Last updated at 12 May 2022

Equasia Group refers to members of the Equasia consulting group (“Equasia
Group”). It consists of the following businesses (each, an “Equasia Group
Business”):

• Corporate Advisory
• Legal
• International Administration
• Accounting and Reporting
• Intellectual Property
• Compliance
• Sustainability and Responsibility

Where we refer to an Equasia Group “office”, we are referring to an office
of an Equasia Group Business.

Further details of the operating structure and regulatory status of each
Equasia Group Business, and applicable legal and regulatory terms, follow
below.

Entities and Regulatory status

Hong Kong:

Equasia Ltd

A limited company registered in Hong Kong

Companies Registry no 1502042

Trust and Company Services Registration TC002611

HTF Ltd

A limited company registered in Hong Kong

Companies Registry no 574280

Trust and Company Services Registration TC004910

Bonnard Lawson Consulting Ltd

A limited company registered in Hong Kong

Companies Registry no 2482124

Registered Business Name: Equasia Advisors

People’s Republic of China:

BNLS Law Firm

An independent partnership under Chinese law, affiliated with Equasia Group

Licensed as a PRC law firm in Shanghai, PRC under no 31310000MD0285066B

Shanghai Equasia Consultancy Ltd

上海瑛汇颀商务咨询有限公司

A wholly foreign owned limited company registered in Shanghai, PRC under no
91310115MA1K3MA829

Registered as a Trademark Agent with the Trademark Office of China National
Intellectual Property Administration

http://wssq.sbj.cnipa.gov.cn:9080/tmsve/agentInfo_getAgentDljg.xhtml

Privacy Policy

Your privacy is important to us. Equasia Group, as defined in our legal and
regulatory section, (“Equasia Group”, “we”, or “us”), are committed to
protecting and safeguarding any personal information we collect. This
document provides Equasia Group’s personal information processing rules,
which are based on the privacy and data protection principles common to the
countries we operate in (the “Privacy Policy”).

This Privacy Policy is mainly intended to let you know what personal
information we may collect about you and how we process that information.

This Privacy Policy applies to the personal information we collect from the website and related subdomains
(the “Website”) managed by us, and from when you use any
of the services we provide (the “Services”). This Privacy
Policy will govern any personal information you provide to us while
registering to, or using, the Website and our Services.

Generally, our intent is to collect only the personal information provided
voluntarily. Equasia Group does not collect or process any personal
information from visitors of the Website that is not voluntarily provided.

This Privacy Policy applies to the personal information we collect through
the Website and other means by which we collect data. For example, it also
covers how we collect information from in-person discussions, telephone
conversations, and non-electronic communications.

Equasia Group collects and processes personal information in the context of
providing Services, subject to the applicable data protection and privacy
laws and regulations. Please review this Privacy Policy to learn more about
how we collect, use, share and protect the personal information that we
have obtained.

For the avoidance of doubt, personal information processing includes, but
is not limited to, the collection, storage, use, transmission, provision,
disclosure, and deletion of personal information.

Acceptance and update of this Privacy Policy

We might amend this Privacy Policy from time to time. Therefore, we
encourage you to visit this page regularly to know exactly where you stand.
If we make changes to this Privacy Policy that will impact you, such as if
we intend to process your personal information for a new purpose other than
communicated in this Privacy Policy, we will notify you of these changes
before starting further processing activities.

If you disagree with this Privacy Policy, you should discontinue using our
Services. Please note we may not be able to provide some of our Services to
you if you disagree with the processing of your personal information as
described in this Privacy Policy. If you are using the Website and prefer
to contact us by phone or pay us a visit in person, please check our
information here.

If you have any doubts about this Privacy Policy, you may contact us at any
time at the e-mail address provided in item 14.

What kind of information do we collect?

Personal information:
Personal information refers to all kinds of information related to
identified or identifiable natural persons that are electronically or
otherwise recorded, such as your name, e-mail address, ID information,
address, other contact details, and online identifiers. We may also collect
personal information from third parties that you provide to us.

Usually, we obtain personal information about you if you choose to provide
it, such as to contact mailboxes or register for certain services. By
registering and/or submitting personal information to Equasia Group, you
also acknowledge that Equasia Group may use this information in accordance
with this Privacy Policy. Your personal information is not used for other
purposes unless we obtain your permission or unless otherwise required or
permitted by law or professional standards.

Please note that if you disclose someone else personal information to us,
it is your responsibility to ensure the person or people you have provided
or will provide personal information about are aware of it and have
accepted how Equasia Group uses their information (as described in this
Privacy Policy).

We only collect personal information to offer our Services. We may also
collect information from your computer, phone tablet, or other devices you
are using to access the Website, such as your IP address. Please note that
some of these data are necessary for the Website’s functioning.

Sensitive personal information:
Sensitive personal information refers to any information that, if leaked or
illegally used, could easily lead to the infringement of human dignity or
cause harm to an individual or their property, such as financial
information, health care information, and personal information of minors
under the age of 14.

Equasia Group does not collect sensitive personal information unless
strictly necessary to provide the Services. We may only collect your
sensitive personal information after specifically obtaining your consent
and notifying you of the necessity of the processing and the impacts it
might have on your rights and interests.

Other data (excluding personal information):
Other data refers to information that cannot be traced back to a specific
individual. For example, we may track the number of visitors to our website
each day.

Personal information from third parties:
We might also receive information about you from other sources when
necessary for them to provide you with services or for other reasons, as
should be specific in their notices and policies. These include business
partners, other members of the Equasia Group corporate family, and
independent third parties. We suggest you carefully read any third-party
privacy notice and policy to understand how they share your personal
information with us.

Equasia Group will process any personal information collected under the
provisions of relevant data protection and privacy laws and regulations.

How do we collect and use information from or about you?

We collect information, for example, when you
: (i) enter your information via the contact page and submit it to us; (ii)
obtain products and/or services from us; (iii) request information from us;
(iv) opt-in or subscribe to our newsletter or participate in a campaign;
(v) respond to our customer surveys; or (vi) engage one of our business
partners to provide you with services or products that require the
disclosure of your personal information to us.

Automatic collection:
In some instances, Equasia Group and its service providers use cookies, web
beacons, and other technologies to automatically collect certain types of
information when you visit us online, as well as through e-mails that we
may exchange. The collection of this information allows us to customize
your online experience, improve the performance, usability, and
effectiveness of Equasia Group’s online presence, and measure our marketing
activities’ effectiveness.

If you have subscribed to our marketing activities, you shall have the
right to opt out anytime if you do not wish to receive any future marketing
materials from Equasia Group.

We may also:

· acquire information from public sources or third-party sources, such
as our advertising and market research partners, to update or enhance the
other information collected about you. Local law may require that you
authorize the third party to share your information with us before we can
acquire it; and

· automatically acquire information when you reply to or interact with
an e-mail we send, such as to track your engagement with our messages or
when your replies to our messages contain additional e-mail addresses.

What is the legal basis for processing your personal information?

Equasia Group generally collects only the personal information necessary to
fulfill your request. However, where additional, optional information is
sought, you will be notified of this at the point of collection.

Relevant data protection and privacy laws from jurisdictions such as the
Peoples’ Republic of China, Hong Kong SAR, and European Union, where
applicable, allow us to process personal information, so long as we have a
ground under the law to do so. Additionally, they require us to tell you
what those grounds are. As a result, when we process your personal
information, we will rely on one of the following processing conditions:

To provide products or services:
We may process your personal information to provide the Services or operate
the Website, including providing support and processing your requests,
questions, and concerns.

The processing is necessary for the conclusion or performance of a
contract that you are a party

: We will process your personal information when processing your personal
information is necessary to perform our obligations under a contract
entered with you.

For conducting human resource management
: We will process your personal information when you provide it to us in a
recruitment process or if you are part of our staff.

When it is necessary for us to fulfill statutory functions or statutory
obligations

: We will process your personal information when we are required to do so
to comply with a legal obligation, such as keeping records for tax purposes
or providing information to a public body or law enforcement agency

You gave us your consent:
We may occasionally ask you for separate permission to process your
personal information for specific purposes such as to send you e-mails with
information about our products and Services, or to ask you for permission
to share your personal information with our business partners overseas to
enhance the quality of the Services we provide you. We will only process
your personal information in this way if you agree to us doing so. You may
withdraw your consent at any time by contacting Equasia Group at
support@equasia-group.com.

How do we use your information?

Based on the legal grounds described above, we usually process your
personal information for the following reasons:

· to allow you to use and interact with the Website, and download any
informative material we may provide free of charge;

· to communicate with you in response to your requests for
information, or as may be relevant for providing the Services to you;

· to send marketing communications related to our products and
services;

· to customize the information Equasia Group delivers to you;

· to improve the overall quality of the Website and our Services;

· to count, track, and aggregate your activity into our analysis of
general traffic flows at the Website (e.g., tracking where traffic comes
from, how traffic flows within the google.com properties, etc.);

· as required by applicable law or legal requirements about records
retention or for internal administrative purposes;

· as may be specifically authorized by you from time to time in
writing.

Sharing your personal information

We do not share personal information with unaffiliated third parties,
except as necessary for legitimate professional and business needs to carry
out your requests and/or as required or permitted by law or professional
standards.

We may also share your personal information with our affiliates worldwide,
who are all governed by this Privacy Policy.

We will share your personal information in situations such as the
following:

· Equasia Group works with reputable partners, service providers, or
agencies so they can process your personal information on our behalf.
Equasia Group will only transfer personal information to them when they
meet our strict standards on data processing and security.

· If we are reorganized or sold to another organization, we may also
disclose personal information related to the sale, assignment, or other
transfer of the site’s business to which the data relates. You will be
notified if that happens;

· Equasia Group may, to the extent permitted by the local laws or
subject to the fulfillment of the regulatory requirements of the applicable
laws, disclose personal information to respond to requests of courts,
tribunals, government, or law enforcement agencies.

· Disclosures of personal information may also be needed for data
privacy or security audits and/or to investigate or respond to a complaint
or security threat.

Other than stated above, we may share your personal information with third
parties only under any of the following circumstances:

• when we have your consent to share the information;

· we need to share your information to provide any information,
services, or goods at your request;

• we need to share the information to contact you;

· we need to enforce the terms of use of any of the Website or any of
our Services;

· in any case of dispute or legal proceeding of any kind between you
and any member of Equasia Group;

· if we believe that you have breached the applicable terms of use or
have abused your rights to use any of our Services or performed any act or
omission that we believe to be violating any applicable law, rules, or
regulations;

· in urgent circumstances to prevent physical harm or damage to any
person or property; or

· in any other situation as required or authorized by applicable laws
and regulations.

Equasia Group will not transfer or disclose the personal information you
provide to any third parties for their own direct marketing use.

Prior to entrusting the processing of your personal information, we will
agree on the processing methods, categories of personal information,
protection measures, and the rights and obligations of both Equasia Group
and the third party.

Any third party with whom we may share your personal information will be
contractually bound to keep your personal data confidential and
appropriately secure.

How is your personal information shared within Equasia Group?

When using our Services, you agree to the collection and/or processing of
data by third parties, when necessary, and by the members of the Equasia
Group, as described below. We may receive personal information about you
from other companies in the Equasia Group, or share your personal data with
them, for the following purposes:

• To provide services and products
• To provide customer service

· To detect, prevent, and investigate fraudulence or other illegal
activities and data breaches

• For analytical and product improvement purposes

· To send you personalized offers or marketing with your consent, or
as otherwise permitted by applicable law

· For hosting, technical support, overall maintenance, and maintaining
security of such shared data

• To ensure compliance with applicable laws

As applicable and unless indicated otherwise, for the purposes described
above, Equasia Group normally relies on our contractual relationship, on
your consent, our legitimate interest (where applicable), or to comply with
legal obligations.

All companies within the Equasia Group may need to exchange personal
information of our clients to ensure the best delivery of our products and
services.

International transfers of personal information

To be able to provide you certain Services, we may process your personal
information to third parties in different jurisdictions, including Mainland
China, Hong Kong Special Administrative Region (“Hong Kong SAR”) and
jurisdictions in Southeast Asia.

When we need to process your personal information overseas, we may rely on
different data protection rules based on the applicable laws and
regulations. We may rely on, for example, appropriate standard contractual
clauses and other mechanisms that are compatible with relevant data
protection laws and regulations.

When we need to process your personal information overseas, we will do so
after obtaining your separate consent. We will take all the necessary
measures to ensure the safety of your personal information. The reasons for
the transfer and the categories of recipients of the personal information
transferred are stated below.

To provide you our full range of Services, we may need to share your
personal information with our business partners who are not located in the
same jurisdiction as we are. For example, if you need consulting Services
in transactions involving Hong Kong SAR and Mainland China, we may need the
support of our partners in Mainland China.

How long we retain your information

We will retain your personal information for the shortest time necessary to
achieve the processing purposes, such as to enable you to use our Services,
to comply with applicable laws, resolve disputes with any parties, and
otherwise as necessary to allow us to conduct our business, including to
detect and prevent fraud or other illegal activities. In any case, the
retention period will not exceed 10 years.

All personal information we retain will be subject to this Privacy Policy.
If you have a question about a specific retention period for certain types
of personal information we process about you, please contact us using the
contact details provided below in item 14.

How we handle children’s personal information

Equasia Group’s services are not directed at children. We do not knowingly
collect personal information from children under the age of 14 without
consent from their parent or guardian. We will delete such information if
we become aware that it has been submitted by a third party who is not the
minor parent or legal guardian.

In case we absolutely need to process children’s personal information to
provide you our Services, we will notify the parents or guardian of the
necessity of the processing and the impacts on the child’s rights and
interests and implement strict security policies.

If you are a parent or guardian and are concerned about our collection of
your child’s personal information, please contact us.

Links to other websites

The Website may contain links to sites operated by third parties whose
policies regarding handling information may differ from ours. These
websites and platforms have separate and independent privacy or data
policies, privacy statements, notices, and terms of use, which we recommend
you read carefully.

Your rights and how you can exercise them

According to relevant laws, regulations, and national standards, as well as
common practices in the jurisdictions where privacy laws apply to Equasia
Group’s processing of personal information, you will have the following
rights:

· the right to know and to decide on the processing of your personal
information;

· the right to restrict or refuse the processing of your personal
information;

· the right to consult and duplicate your personal information;

· the right to have your personal information rectified if inaccurate
or incomplete;

• the right to change the scope of your consent;

· the right to de-register from our mailing list once you have given
us your consent to be in it;

· the right to request the erasure of your personal information, for
example, when it is no longer needed for the purposes for which it was
collected or processed, or to have it erased when you withdraw your
consent; and

· the right to request the portability of the personal information
entrusted to Equasia Group on the basis of consent.

To exercise the rights mentioned above, you may contact us directly at support@equasia-group.com
and ask us the following: (i) to provide you a copy of your personal
information, (ii) to correct your personal information, (iii) to erase or
restrict the processing of your personal information, and (iv) to transfer
some of your personal information to other organizations. You may also
object to our processing of your personal information.

We will acknowledge your e-mail within 3 days and seek to resolve your
concern within 1 month of receipt. However, where the issue is complex, or
we have a large volume of requests, we will notify you that it will take
longer than one month to resolve your concern, and we will seek to resolve
it within 2 months. Please note:

· We should be able to determine your identity in order to be able to
respond to your request.

· We may not accommodate a request to change information if we believe
the change would violate any law or legal requirement or cause the
information to be incorrect.

· We are not obliged to delete personal information if we can show
that the processing is required under applicable law or regulation, or, for
example, for the establishment, exercise, or defense of a legal claim.

· Where the retention period provided by any law or administrative
regulation has not expired, or it is difficult to realize the deletion of
personal information technically, we will cease the processing of your
personal information and take necessary security protection measures for
such information.

· If you provide us with your e-mail address, you will always have the
opportunity to opt-out of receiving e-mail newsletters and promotions
through the unsubscribe link in the e-mail communications.

· If you do not allow us to collect, or ask us to delete or to stop
processing, any of your personal information, we may not be able to provide
you with certain features and/or Services, and some of the Website’s
features and some of our Services may not work appropriately or adjusted to
your interests and preferences.

If you want to exercise any of your rights, you may contact us at
support@equasia-group.com

We will not charge for your reasonable requests in principle. However, a
fee to reflect the cost may be imposed as appropriate on repeated requests
beyond a reasonable scope.

If you are unhappy with our processing of your personal information or you
understand there is an alleged infringement of any applicable data privacy
laws, you may lodge a complaint with a competent supervisory authority.

How we protect your personal information

Equasia Group is concerned about the security of your data. We have
implemented technical and organizational security measures designed to help
protect your information from unauthorized access, disclosure, use, and
modification. In addition, we review our security procedures to consider
appropriate new technologies and methods from time to time.

Please be aware that despite our efforts, no security measures are perfect
or impenetrable. As a result, we cannot ensure, and do not warrant or
guarantee, that the information you transmit to us will remain secure, nor
do we guarantee that this information will not be accessed, disclosed,
altered, destroyed, or used in an unauthorized manner.

If we learn of a security breach, we may attempt to notify you
electronically so that you can take appropriate protective steps. We may
also post a notice on the Website or our Services if a security breach
occurs. Depending on where you live, you may have a legal right to receive
a notice of a security breach in writing. Depending on the breach, we may
also have the right to implement corrective measures, and you may not need
to be notified.

Contact Us

If you have any additional questions or concerns about our privacy policy,
please contact us at support@equasia-group.com.