Privacy Policy

ALLIANCE CHUAN GROUP (BVI) LIMITED — PRIVACY POLICY

Alliance CHUAN Group (BVI) Limited and its affiliates (collectively, "CHUAN," "Company," "we," "us," or "our") operates and provides access to the websites located at www.capitalchuan.com and www.chuanx.xyz, together with their content, subdomains, and any sites automatically redirected to them (collectively, the "Sites"). This Privacy Policy (this "Policy") describes how CHUAN collects, uses, discloses, retains, and otherwise processes Personal Information when you visit or interact with the Sites or otherwise engage with CHUAN (collectively, the "Services"), as well as the rights and choices individuals have regarding their Personal Information under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO") and other applicable laws.

ALLIANCE CHUAN Group (BVI) Limited is a company incorporated in the British Virgin Islands, with its registered office at Ritter House, Wickhams Cay II, PO Box 3170, Road Town, Tortola , and its principal place of business in Hong Kong at Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong. For the purposes of the PDPO, ALLIANCE CHUAN Group (BVI) Limited is a "data user" in respect of the Personal Information collected and processed subject to this Policy.

If you wish to contact CHUAN regarding your Personal Information, please contact our Data Protection Coordinator at: Email — operations@alliancechuan.com; Mail — Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong, Attn: Data Protection Coordinator.

By using the Sites or the Services, you agree that your Personal Information will be handled as described in this Policy. Your use of the Sites and any dispute over privacy are subject to this Policy and our Terms of Use, including the applicable limitations on damages and the resolution of disputes set forth therein. Our Terms of Use are incorporated by reference into this Policy. If you do not agree with this Policy, in general or any part of it, you should not access or use the Sites or the Services. Please read this Policy carefully so that you understand your rights in relation to your Personal Information and how your Personal Information will be collected, used, disclosed, and otherwise processed by us.

This Policy applies only to information collected through the Sites and the Services. Information collected in connection with investor onboarding, fund administration, or other services provided to investors in their capacity as investors of any investment vehicle managed or sponsored by CHUAN or its affiliates is subject to a separate Investor Privacy Notice, which is provided to investors at the time of onboarding or subscription.

1. Personal Information We Collect

1.1 "Personal Information" means any data that relates directly or indirectly to an identified or identifiable individual, including without limitation name, contact details, identification numbers, online identifiers, and any other information that, alone or in combination, can identify you. Personal Information does not include: (a) information that does not identify you, such as fully anonymized or aggregated data; or (b) information about you that is lawfully publicly available.

1.2 CHUAN generally collects Personal Information directly from you, and automatically through your use of the Sites and the Services.

1.3 Personal Information We Collect Directly From You

The Personal Information we collect from you depends on how you interact with the Sites and the Services, but generally includes the following:

• Contact Information. Name, institutional affiliation, postal address, email address, telephone number, and any other information you choose to provide when you contact us, request information, or submit an inquiry through the Sites.

• Communications Information. The content, subject line, and metadata of any communications you send to us, including emails, "Contact" form submissions, and any other correspondence.

• Investor-Related Information. If you are an investor or a representative of an investor, additional information may be collected in connection with anti-money-laundering checks, investor onboarding, and fund administration. Such information is subject to a separate Investor Privacy Notice.

1.4 Personal Information We Collect Automatically

We collect limited Personal Information automatically through basic, first-party cookies and similar technologies on the Sites. This information is limited to what is necessary for the operation and security of the Sites and may include: IP address; browser type and version; operating system; pages viewed and links clicked on the Sites; referring URL; date and time of access; and session duration.

We do not use Google Analytics or any other third-party analytics service. We do not use third-party advertising cookies, third-party tracking pixels, or any other third-party data-collection technologies on the Sites. For more information about the limited cookies we use, please see our Cookie Notice.

2. How We Use Personal Information

We use Personal Information collected through the Sites for the following purposes, or as otherwise notified to you at or before the time of collection:

• Operating Services and Providing Related Support. To provide and operate the Sites and the Services, communicate with you about your use of the Sites, verify eligibility to access restricted areas of the Sites, provide troubleshooting and technical support, respond to your inquiries, and for similar service and support purposes.

• Analytics and Improvement. To better understand how users access and use the Sites, evaluate and improve the Sites and our business operations, develop new services and features, and for internal quality control.

• Security and Protection of Rights. To protect the Sites and our business operations, to protect our rights or those of our stakeholders, to prevent and detect fraud, unauthorized activities, and other misuse, to conduct risk and security control and monitoring, and to investigate, prevent, or take action regarding illegal activities, suspected fraud, or violations of our Terms of Use.

• Compliance and Legal Process. To comply with applicable law and our legal obligations (including without limitation obligations under anti-money-laundering, counter-terrorism-financing, tax, and securities laws), and to respond to legal process and related legal proceedings.

• General Business and Operational Support. For the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

• Business Transfers. To consider, negotiate, and implement mergers, acquisitions, reorganizations, and other business transactions.

3. How We Disclose Personal Information

CHUAN does not sell, rent, lease, or otherwise commercially exploit your Personal Information. We disclose Personal Information only as described in this Policy, with your consent, or as required or permitted by applicable law.

3.1 Categories of Recipients

We disclose Personal Information to the following categories of recipients:

• Affiliates and Related Entities. We disclose Personal Information to our affiliates, parent companies, subsidiaries, and other entities under common control with CHUAN, including without limitation Alliance CHUAN Group (BVI) Limited and any direct or indirect subsidiary, branch, representative office, or affiliated investment vehicle (whether or not separately organized) in any jurisdiction. Such disclosure is made for the purposes described in Section 2 of this Policy.

• Investment Vehicles and Managed Funds. In connection with our investment management business, we may disclose Personal Information to the investment funds, vehicles, accounts, and other structures managed, sponsored, or advised by CHUAN or its affiliates, including without limitation general partners, managing members, trustees, directors, officers, employees, agents, and service providers of such investment vehicles, for the purposes of administering the relationship with the relevant investment vehicle, fulfilling regulatory and compliance obligations applicable to such vehicle, and operating, valuing, reporting on, and winding up the vehicle.

• Service Providers and Vendors. We disclose Personal Information to third-party service providers, vendors, contractors, and other entities that perform services on our behalf, including without limitation: (i) Hong Kong-based professional advisors, including auditors, accountants, legal counsel, tax advisors, and corporate-services providers; (ii) Hong Kong-based hosting, IT, and cybersecurity providers that support the operation of the Sites; and (iii) Hong Kong-based administrative and back-office service providers. Each such service provider is contractually obligated to use the Personal Information only for the purpose of providing services to CHUAN and to protect the Personal Information with at least the same level of security as CHUAN.

• Government Authorities, Regulators, and Law Enforcement. We may disclose Personal Information to government authorities, regulators, courts, tribunals, law enforcement agencies, or other public or quasi-public bodies in Hong Kong or elsewhere where we believe in good faith that such disclosure is: (i) required or authorized by applicable law, regulation, legal process, or governmental request (including without limitation requests from tax authorities, securities regulators, anti-money-laundering authorities, the Hong Kong Privacy Commissioner for Personal Data, and other competent authorities); (ii) necessary to enforce our agreements, policies, and terms of use; (iii) necessary to protect the security or integrity of the Sites; (iv) necessary to protect the property, rights, and safety of CHUAN, our users, or the public from harm or illegal activities; or (v) necessary to investigate and defend ourselves against any third-party claims or allegations.

• Professional Advisors. We may disclose Personal Information to our professional advisors, including without limitation our auditors, accountants, legal counsel, tax advisors, regulatory consultants, and other professional advisors, in connection with the rendering of professional services to CHUAN.

• Prospective Acquirers and Lenders (Business Transfers). If CHUAN undergoes a corporate change in control, merger, acquisition, reorganization, sale of all or a portion of its assets, financing, or similar business transaction, we reserve the right to transfer your Personal Information to the relevant counterparty, acquirer, successor, lender, or third-party advisor (including attorneys and consultants) in connection with such transaction, subject to confidentiality obligations no less protective than those set forth in this Policy.

• Other Disclosures. We may disclose Personal Information with your consent or at your direction, including without limitation when you direct us to share information with third-party service providers, counterparties, or other parties.

3.2 Purposes of Disclosure

We disclose Personal Information to the categories of recipients described above for the purposes set forth in Section 2 of this Policy.

3.3 No Sale or Commercial Exploitation

CHUAN does not sell, rent, lease, or otherwise commercially exploit your Personal Information for monetary or other valuable consideration. The disclosures described in this Section 3 are made for the purposes of operating CHUAN's business, providing the Services, or complying with legal obligations, and do not constitute sales, rentals, or "sharing" as those terms may be defined under applicable law.

3.4 Cross-Border Data Transfers

CHUAN is incorporated in the British Virgin Islands and operates from Hong Kong. Accordingly, your Personal Information may be transferred to, stored in, and processed in the British Virgin Islands and Hong Kong for the purposes set forth in this Policy.

The British Virgin Islands and Hong Kong have respective legal frameworks for the protection of personal data. If your Personal Information is collected in Hong Kong and transferred to the British Virgin Islands, we will ensure that the transfer is conducted in compliance with the PDPO and the BVI Data Protection Act, 2021 (or any successor legislation).

We do not transfer your Personal Information to jurisdictions other than the British Virgin Islands and Hong Kong, except: (i) with your express consent; (ii) as necessary to comply with applicable law or legal process; (iii) in connection with a business transfer as described in Section 3.1(f); or (iv) as otherwise permitted under the PDPO.

4. Links to Third-Party Sites

The Sites may contain links to third-party websites and applications. Any access to and use of such linked sites are not governed by this Policy but are instead governed by the privacy policies of those third parties. CHUAN is not responsible for the information practices of any third-party websites. Before visiting any third-party website or providing any Personal Information to any third party, you should inform yourself of the privacy policies and practices of such third party.

5. Security

We have implemented reasonable technical, administrative, and physical safeguards designed to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, in accordance with Data Protection Principle 4 (Security of Personal Data) under the PDPO. However, please be aware that, despite our efforts, no data security measures can guarantee absolute security. You are responsible for maintaining the confidentiality of your password and account credentials. CHUAN is not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

6. Retention of Personal Information

We retain Personal Information only for as long as necessary to achieve the purposes for which it was collected, as required by applicable law (including without limitation anti-money-laundering, counter-terrorism-financing, tax, and securities recordkeeping requirements), or as otherwise notified to you. Specific retention periods may vary depending on the type of Personal Information and the purposes of processing, and may include retention to comply with applicable law, to defend legal claims, or as otherwise necessary and proportionate to provide the Services.

7. Your Rights under the Hong Kong PDPO

If you are an individual whose Personal Information is collected and held by CHUAN in Hong Kong, you have the following rights under the Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO"):

7.1 Right of Access (Data Access Request)

You have the right to make a Data Access Request ("DAR") to ascertain whether CHUAN holds Personal Information about you, and if so, to request a copy of such Personal Information. CHUAN will respond to a DAR in accordance with the PDPO, generally within forty (40) days of receipt of the request and any applicable fee.

7.2 Right of Correction (Data Correction Request)

If you believe that any Personal Information CHUAN holds about you is inaccurate, you have the right to request that CHUAN correct such Personal Information by submitting a Data Correction Request ("DCR").

7.3 Right to Withdraw Consent

Where the processing of your Personal Information is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of any processing carried out before the withdrawal.

7.4 Direct Marketing

The PDPO imposes specific requirements on the use of Personal Information for direct marketing. CHUAN does not currently use your Personal Information collected through the Sites for direct marketing. Should we wish to do so in the future, we will: (i) obtain your prior express written consent (or other consent as required by the PDPO) before using your Personal Information for direct marketing; (ii) inform you of the types of Personal Information that will be used and the purposes for which it will be used; and (iii) provide you with an opportunity to opt out of further direct marketing communications.

You may, at any time, opt out of receiving direct marketing communications from CHUAN by contacting us at operations@alliancechuan.com.

7.5 Complaints to the Privacy Commissioner

If you believe that CHUAN has not handled your Personal Information in accordance with this Policy or the PDPO, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (the "PCPD"). However, we encourage you to contact us first at operations@alliancechuan.com so that we can attempt to resolve your concerns informally.

7.6 How to Exercise Your Rights

To exercise any of the rights described in this Section 7, please contact us at operations@alliancechuan.com. We may need to verify your identity before processing your request, and we may charge a fee as permitted by the PDPO for processing any Data Access Request.

8. Children

The Sites and the Services are not intended for users under the age of eighteen (18). We do not knowingly collect any Personal Information from children under 18. If we become aware that an individual submitting information is under 18, we will attempt to delete the information as soon as practicable.

9. Changes to this Policy

We reserve the right, in our sole discretion, to modify, alter, or otherwise update this Policy at any time. We will notify you of material changes to this Policy by posting the revised Policy with an updated "Last Updated" date on the Sites. Your continued use of the Sites or the Services after such changes constitutes your acceptance of the revised Policy. We encourage you to periodically review this Policy.

10. How to Contact Us

If you would like to contact us about this Policy, our privacy practices, or to exercise your rights under applicable law, please contact our Data Protection Coordinator: by email at operations@alliancechuan.com; by mail at Unit 1101, 11/F Standard Chartered Bank Building, 4-4A Des Voeux Road Central, Central, Hong Kong, Attn: Data Protection Coordinator.