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OTHER IMPORTANT NOTICES

DISCLAIMER - WEBSITE
The information contained in this website is provided for reference only and should not be treated as any professional advice. It is strongly recommended that specific advice should be sought where the circumstances require. Whilst Capital Focus Asset Management Limited and its affiliated companies (collectively referred to as "we", "us", "our" or the "Company") have used its best endeavours to ensure that the information contained in this website is accurate, complete and up-to-dated, the Company makes no representation as to its accuracy or completeness and expressly disclaims any liability whatsoever for any loss howsoever arising from or in reliance upon the whole or any part of such information.

The products and services set out in this website are only intended to be provided to persons in those jurisdictions where the Company can lawfully provide the same. Nothing in this website should be regarded as an offer or solicitation to sell the products or services to persons in any jurisdiction in which it would be unlawful for the Company to make such offer or solicitation. Any person intending to access this website should ensure that they are fully aware of all applicable legal requirements under the laws and regulations affecting them.

The information in this website does not constitute any representations, warranties or obligations binding on the Company who shall have absolute discretion to withdraw, vary, amend or supplement the services and products at any time without notice.

DISCLAIMER – INVEST YOUR MONEY
The information contained in the “Invest Your Money” page is provided for reference only and does not constitute a distribution, an offer to sell or a solicitation of an offer to invest. The information contained is solely for Hong Kong Professional Investors only. The term “Professional Investors” has the meaning as defined under the Securities and Futures Ordinance of Hong Kong.

INTERNET COMMUNICATIONS
Communication over the Internet may be subject to interruption, transmission blackout, delayed transmission or incorrect data transmission. The Company accepts no liability for any damages incurred by users as a result of any delay, loss, diversion, alteration or corruption of any communication either sent to or received from the Company at the user's request over the Internet. Under no circumstances will the Company be liable or bear the responsibilities for any loss or damages of any kind, whether direct, indirect, special, incidental or consequential losses, arising from accessing this website or otherwise.

Hyperlinks to other Internet resources are at your own risk. We do not investigate, verify, monitor or endorse the content, accuracy, opinions expressed, and other links provided by these sources.

It is your sole responsibility to prevent, safeguard and ensure that no computer virus enters your system and this website.

USE AND DISCLOSURE OF PERSONAL INFORMATION
Unless restricted by applicable law, you agree that any and all personal information/data relating to you collected by the Company from this website from time to time may be used and disclosed for such purposes and to such persons as may be in accordance with the Company’s current Data Privacy Policy.

INTELLECTUAL PROPERTY RIGHTS
All contents of this website are owned by the Company and are protected by applicable copyright and other intellectual property laws.

In the event of any inconsistency between the English and Chinese versions of these statements, the English version will prevail.

DATA PRIVACY POLICY

INTRODUCTION

This notice ("Notice") sets out the Data Privacy Policy adopted by Capital Focus Asset Management Limited and Protorn Capital Loans (together with their affiliated companies, collectively referred to as "we", "us", "our" or the "Company"). The purpose of this Notice is to establish the policies and practices of our commitment to protect the privacy of personal data and to act in compliance with the provisions of the Personal Data (Privacy) Ordinance (the "Ordinance") and implementation of the guidelines thereon issued by the Licensed Money Lenders Association. We will use our best endeavours to adhere to the Ordinance and the relevant governing principles.

References to "data subjects" in this Notice means the customers of the Company and various other persons, including without limitation, web site visitors, registered members of the Company, applicants for financial services & facilities, sureties and persons providing security or guarantee or any form of support for obligations owed to the Company, shareholders, directors, corporate officers and managers, sole proprietors, partners, suppliers, contractors, service providers and other contractual counterparties supplying data (including personal data as defined in the Ordinance) to the Company.

The information collected by Capital Focus through this website is shared with Protorn Capital Loans, a licenced money lender in Hong Kong for its use

1. PURPOSES OF THE PERSONAL DATA HELD
From time to time, it is necessary for customers to supply the Company with data in connection with the opening or continuation of accounts and the establishment or continuation of credit facilities or provision of credit facilities and related financial services and products and facilities.

Failure to supply such data may result in the Company being unable to open or continue accounts or establish or continue credit facilities or provide credit facilities and related financial services and products and facilities.

It is also the case that data are collected from customers in the ordinary course of the business for the purpose of processing of new or renewal of loan application or services either application in person, through telephone or internet. This includes information obtained from credit reference agency.

The purposes for which personal data relating to a customer may be used are as follows:

(a) the daily operation of the services and credit facilities provided to customers;
(b) assessing the merits and suitability of applicants for loan facilities and related financial services and / or processing and / or approving their applications, renewals and cancellations;
(c) conducting credit checks at the time of application for credit and at the time of regular or special reviews which normally will take place one or more times each year;
(d) creating and maintaining the Company's credit rating models;
(e) assisting other money lenders and / or financial institutions to conduct credit checks and collect debts;
(f) ensuring ongoing credit worthiness of customers;
(g) designing financial services or related products for customers' use;
(h) marketing financial or other services or products of the Company and / or selected companies as described in paragraph 7 below;
(i) determining the amounts owed to or by customers;
(j) collection of amounts outstanding from customers and those providing security for customers' obligations;
(k) meeting the requirements to make disclosure under the requirements of any law binding on the Company and for the purposes of any guidelines issued by regulatory or other authorities with which the Company is expected to comply;
(l) enabling the enforcement of customers' obligations, including without limitation, the collection of amounts outstanding from customers;
(m) complying with the internal policies, procedures, measures or arrangements of us for the use of data and information and for prevention or detection of money laundering, terrorist financing or other unlawful activities;
(n) comparing data of data subjects or other persons for credit checking, data verification or otherwise producing or verifying data, whether or not for the purpose of taking action against the data subjects;
(o) maintaining a credit history of the data subjects (whether or not there exists any relationship between the data subjects and us) for present and future reference;
(p) enabling an actual or proposed assignee of the Company, or participant or sub-participant of the Company's rights in respect of the customer to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation; and
(q) purposes relating thereto.

The Company keeps data only for as long as is reasonably required for the above purposes or as required by applicable law. This includes keeping, for as long as reasonably required, such data as required for handling enquiries relating to any of the above purposes. Also, the information collected by Capital Focus through this website is passed on to Protorn Capital Loans for its use.

2. SECURITY OF PERSONAL DATA
It is the policy of the Company to ensure an appropriate level of protection for personal data in order to prevent unauthorized access, processing or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by unauthorized access to that data. It is the practice of the Company to achieve appropriate levels of security protection by restricting physical access to data by providing secure storage facilities, and incorporating security measures into equipment in which data is held. Measures are taken to ensure the integrity, prudence, and competence of persons having access to personal data. Data is only transmitted by secure means.

3. ACCURACY OF PERSONAL DATA
It is the policy of the Company to ensure accuracy of all personal data collected and processed by the Company. Appropriate procedures are implemented to provide for all personal data to be regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. In so far as personal data held by the Company consists of statements of opinion, all reasonably practicable steps are taken to ensure that any facts cited in support of such statements of opinion are correct.

4. COLLECTION OF PERSONAL DATA
Personal data will be collected on-line and off-line by the Company for the purpose of conducting our business as set out in paragraph 1 above.

In relation to the collection of personal data on-line, the following practices are adopted:

(a) On-line Security

The Company will follow strict standards of security and confidentiality to protect any information provided to the Company online. Encryption technology is employed for sensitive data transmission on the Internet to protect individuals' privacy.

(b) Cookies

Cookies are small pieces of data transmitted from a web server to a web browser. Cookie data is stored on a local hard drive such that the web server can later read back the cookie data from a web browser. This is useful for allowing a website to maintain information on a particular user.

Cookies are designed to be read only by the website that provides them. Cookies cannot be used to obtain data from a user's hard drive, get a user's e-mail address or gather a user's sensitive information.

The Company will only use cookies as a session identifier and will not store user's sensitive information in cookies. Once a session is established, all the communications will use the cookies to identify a user. The cookies will expire once the session is closed. If users try to disable cookies from their web browsers, they may not be able to access the Company's Internet and other financial services.
Cookies may be placed on data subject's device by us or by third parties on our behalf (for example, advertising networks and providers of external services like web traffic analysis services). No personally identifiable information about data subject is collected or shared with third parties as a result of this.

Most web browsers are initially set up to accept cookies. Data subject can choose to 'not accept' cookies by changing the settings on his / her web browser but if he / she blocks all cookies, including strictly necessary cookies, he / she may find that certain features on our website will not work properly.

(c) On-line Correction

Personal data provided to the Company through an on-line facility, once submitted, it may not be facilitated to be deleted, corrected or updated on-line. If deletion, correction and updates are not allowed online, users should approach relevant departments.

(d) On-line Retention

Personal data collected on-line will be transferred to the Company's relevant departments for processing. Personal data will not be retained in web server's database of the Company.

5. HYPERLINK POLICY
The availability of hyperlinks or connection to other sites / addresses at the Company's website does not mean or imply any authentication, verification, representation, approval or endorsement by the Company of such hyperlinks, connection, or the identity or information relating to such sites / addresses.

The Company expressly disclaims any responsibility for such hyperlinks, connection, contents, availability, accuracy or omission of information at other sites / addresses linked to or found on the sites / addresses that link to or from our website.

All hyperlinks or connection to other sites, addresses or resources are accessed and used at your own risks.

6. DISCLOSURE OF PERSONAL DATA
All personal data held by us will be kept confidential but we may, for the purposes set out in the paragraph 1 above, provide and disclose such information to the following parties:

(a) any agent, contractor or third party service provider who provides administrative, professional advisory, telecommunication, information service, computer, payment, data processing, debt collection or other services to the Company in connection with the operation of its business, wherever situated;
(b) any other person who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential;
(c) credit reference agencies and, in the event of default, debt collection agencies;
(d) any person to whom we are under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applicable to us, or any disclosure under and for the purposes of any guidelines, guidance or codes of practice published, given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial service providers with which we are expected to comply, or any disclosure pursuant to any contractual or other commitment of us with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or relevant self-regulatory or industry bodies or associations, all of which may be within or outside Hong Kong and may be existing currently or in the future;
(e) any actual or proposed assignee, transferee or participant or sub-participant of our rights in respect of the data subjects;
(f) subject to the Company receiving data subject's consent, we may provide and disclose personal data held by us to the following persons:
- i. third party financial institutions, insurers, credit card companies, securities, commodities and investment services providers; and
- ii. external service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that we may engage for the purposes set out in paragraph 1 above, wherever situated.

Such information collected in Hong Kong by us may be transferred to places outside Hong Kong in order to carry out the purposes, or directly related purposes, for which the personal data were collected.

7. DIRECT MARKETING
We intend to use a data subject's data to conduct direct marketing of products or services and require the data subject's consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

(a) the name, contact details, products and other service portfolio information, transaction pattern and behaviour, financial background and demographic data of a data subject held by us from time to time may be used by us in direct marketing;
(b) the classes of services, products and subjects which may be marketed includes credit / loan facilities and related financial services and products;
(c) the above services, products and subjects may be provided by us and / or third party financial institutions, insurers, securities and investment services providers;
(d) in addition to marketing the above services, products and subjects itself, we also intend to provide the data described in paragraph 7(a) above to all or any of the persons described in paragraph 7(c) above for use by them in marketing those services, products and subjects, and we require the data subject's written consent (which includes an indication of no objection) for that purpose; and
(e) we may receive money or other property or benefit in return for providing the data to the other persons in paragraph 7(d) above. We will inform the data subject if it will receive money or other property or benefit in return for providing the data to the other persons.

If a data subject does not wish us to use or provide to the other person his or her data for use in direct marketing as described above, the data subject may exercise his / her opt-out right by notifying us by ticking the appropriate box(es) in the application form indicating such objection and / or contacting our Data Protection Officer ("DPO"). A data subject may, at any time and without charge, choose not to receive any direct marketing material or message from us by informing our DPO (whose contact details are set out below) in writing.

8. DATA ACCESS REQUESTS AND DATA CORRECTION REQUESTS
It is the policy of the Company to comply with and process all data access and correction requests in accordance with the provisions of the Ordinance, and for all staff concerned to be familiar with the requirements for assisting individuals to make such requests.

The Company may, subject to the Ordinance, impose a moderate fee for complying with a data access request. If a person making a data access request requires an additional copy of the personal data that the Company has previously supplied pursuant to an earlier data access request, the Company may charge a fee to cover the full administrative and other costs incurred in supplying that additional copy.

In the event of any default of payment relating to an account, unless the amount in default is fully repaid or written off (other than due to a bankruptcy order) before the expiry of 60 days from the date such default occurred, the account repayment data may be retained by the credit reference agency until expiry of 5 years from the date of final settlement of the amount in default. Account repayment data includes amount last due, amount of payment made during the last reporting period (being a period not exceeding 31 days immediately preceding the last contribution of account data by the Company to a credit reference agency), remaining available credit or outstanding balance, and default data (being amount past due and number of days past due, date of settlement of amount past due, and date of final settlement of amount in default lasting in excess of 60 days (if any)).

In the event any amount in an account is written off due to a bankruptcy order being made against the data subject, the account repayment data (as defined in the paragraph above) may be retained by the credit reference agency, regardless of whether the account repayment data reveal any default of payment lasting in excess of 60 days, until expiry of 5 years from the date of final settlement of the amount in default or expiry of 5 years from the date of discharge from bankruptcy as notified by the data subject with evidence to the credit reference agency, whichever is earlier.

Data access and correction requests to the Company may be addressed to the DPO or other person as specifically advised.

9. APPOINTMENT OF DATA PROTECTION OFFICER
Internal policies and guidelines on compliance with the Ordinance for use by staff of the Company has been maintained by us and to co-ordinate and oversee compliance with the Ordinance and the personal data protection policies of the Company, a DPO has been appointed by the Company.

The contact details of the DPO are as follows:

Room 1801, 18/F, Lee Garden Five, 18 Hysan Avenue, Hong Kong.

In the event of any inconsistency between the English and Chinese versions of these statements, the English version will prevail.

Application

Family Name*

First name*

HKID*

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Date of Birth*

Mobile*

Email*

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Loan Amount(HKD＄)*

Personal Loan Application Declaration

I understand and agree to the Terms & Conditions And Key Facts Statement for Protorn Capital Loans Personal Loan, Policy Statement relating to the Personal Data (Privacy) Ordinance (“Policy Statement”), all the terms, conditions and disclosures in this form. I understand that Protorn Capital Loans will review my credit report from the Credit Reference Agency in assessing this application. I further agree and confirm to authorize “Protorn Capital Loans” as below:

1. I hereby give my consent to Protorn Capital Loans to transfer all or part of my information provided above (“the Information”) to Credit Reference Agency for the purpose of matching the Information against the data held in the database of Credit Reference Agency from time to time in order to verify my identity. I acknowledge that Protorn Capital Loans will not process, record or keep any of the Information in any manner.

I further give my consent to and authorize Credit Reference Agency to access all or part of my consumer credit data which may be held in its database from time to time (“My Credit Data”) and to
(i)match all or part of My Credit Data against the Information transferred by Protorn Capital Loans to Credit Reference Agency; and
(ii)generate questions directly or indirectly from any or all of the information contained in My Credit Data whether on its own or in conjunction with other source of information, collect responses to such questions from me and match such responses against any information contained in My Credit Data;

for the purpose of verifying my identity as part of assessment of my credit related risks in relation to my application use, process and match all information, including but not limited to any photo images or documents, I provided for the purpose of verifying my identity in the process of account opening only and thereafter to process, use and transfer the result of the verification or any data arising therefrom to Protorn Capital Loans; and I further acknowledge and agree that the access and use of My Credit Data by Credit Reference Agency in the manner described above shall not be made the basis for any complaint, claim, suit, demand or cause of action or other proceedings against Credit Reference Agency by me.

I declare that all the information provided in this form is true, accurate and complete. I understand that Protorn Capital Loans will only update any change to my existing records (if applicable) after successful identity verification and I will update you immediately on any subsequent changes to the above information. I authorize you to verify the above information from and/or exchange it with any source. I also declare that
1. I am not bankrupt;
2. No petition for bankruptcy is presented against me;
3. I am not insolvent
4. No application by me or any other person for an interim order for making a debtor's proposal for voluntary arrangements.
I also understand that the Policy Statement form an integral part of this form and shall be deemed incorporated into this form, all contracts, account mandates and other binding arrangements which I have entered into or intended to enter into with you.
I agree to your recording all my telephone conversations with you. In any event, you may refuse to accept this application in the light of my individual circumstances.
I understand that Protorn Capital Loans Personal Loan is offered by Protorn Capital Loans.
I acknowledge that the email provided will be used for electronic communication for this application, that electronic messages may contain viruses or may be delayed and that there are confidentiality and other risks associated with the delivery of customer communication.
6. I also agree that Protorn Capital Loans shall not be held responsible for any of these occurrences or for any unauthorized access and/or alteration to any e-mail communication. All electronic communications will be deemed to have been received by me on the day that Protorn Capital Loans sends the e-mail to the relevant e-mail address, even if the recipient does not access the electronic communication for any reason
I understand that you, your employees, your authorized agents or any of your affiliates may act in different capacities, and may be remunerated, or may receive benefits or profits, either directly or indirectly in connection with the services provided. The remuneration of your employees or authorized agents may comprise a fixed pay and/or a variable compensation which is determined by a number of factors including the sales performance.
I understand that in the event of any default in repayment, unless the amount in default is fully repaid before the expiry of 60 days from the date such default occurred, my account data may be retained by the credit reference agency until the expiry of 5 years from the date of final settlement of the amount in default.
Upon termination of the account by full repayment and on condition that there has not been, within 5 years immediately before account termination, any material default on the account, I shall have the right to instruct Protorn Capital Loans to make a request to the credit reference agency to delete from its database any account data relating to my terminated account.
To help prevent money laundering and terrorist financing, I understand the laws of many jurisdictions, as well as the Protorn Capital Loans’s policy, require Protorn Capital Loans to obtain, verify, and record information that identifies me. When I apply for Protorn Capital Loans Personal Loan, I will be asked for my name, address, date of birth, and other information that will allow Protorn Capital Loans to identify me. I may also be asked to see and retain a copy of my photo ID or other identifying documents.
I am also consenting to submit my personal loan application, to being contacted by Protorn Capital Loans staff and to provide other personal information and to complete my application over the phone when he/she contacts me

With respect to this form and any other relevant documents, in case of any discrepancy between the English and Chinese version, the English version shall prevail.

I have agreed the above Declarations, Terms and Conditions.

By checking this box, I confirm that I have read, understood and agreed to the Personal Loan Application Declaration.By clicking the "SUBMIT" button, I confirm that I wish to apply for the product that I have selected above and understand that Protorn Capital Loans will review my credit report from the Credit Reference Agency in assessing this application.

Registration signifies that you have read and agreed to the terms and conditions of our
Important Notice and Personal Data Privacy Policy.。

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Investment Enquiry

Surname*

First Name*

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Remarks

Personal Loan Application Declaration

1. I hereby give my consent to Protorn Capital Loans to transfer all or part of my information provided above (“the Information”) to Credit Reference Agency for the purpose of matching the Information against the data held in the database of Credit Reference Agency from time to time in order to verify my identity. I acknowledge that Protorn Capital Loans will not process, record or keep any of the Information in any manner.

I further give my consent to and authorize Credit Reference Agency to access all or part of my consumer credit data which may be held in its database from time to time (“My Credit Data”) and to
(i)match all or part of My Credit Data against the Information transferred by Protorn Capital Loans to Credit Reference Agency; and
(ii)generate questions directly or indirectly from any or all of the information contained in My Credit Data whether on its own or in conjunction with other source of information, collect responses to such questions from me and match such responses against any information contained in My Credit Data;

for the purpose of verifying my identity as part of assessment of my credit related risks in relation to my application use, process and match all information, including but not limited to any photo images or documents, I provided for the purpose of verifying my identity in the process of account opening only and thereafter to process, use and transfer the result of the verification or any data arising therefrom to Protorn Capital Loans; and I further acknowledge and agree that the access and use of My Credit Data by Credit Reference Agency in the manner described above shall not be made the basis for any complaint, claim, suit, demand or cause of action or other proceedings against Credit Reference Agency by me.

I declare that all the information provided in this form is true, accurate and complete. I understand that Protorn Capital Loans will only update any change to my existing records (if applicable) after successful identity verification and I will update you immediately on any subsequent changes to the above information. I authorize you to verify the above information from and/or exchange it with any source. I also declare that
1. I am not bankrupt;
2. No petition for bankruptcy is presented against me;
3. I am not insolvent
4. No application by me or any other person for an interim order for making a debtor's proposal for voluntary arrangements.
I also understand that the Policy Statement form an integral part of this form and shall be deemed incorporated into this form, all contracts, account mandates and other binding arrangements which I have entered into or intended to enter into with you.
I agree to your recording all my telephone conversations with you. In any event, you may refuse to accept this application in the light of my individual circumstances.
I understand that Protorn Capital Loans Personal Loan is offered by Protorn Capital Loans.
I acknowledge that the email provided will be used for electronic communication for this application, that electronic messages may contain viruses or may be delayed and that there are confidentiality and other risks associated with the delivery of customer communication.
6. I also agree that Protorn Capital Loans shall not be held responsible for any of these occurrences or for any unauthorized access and/or alteration to any e-mail communication. All electronic communications will be deemed to have been received by me on the day that Protorn Capital Loans sends the e-mail to the relevant e-mail address, even if the recipient does not access the electronic communication for any reason
I understand that you, your employees, your authorized agents or any of your affiliates may act in different capacities, and may be remunerated, or may receive benefits or profits, either directly or indirectly in connection with the services provided. The remuneration of your employees or authorized agents may comprise a fixed pay and/or a variable compensation which is determined by a number of factors including the sales performance.
I understand that in the event of any default in repayment, unless the amount in default is fully repaid before the expiry of 60 days from the date such default occurred, my account data may be retained by the credit reference agency until the expiry of 5 years from the date of final settlement of the amount in default.
Upon termination of the account by full repayment and on condition that there has not been, within 5 years immediately before account termination, any material default on the account, I shall have the right to instruct Protorn Capital Loans to make a request to the credit reference agency to delete from its database any account data relating to my terminated account.
To help prevent money laundering and terrorist financing, I understand the laws of many jurisdictions, as well as the Protorn Capital Loans’s policy, require Protorn Capital Loans to obtain, verify, and record information that identifies me. When I apply for Protorn Capital Loans Personal Loan, I will be asked for my name, address, date of birth, and other information that will allow Protorn Capital Loans to identify me. I may also be asked to see and retain a copy of my photo ID or other identifying documents.
I am also consenting to submit my personal loan application, to being contacted by Protorn Capital Loans staff and to provide other personal information and to complete my application over the phone when he/she contacts me

With respect to this form and any other relevant documents, in case of any discrepancy between the English and Chinese version, the English version shall prevail.

I confirm that I am a Professional Investor as defined within the meaning of the Securities and Futures Ordinance of Hong Kong. I would like to obtain more information on the Protorn Capital Loans Consumer Debt Fund..

Registration signifies that you have read and agreed to the terms and conditions of our
Important Notice and Personal Data Privacy Policy.

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Testimonials

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Jocab

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Gareth. Z, Consultant