Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to all products and services offered by EASTAR ASSET MANAGEMENT LIMITED ("GeneX," "we," or "us"). If you have any questions about this Policy, please feel free to contact us through our website or email us at info@eastarasset.com.

At EASTAR ASSET MANAGEMENT LIMITED, we respect the privacy rights and data protection rights of users. Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information.

2. Your Rights

We commit to protecting your individual rights, in line with the GDPR 2016/679, as follows:

• Right to be Informed: You have the right to clear, transparent information about how we collect and use your personal data.
• Right to Access: You can request a copy of all personal data we hold about you within 30 days.
• Right to Rectification: If you believe any information we hold is inaccurate or incomplete, you may request corrections.
• Right to Erasure: Also known as the "right to be forgotten," you can request deletion of your personal data.
• Right to Restriction of Processing: You can request that we restrict processing of your personal data under certain circumstances.
• Right to Data Portability: You can request to receive your personal data in a structured, commonly used format.
• Right to Object: You have the right to object to processing of your personal data for direct marketing purposes.
• Rights Related to Automated Decision Making: You have the right not to be subject to decisions based solely on automated processing.

To exercise any of these rights, please contact our Data Protection Officer at info@eastarasset.com or submit a request through our Data Subject Rights Portal in your account settings.

3. Data Controller

EASTAR ASSET MANAGEMENT LIMITED, registered office in Hong Kong, Wanchai Central Building 89 Lockhart Road, Flat/RM 401, is the Data Controller. As used in this Privacy Policy, "GeneX," "us" and "we" refers to EASTAR ASSET MANAGEMENT LIMITED SRL. The "Websites" means EASTAR ASSET MANAGEMENT LIMITED's websites and the "Services" means EASTAR ASSET MANAGEMENT LIMITED's communications and messaging products, applications and services, collectively referred to as the "Products."

4. Data Collection

A. Information Related to Your Interaction with GeneX

• Registration and Contact Information: We collect information when you register or provide contact information, including username, name, email address, mailing address, or phone number.
• Payment Information: When you purchase Services, we collect transaction information, including credit card details, billing and mailing address.
• Technical, Usage, and Location Information: We automatically collect information on how you interact with the Products, such as IP address, date and time, browser information, operating system, pages viewed, and items clicked.
• Third-Party Platform Information: We may collect information when you interact with our advertisements and content on third-party sites or platforms.

B. Customer Data

You may submit various types of information and data into the Services for hosting and processing purposes ("Customer Data"). Customer Data may include personal information such as names, email addresses, phone numbers, and information contained in communications between you and your customers using our Services.

We will only use, disclose, and otherwise process Customer Data for the purposes set forth in your agreement with us for the provisioning of the Services.

5. Sources of Information

• From You: You are the primary source of the personal information we collect.
• From other sources: We obtain personal information from other users who submit Customer Data to us and from Third Party Platforms.

6. Data Use

We use your information in the following ways:

• To provide, maintain, and improve the Products and our other products and services
• To process your inquiries and deliver customer service
• To process your payments
• To control unauthorized use or prevent activities that may violate our policies
• To analyze trends and gather demographic information
• To communicate directly with you, including sending newsletters and promotions

7. Data Retention

GeneX implements a structured data retention framework:

• Active Account Data: We retain personal data for as long as you maintain an active GeneX account.
• Inactive Accounts: If your account becomes inactive for 24 months, we will notify you 30 days before archiving your data.
• Post-Termination Retention: After account termination, we retain certain data for up to 12 months for legal compliance and dispute resolution.
• Data Deletion Process: When retention periods expire, we implement a secure deletion process.
• Customer-Requested Deletion: You can request immediate deletion of your data at any time, which will be processed within 30 days.

8. Third Party Data Use

We do not share or transfer your personal information to third parties except in the following limited circumstances:

• With our parent companies, subsidiaries, and affiliates
• With third-party service providers to permit such parties to provide services
• To facilitate the delivery of interest-based ads
• When we have a good faith belief that disclosure is necessary to satisfy any applicable law or legal process
• To detect, prevent, or address fraud or security issues
• With business partners who offer a service to you jointly with us
• To process your payments
• If we become involved in a merger, acquisition, or sale of assets
• With a third party if we have your consent

9. Your Controls and Choices

• Opt-Outs: You may opt out of having your personal information used for certain purposes.
• Communication Preferences: You can opt out of receiving our newsletter and promotional communications.
• Data Subject Rights: You can access, rectify, erase, restrict, or export your personal information at any time by emailing us at info@eastarasset.com.
• Data Portability: You have the right to have your personal data downloaded in a portable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority.

10. Security

We maintain appropriate technical and organizational safeguards to protect your personal information. When you enter sensitive information, we encrypt that information in transit using industry-standard Transport Layer Security (TLS) encryption technology. No method of transmission over the Internet is one hundred percent secure, but we strive to use reasonable efforts to protect your personal information.

11. Personal Data Location

All our data is stored on servers located in Hong Kong.

12. No Children Under Age 16

The Products are not intended for use by anyone under the age of 16, nor does GeneX knowingly collect or solicit personal information from anyone under the age of 16.

13. Changes to the Privacy Policy

We reserve the right to change our Privacy Policy at any time. If we make material changes to this policy, we will notify you by email or through notice on the Products.

14. Contact Information

If you have questions or need to contact us about this Privacy Policy, please email us at info@eastarasset.com.