Privacy Policy

Persistent Asset Partners Limited ("we", "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 when you visit our website or engage with our services. We are regulated by the Securities and Futures Commission of Hong Kong and comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, as well as applicable international privacy standards including GDPR where relevant.

We may collect the following types of personal information: • Identity Information: Name, title, date of birth, nationality, and identification documents • Contact Information: Email address, telephone numbers, mailing address • Financial Information: Investment experience, source of funds, net worth, investment objectives • Professional Information: Employer details, job title, professional qualifications • Technical Data: IP address, browser type, device information, usage data when accessing our website • Communication Records: Correspondence and meeting notes with our team For institutional clients and family offices, we may also collect information about beneficial owners, directors, and authorized representatives as required by applicable regulations.

We use your personal information for the following purposes: • Service Delivery: To provide investment management and advisory services • Regulatory Compliance: To fulfill our obligations under securities laws, anti-money laundering regulations, and tax reporting requirements • Client Communication: To send you investment reports, market updates, and service-related communications • Risk Management: To assess suitability and appropriateness of investment products • Business Operations: To maintain accurate records and improve our services • Legal Purposes: To establish, exercise, or defend legal claims We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose.

We may share your personal information with: • Service Providers: Fund administrators, custodians, auditors, legal advisors, and IT service providers who assist in our operations • Regulatory Authorities: Securities and Futures Commission, Inland Revenue Department, and other regulatory bodies as required by law • Fund Managers: Underlying hedge fund managers in which we invest on your behalf • Professional Advisors: Accountants, lawyers, and consultants engaged for specific matters • Group Companies: Other entities within our corporate group for administrative purposes We require all third parties to respect the security of your personal data and to treat it in accordance with applicable laws. We do not sell or rent your personal information to third parties for marketing purposes.

Given the global nature of our investment activities, your personal data may be transferred to and processed in jurisdictions outside Hong Kong, including but not limited to the United States, European Union member states, and Mainland China. When transferring data internationally, we ensure appropriate safeguards are in place, including: • Standard contractual clauses approved by relevant authorities • Ensuring the recipient jurisdiction has adequate data protection laws • Obtaining your explicit consent where required For investments through our QFII license, certain information may be shared with the China Securities Regulatory Commission and other Mainland Chinese authorities as required by applicable regulations.

We have implemented appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include: • Encryption of sensitive data in transit and at rest • Access controls and authentication procedures • Regular security assessments and penetration testing • Employee training on data protection • Physical security measures at our offices • Incident response procedures While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but commit to promptly addressing any data breaches in accordance with applicable laws.

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including: • Active Clients: Throughout the duration of our business relationship • Former Clients: For a minimum of 7 years after the relationship ends, as required by securities regulations • Prospective Clients: For 2 years after last contact if no relationship is established • Regulatory Records: As required by applicable laws, which may be longer than 7 years for certain documents After the retention period expires, we will securely delete or anonymize your personal data unless further retention is required by law.

Under applicable privacy laws, you have the following rights: • Access: Request a copy of the personal data we hold about you • Correction: Request correction of inaccurate or incomplete data • Erasure: Request deletion of your data in certain circumstances • Restriction: Request limitation of processing in certain circumstances • Portability: Request transfer of your data to another service provider • Objection: Object to processing based on legitimate interests • Withdraw Consent: Withdraw consent where processing is based on consent To exercise these rights, please contact our Data Protection Officer. We will respond to your request within 40 days as required by Hong Kong law. Note that some rights may be limited where we have legal obligations to retain or process your data.

Our website uses cookies and similar tracking technologies to enhance your browsing experience. These include: • Essential Cookies: Necessary for website functionality • Analytics Cookies: Help us understand how visitors use our website • Preference Cookies: Remember your settings and preferences You can control cookie settings through your browser. However, disabling certain cookies may affect website functionality. We do not use cookies for advertising or tracking purposes beyond our website.

For questions about this Privacy Policy or to exercise your data protection rights, please contact: Data Protection Officer Persistent Asset Partners Limited Suite 1208, 12/F, One Pacific Place 88 Queensway, Hong Kong Email: hengshengzichan@gmail.com You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong, if you believe we have not handled your personal data in accordance with applicable laws.

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the updated policy on our website and, where appropriate, by direct communication. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.