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Privacy Policy





Central X Limited (“Company”) is committed to protecting and respecting your privacy.


This policy applies as between you, the User of the website, and Company, as the owner and provider of (“Website”). This policy (together with our “Terms and Conditions”, “Terms of Website Use” and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by the Company. Please read the following carefully to understand our views and practices regarding your personal data.


1.   Definition and Interpretation


In this Policy the following terms shall have the following meanings:


“Data”                              means collectively all information that you submit to the Company via the Website. This definition shall, where applicable, incorporate the definitions                                                provided in Hong Kong Personal Data (Privacy) Ordinance (“PDPO”);

“Cookie”                          means a small text file placed on your computer by this Website when you visit certain parts of the website and/or when you use certain features of the                                            Website. Details of the cookies used by this Website are set out in Clause 14;

“Company ”                    means Central X Limited with the Hong Kong Company Number 2295665;

“User”                              means any third party that accesses the website and is not employed by the Company and acting in the course of their employment; and

“Website”                        means the website that you are currently using and any sub-domains, sister domains of this site unless expressly excluded by                                          their own terms and conditions.


2. Scope of this Policy

This Policy applies only to the actions of the Company and users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.


3. Data Collected

Without limitation, any of the following data may be collected by this Website from time to time:


  1. Name;

  2. Date of Birth;

  3. Gender;

  4. Job Title;

  5. Profession;

  6. Contact information such as email addresses; telephone/mobile numbers; residential address and profile details from social media;

  7. Demographic information such as post code, preferences and interests;

  8. Financial information such as credit/debit card numbers; bank details; e-money details such as [e-money providers] etc. business plan of financial information; company accounts;

  9. IP address (automatically collected);

  10. Web browser type and version (automatically collected);

  11. Operating system (automatically collected);

  12. A list of URLs starting with a referring site, your activity on this site, and the site you exit to (automatically collected);

  13. Other information that may be collected but not limited to are court judgments; personal and business credit rating; anti-money laundering details; social media details; Companies Registry; records of payments and services used by the Company.


4. Our Use of Data

Any personal data you submit will be retained by the Company during your use of the Website and a minimum of 7 years [H1] after deleting your account. The data shall be used for the following purposes:


  1. for the specific purpose for which the information was provided;

  2. to confirm your identity and ensure that you are eligible to access and use the services provided on the website;

  3. to process and, where necessary, respond to your application(s), enquiry(s), or request(s);

  4. to conduct due diligence checks on you in accordance with all applicable laws and Company's internal 'Know Your Client' and Anti-Money Laundering/Countering the Financing of Terrorism policies;

  5. to verify and approve the disclosures entrepreneurs seeking capital for their business through Company's platform make to potential investors;

  6. to enable Company to comply with all of its legal and regulatory obligations;

  7. to inform or update you about products, or services that you request from Company or that may interest you, where you have consented to be contacted for such purposes;

  8. to update you about changes to the website or Company's operations;

  9. to monitor, improve, and administer the Site and the services provided through it, and conduct statistical or other forms of analysis for purposes of maintaining or improving the Site and Company's services in general; or

  10. to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency.


4.2 All personal data is stored securely in accordance with the Data Protection Principles in the Hong Kong PDPO. For more details on security see Clause 13 below.


4.3 Any or all of the above data may be required by us from time to time in order to provide you with the best possible service and experience when using the Website. Specifically, Data may be used by us for the following reasons:

  1. Internal record keeping;

  2. Improvement of our products / services;

  3. Transmission by email of promotional materials that may be of interest to you;

  4. Contact for market research purposes which may be done using email, telephone, fax or mail. Such information may be used to customise or update the website.


5. Disclosure and Other Third Party Agreements


5.1 Unless we are obliged or permitted by law to do so, and subject to Clause 5, your Data will not be disclosed to third parties. This does not include our affiliates and / or other companies within our group. Data may be disclosed in the following circumstances:

  1. you have expressly or implicitly consented to such disclosure, or may be deemed to have consented to such disclosure;

  2. such disclosure is a necessary part of the process of sale of shares or venture M&A;

  3. necessary to provide you with the products and/or services you have requested for, or to respond to your queries;

  4. necessary for the operation of the Site or Company's internal processes;

  5. required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;

  6. Company believes, in good faith, that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Site, Company's interests, or any Company employee;

  7. Company is the subject of a takeover and your personal information forms part of Company's assets to be transferred to the acquiring entity; or

  8. you disclose such information to third parties in the course of participating in any competitions or promotional programmes on the Site.


5.2 You will have the option to make certain data on your profile public for logged in users only, for contacts only, or you have the option to select your profile to be private. Certain details will be shared with shareholders should you back or invest in a pitch that raises funds in order to deliver your rewards or register you as an investor.


5.3 Company may use credit / ID agencies to perform a search on individuals. This search will not be visible to members and will not impact your own credit rating. The search will be performed only with your prior permission.


5.4 The Website will also perform ID verification on all investors and pitch team members. Copies of ID’s are stored in our servers in compliance with this privacy policy. Your status as a verified member may be public information depending on your privacy settings. It will also be used for the assessment of User account[H2] applications, anti-money laundering, client due diligence, counter terrorism financing checks and your qualification as an investor.


6. Other Agreements


6.1 In addition to this privacy policy, our Terms and Conditions, Disclaimers and Risk Warnings apply to you and everyone else who uses the Website. We refer to the Terms of Service, Risk Warnings, Disclaimers and this privacy policy together as the Website Agreements.


6.2 During the course of your use of the Website you may choose to agree to be bound by certain other agreements: for example, if you wish to invest in a business and or individual through the Website, you will need to agree to the relevant investment agreement. We refer to all of these other agreements as the Other Agreements.


6.3 The Website Agreements will continue to apply to you even after you have agreed to any Other Agreements.


7. Third Party Websites and Services


7.1 The Website may, from time to time, employ the services of other parties for dealing with matters that may include, but are not limited to: payment processing, delivery of purchased items including electronic online training programmes, search engine facilities, advertising and marketing. The providers of such services may have access to certain personal data provided by users of this website.


7.2 Any data used by such parties is used only to the extent required by them to perform the services that the Website requests. Any use for other purposes is strictly prohibited. Furthermore, any data that is processed by third parties shall be processed within the terms of this policy and in accordance with Hong Kong common law and the PDPO.


8. Links to Other Websites

The Website may, from time to time, provide links to other websites. The Website has no control over such websites and is in no way responsible for the content thereof. This policy does not extend to your use of such websites. Users are advised to read the privacy policy or statement of other websites prior to using them.


9. Changes of Business Ownership and Control


9.1 Company may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Company. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this policy, be permitted to use the data for the purposes for which it was originally supplied to us.


9.2 In the event that any data submitted by users is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. You will not be given the choice to have your data deleted or withheld from the new owner or controller.


10. Controlling Use of Your Data

In the event of a potential transaction that you indicate to make, you agree for us to provide your full name, email address and contact details to the buyer or seller of the potential transaction, to use this information in order to deliver your necessary agreements. Wherever you are required to submit data, you will be given options to restrict our use of that data. This may include the following:

  1. Use of Data for direct marketing purposes;

  2. andSharing data with third parties.


11. Your right to withhold information


11.1 You may access certain areas of the Website without providing any data at all. However, to use all features and functions available on the Website you may be required to submit certain data.


11.2 You may restrict your internet browser’s use of Cookies. For more information, see Clause 14.


12. Accessing your own Data

You have the right to ask for a copy of any of your personal data held by Company (where such data is held) on payment of a fee which will be determined by the Company from time to time.


13. Security


13.1 Data security is of great importance to Company and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected via the Website. Company has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of your information.


13.2 Nevertheless, you acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to Company is done so at your own risk. Company does not warrant or guarantee that the information you provide will not be accessed, copied, used, or disposed of in breach of Company's security measures, and you agree not to hold Company liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, Company will, as far as reasonably possible, promptly notify all affected persons. You accept that you are responsible for keeping confidential your username and password to your account with Company.


14. Cookies


14.1 This Website may place and access certain first party cookies on your computer. First party cookies are those placed directly by Company via this Website and are used only by the Website. The Website uses cookies to improve your experience of using the Website and to improve our range of products and services. The Website has carefully chosen these cookies and has taken steps to ensure that your privacy is protected and respected at all times.


14.2 All Cookies used by this Website are used in accordance with the Hong Kong laws, including the PDPO.


14.3 We use the following cookies:

  1. Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, using Company's online payment services.

  2. Analytical/performance cookies. They allow Company to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Company to improve the way the Website works, for example, by ensuring that users are able to use custom features.

  3. Functionality cookies. These are used to recognise you when you return to our Website. This enables Company to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  4. Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. Company will use this information to make the Website and the advertisements targeted more relevant to your interests. Company may also share this information with third parties for this purpose.

  5. By using this Website, you may receive certain third party cookies on your computer. Third party cookies are those placed by Websites and/or parties other than the Website. Third party cookies are used on this Website for external social media profiles, and are detailed in full below. These cookies are not integral to the services provided by the Website.


14.4 You can choose to enable or disable cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.


14.5 You can choose to delete cookies at any time however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.


14.6 It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.


15. Changes to this Policy


Company reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.  


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