate, current, complete, fit for its intended purpose and compliant with relevant legislation and regulations as at the date of issue. However, errors or omissions may occur due to circumstances beyond our control and no warranty is given, and no representation is made, regarding the accuracy, validity or completeness of the information on this Website and no liability is accepted by such persons for the accuracy or completeness of such information. You must conduct your own due diligence and investigations rather than relying on any of the information in this Website. Any person who acts upon the information contained on this Website does so entirely at his or her own risk.

Information posted on this Website is current only as at the date it is first posted and may no longer be true or complete when viewed by you. CAPSTONE cannot guarantee that Content will be accurate, complete and current at all times. To the extent that any information on this Website relates to a third party, such information has been provided by that third party and is the sole responsibility of such third party and CAPSTONE accepts no liability for such information. All Content on this Website is subject to modification from time to time without notice.

To the extent that this Website contains any expression of opinion or forecast, such opinion or forecast is based on sources believed by CAPSTONE to be reliable, but is not guaranteed or warranted as to its current validity, accuracy or completeness. Opinions expressed represent the opinions of CAPSTONE at the date of publication only, reflecting prevailing market conditions and certain assumptions (which may not prove to be valid), are subject to change and should not be relied on by users of this Website.

Linked Websites

Links to websites operated by third parties are provided for information only and do not constitute any form of advice, endorsement or recommendation of such websites or the material on them. CAPSTONE accepts no responsibility for information contained on any other websites which can be accessed by hypertext link from this Website or for these websites not being available at all times. CAPSTONE has not reviewed, and will not review or update, such websites or information and any use that you make of such websites and information is at your own risk. Please note that when you click on any external site hypertext link you will leave this Website.

Links to this Website

Neither you nor any other party may use any part of this Website on any other website, or link any other website to this Website, without our prior written permission.We are not responsible for the set-up of any link from a third party website to this  Website.

Neither you nor any other party may deep-link to, frame, spider, harvest or scrape the content of this Website, including the layout and all pages, screens, information and materials included in or accessible through this Website (”Content”) or otherwise access the Content for any purposes, or use any machine, electronic, web based or similar device to read or extract the Content by machine based or automated means, without our prior written permission.

Data Privacy

Please see our Persontal Data Privacy Statement for information on how we handle your personal data.

Cookie Policy

We use cookies to enhance your website experience. By using this Website, you agree that we may store and access cookies on your device. A cookie is a small data file sent to your browser to store and track information about users and their visit to a website by the website that you visit.

The cookie technology captures your browsing pattern on this Website and some other websites after you browse here. While this cookie can tell us when you enter this Website and which pages you visit, it cannot read data off your hard disk. The information and analysis will be used by us to improve and customise your experience on this Website, and may be shared with our selected group of partners to improve and customise your experience on their websites, or enable them to provide you with information on relevant products and services.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies and remove cookies stored, if you prefer. This may prevent you from using certain features and functions of this Website.

Availability of Website, Products and Services

Not all products or services provided on this Website are available in all jurisdictions. CAPSTONE’s products and services are only available in jurisdictions where, and to investors to whom, it is lawful to advertise and market these products and services. The information on this Website has been prepared for informational purposes only without regard to any particular user’s investment objectives or any such user’s financial situation or position, and CAPSTONE is not soliciting any action based upon them.

The Content of this Website, or products or services available via this Website may be wholly or partially suspended, withdrawn or changed at any time. We also reserve the right at any time to immediately suspend the provision of all or any part of this Website to you and/or block your access to this Website.

Internet and E-mail Communications

Messages sent over the Internet (including e-mail) cannot be guaranteed to be completely secure as they are subject to possible interception, monitoring, delay, loss or alteration. CAPSTONE is neither responsible for any such messages nor liable to you or anyone else for any damages or otherwise in connection with any messages sent by you to us or any other party or any messages sent or appearing to be sent by us or any third party to you over the Internet (including e-mail). You should not include any sensitive or confidential information in such messages.

Our Monitoring of Communications

To help us improve and/or provide our service and in the interest of security, we may monitor and/or record communications (whether over the Internet, telephone or otherwise) between you and us. All recordings are our sole property.

Changes to these Terms

We reserve the right to change, modify, add or remove these Terms at any time by updating these Terms at our sole discretion, without notice or liability. We suggest you review these Terms periodically. If you use this Website after changes are posted to this section, you are deemed to accept the changed Terms.

If any part of these Terms is found by any court or other competent authority to be invalid, unlawful or unenforceable, then such part shall be deemed to have been severed from the rest of these Terms which shall continue to be valid and enforceable to the fullest extent permitted by law.

No Warranties

All warranties and representations, whether express, implied or statutory are, to the fullest extent permitted by the law, excluded. Use of this Website is at your sole risk.

We do not warrant, either expressly or impliedly, that:

· any information contained on this Website will be accurate, complete or up to date or meet your specific requirements,

· access to this Website or the functions contained in this Website will be uninterrupted or that there will be no delays, failures, errors, omissions or loss of information as this Website is transmitted to you, or

· this Website or the server that makes it available or e-mails by us are free from viruses or other contaminating or destructive materials or elements that may be transmitted or that your computer system will not be damaged.

We do not provide any guarantee about the accuracy, functionality or performance of any third party software, Content or equipment used in connection with this Website.

Exclusion of Liability

To the extent permitted by law, CAPSTONE shall not be liable for any damage, loss or liability (whether arising in contract, tort, including negligence, or otherwise) arising out of or in connection with:

· your use of this Website,

· your reliance on or your inability to use the information, products or services on this Website, or

· any failure or performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure to this Website or your use or attempted use of it.

The above exclusions also apply to any direct, indirect, special, incidental, punitive, exemplary or consequential loss (such as loss of profits, business, opportunity or data), expenses or damage of any kind whatsoever and howsoever arising even if you have advised us or any other member of CAPSTONE of the possibility of such damages, losses or liabilities.

Regulatory Status

CAPSTONE is regulated by the Securities and Futures Commission of Hong Kong (the “SFC”).

This Website has not been reviewed by the SFC or any other regulator.

Governing law

These Terms are governed by and are to be interpreted in accordance with the laws of Hong Kong.

The courts in Hong Kong will have exclusive jurisdiction in respect of any dispute which may arise in connection with these Terms or your use of this Website. It is a condition of using this Website that you waive any objection to proceedings in the courts of Hong Kong on the grounds of venue or that proceedings have been brought in an inconvenient or inappropriate forum.