Privacy Statement

1. SDG Securities (HK) Limited (“SDGS” or “we”) is committed to providing clients with the best securities services.

2. We shall use client's data accordingly based on the service needs. We understand that clients are extremely cautious about the use and confidentiality of their personal data, which is why we are going to handle all personal data with our highest standard of care.

3. We have always been cautious about client data security and client privacy protection. Therefore, SDGS has made following rules and is committed to maintain the confidentiality of client data and information.

4. Individual client may be required to provide us personal data ("Information") for the purpose of use provided under Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong). The client's data (and other data) can be used for the following purposes:

· The day-to-day operations of the services and facilities provided to clients;

· Conduct a credit review;

· Assist other agencies in conducting credit reviews;

· Ensure that the client's credit is maintained;

· Design financial services or related products for use by clients;

· Promote financial services and related products to clients ;

· Determine the amount of debt owed to clients or clients in arrears;

· Comply with the requirements for disclosure in accordance with the requirements of any legislation or regulation; and

· any use related to any of the foregoing.

5. Client-related data (and other data) held by SDGS will be kept confidential. SDGS may disclose all data (and other data) to following persons, and clients’ consent for such disclosure is also the conditions for SDGS to provide services, products and data to clients:

· Any officer, employee, agent, contractor or third party who provides SDGS with administrative, credit data, debt recovery, telecommunications, computer, payment or other services related to its business operations ;

· Any financial institution that the client has or intends to trade with;

· Regulatory or judicial authorities and other relevant government or statutory bodies;

· Any other person who is responsible for maintaining the confidentiality of SDGS, including SDGS, which is committed to maintaining such information;

· The use of data between clients within the company of SDGS is subject to strict internal security standards, confidentiality policies and applicable laws;

· We bind our employees to full compliance with such standards, policies and laws; and

· We do not distribute data about our clients to other companies except for conducting business, complying with applicable laws, protecting against fraud or making products and services that we believe may be in the clients' interest. We may also provide information to regulatory authorities and law enforcement officers in accordance with applicable laws.

6. We intend to use your personal data for direct marketing purposes, for which we must obtain your consent (including no objection). Part VIA of the Personal Data (Privacy) (Amendment) Ordinance 2012 introduces specific requirements for obtaining your consent (including no objection). In this regard, please pay attention to:

· Your name, contact details, product and service portfolio information, trading patterns and conduct, financial background and statistics held by SDGS from time to time may be used by SDGS for direct sales;

· The following categories of services, products and promotional slogans will be made available to you for promotion:

a) Finance, insurance, securities, commodities, investment and related services and products and credits; and

b) Services and products in the category of promotional slogans are provided by associates of SDGS (the names of such associates will be provided on the application form for services and products, as the case may be).

· In addition to promoting the above services, products and promotional slogans, SDGS also intends to provide the data to all or any of them for the purpose of promoting such services, products and promotional slogans (SDGS may or may not receive remuneration) and SDGS hereby obtains your written consent (including no objection) for this purpose; and

· If you do not wish SDGS to use or provide your data to other persons for the above direct marketing purposes, you may send a written notice to SDGS to exercise your right to refuse to participate in direct marketing activities.

7. SDGS may carry out the following activities in accordance with the Personal Data (Privacy) Ordinance and other applicable laws:

· Pair, compare or exchange any data or other data provided by or with the Client with the data (or other data) held by SDGS or any other person for the following purposes:

a) Credit review;

b) Data (or other data) check; and

c) Propose or check data (or other data) that may be used to take actions that are unfavorable to the client or any other person at any time.

· Transfer such data (or other data) to any place outside Hong Kong (whether processing, holding or using such data or other data outside of Hong Kong).

8. According to and in accordance with the terms of the Personal Data (Privacy) Ordinance, each client has the right to:

· Check if SDGS holds data about the client and whether it has the right to use such data;

· Request SDGS to change any wrong information about the client; and

· Determine the policies and practices of SDGS and the types of personal data held by SDGS.

9. Client may submit request to review and/or correct any data client to our Personal Data Protection Officer at the following address:

· Suite 5806-5807, 58/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong; Attention to: Personal Data Protection Officer, or

· Email to dataprivacy@sd-gold.hk

10. Pursued by the terms of the Personal Data (Privacy) Ordinance, SDGS reserves the right to charge a reasonable fee for processing any data request.

11. The information about the clients will only be used for the business purposes as well as product design and offers of SDGS.

12. As we develop new products and services in the new technology era, we will continue to make every effort to ensure that our clients' data is properly used and properly protected.

13. This disclaimer and statement may be drafted and concluded in different languages, including Chinese, English and others. In case of any inconsistency and discrepancy between the Chinese version and any version of other language, the Chinese version shall prevail.