Privacy Policy 私隱政策

1. Introduction

Capital Grand Investment Limited (CR No. 0885847) ("we", "us", "our", or "the Company") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO").

By using our website or services, you consent to the collection and use of information in accordance with this Privacy Policy.

2. Information We Collect

We may collect the following types of personal data:

• Personal Identification Information: Name, email address, phone number, business address
• Professional Information: Company name, job title, investor classification
• Financial Information: Investment objectives, risk tolerance, financial statements (for qualified clients)
• Technical Data: IP address, browser type, device information, cookies
• Communication Records: Correspondence with our team, meeting notes, consultation records

3. How We Use Your Information

We use your personal data for the following purposes:

• Providing wealth management and financial planning services
• Responding to inquiries and consultation requests
• Conducting client verification and due diligence (KYC/AML compliance)
• Sending service updates, market insights, and newsletters (with consent)
• Complying with legal and regulatory obligations under Hong Kong SFC regulations
• Improving our website and services
• Preventing fraud and maintaining security

4. Legal Basis for Processing

We process your personal data based on:

• Consent: Where you have given explicit consent for specific purposes
• Contractual Necessity: To fulfill our obligations under service agreements
• Legal Obligations: To comply with Hong Kong laws and SFC regulations
• Legitimate Interests: For business operations, fraud prevention, and service improvement

5. Data Sharing and Disclosure

We may share your personal data with:

• Service Providers: Third-party vendors assisting with technology, analytics, and operations
• Professional Advisors: Lawyers, auditors, and consultants bound by confidentiality
• Regulatory Bodies: Hong Kong SFC and other authorities when legally required
• Business Transfers: In case of merger, acquisition, or sale of assets

We do not sell, rent, or trade your personal data to third parties for marketing purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest (SSL/TLS, 256-bit encryption)
• Secure servers with restricted access controls
• Regular security audits and vulnerability assessments
• Employee training on data protection practices
• Multi-factor authentication for client portals

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by law. Specifically:

• Client Records: 7 years after service termination (SFC requirement)
• Marketing Inquiries: 3 years or until consent is withdrawn
• Website Analytics: 26 months (Google Analytics default)

8. Your Rights Under Hong Kong PDPO

You have the following rights regarding your personal data:

• Right to Access: Request copies of your personal data we hold
• Right to Correction: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Object: Opt-out of direct marketing communications
• Right to Data Portability: Receive your data in a structured format (where applicable)

To exercise these rights, please contact us at: info@capitalgrandinvestment.com

9. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to:

• Remember your language preference
• Analyze website traffic and user behavior
• Improve user experience and functionality

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

10. International Data Transfers

Your personal data is primarily stored and processed in Hong Kong. If we transfer data outside Hong Kong, we ensure adequate protection through:

• Standard contractual clauses
• Data processing agreements with service providers
• Compliance with cross-border data transfer regulations

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal data from minors.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. Continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Us

For questions or concerns about this Privacy Policy or your personal data, please contact:

Capital Grand Investment Limited
Data Protection Officer
Room 8-9, 9/F., Tower 1, W Mega
250-252 Texaco Road, Tsuen Wan, New Territories, Hong Kong
Email: info@capitalgrandinvestment.com
Phone: +852 1234 5678

14. Complaints

If you believe we have not complied with Hong Kong privacy laws, you may lodge a complaint with:

Office of the Privacy Commissioner for Personal Data
Address: 12/F, Sunlight Tower, 248 Queen's Road East, Wan Chai, Hong Kong
Hotline: +852 2827 2827
Website: www.capitalgrandinvestment.com