Privacy Policy

1. Introduction

Lux Capital (Int.) Limited ("Lux Capital", "we", "us" or "our") respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose and safeguard your information when you:

• Visit our website at https://www.lux-capital.io (the "Website");
• Use any products, services, features, content, tools or applications we make available (collectively, the "Services"); or
• Otherwise interact with us (for example, by email, phone or in person).

By accessing or using our Website or Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Privacy Policy, you should discontinue use of the Website and Services.

This Privacy Policy is intended to comply with applicable data protection laws, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and, where applicable, certain requirements under the EU General Data Protection Regulation (GDPR) and the UK GDPR.

2. Data Controller

The data controller responsible for your personal data is:

3. Information We Collect

We may collect information that identifies you or can be associated with you ("personal data"), as well as non-identifying information.

3.1 Information You Provide

We collect information you voluntarily provide, for example when you:

• Contact us via the Website, email, phone or other channels;
• Subscribe to newsletters or updates;
• Request information about our products, services or investment opportunities;
• Provide information as part of a business, investment, partnership or employment enquiry;
• Otherwise choose to provide information to us.

This may include:

• Identification and contact details: name, email address, phone number, postal address, country/region of residence, company name, job title;
• Business and professional information: information about your company, role, investment profile, and industry interests;
• Account or access details (if applicable): username, password, and related information for any portal we may provide;
• Other information: content of your communications, forms, questionnaires, pitch decks and proposals.

You are not required to provide the personal data we request. However, if you choose not to, we may not be able to respond to your enquiries or provide certain Services.

3.2 Information Collected Automatically

When you visit or interact with our Website, we may automatically collect:

• Technical data: IP address, browser type and version, operating system, device identifiers, language settings, and time zone;
• Usage data: pages and content viewed, links clicked, referring and exit pages, length of visits and browsing patterns;
• Log information: dates and times of access, error logs and other diagnostic data.

This information is typically collected using cookies and similar technologies (see Section 5).

3.3 Information from Third Parties

We may receive information about you from:

• Service providers (e.g. analytics, hosting and communication providers);
• Business partners and professional networks;
• Publicly available sources, such as company websites, professional profiles, regulatory filings and public registers.

We treat this information in accordance with this Privacy Policy and applicable laws.

4. How We Use Your Information

We process your personal data for the purposes set out below. Under the PDPO, we process your data for purposes directly related to our functions or activities. Where GDPR/UK GDPR applies, we rely on one or more of the following legal bases: performance of a contract, legal obligation, legitimate interests or your consent.

We may use your information to:

• Provide and operate our Services - Manage and respond to enquiries, proposals, and business or investment discussions; provide information or materials you request; and communicate in relation to engagements, agreements or transactions.
• Communicate with you - Respond to emails and other communications; send administrative messages, such as important notices relating to this Privacy Policy or our terms.
• Send marketing and business communications - Provide news, updates, insights, invitations to events, and information about our activities that we think may be of interest to you. You can opt out at any time (see Section 9.3).
• Manage relationships with partners, investors, founders and other stakeholders - Evaluate potential investments, partnerships or collaboration opportunities; maintain records of engagements and communications.
• Operate, maintain and improve our Website and Services - Analyse usage, monitor performance, troubleshoot issues, improve user experience and enhance security, including prevention of misuse and fraud.
• Comply with legal and regulatory obligations - Comply with applicable laws and regulations, regulatory reporting, compliance checks, due diligence and record-keeping; respond to lawful requests and legal processes.
• Other purposes with your consent - Where you have given specific consent for a particular use of your data.

5. Cookies and Similar Technologies

5.1 Use of Cookies

Our Website may use cookies and similar technologies to collect and store certain information when you access or use the Website. Cookies are small text files placed on your device that help us:

• Recognise your browser or device;
• Understand how you use the Website;
• Improve performance and functionality; and
• Provide a better user experience.

Depending on our configuration, we may use:

• Strictly necessary cookies: required for the operation of the Website;
• Analytics and performance cookies: help us measure and understand how visitors use the Website (e.g. page views, traffic sources);
• Functionality cookies: remember your preferences and settings.

We do not currently use cookies for behaviour-based advertising on the Website. If this changes, we will update this Privacy Policy and, where required, request your consent.

5.2 Managing Cookies

Most web browsers allow you to control cookies through their settings, including blocking or deleting cookies. If you disable or reject cookies, some parts of the Website may not function properly or may be less convenient to use.

6. How We Share Your Information

We may share your personal data with third parties in the following circumstances, and only to the extent reasonably necessary:

• Service providers - With third-party vendors who provide services on our behalf, such as website hosting, IT and system administration, analytics, email delivery and other professional services. These providers are required to protect your personal data and may only use it in accordance with our instructions.
• Business partners and professional advisers - With selected partners, advisers, consultants, lawyers, accountants, auditors and other professional service providers in the context of our business and investment activities.
• Corporate transactions - In connection with, or during negotiations of, any merger, sale of assets, financing, acquisition, restructuring or similar transaction involving Lux Capital. We will take steps to ensure that your personal data remains protected.
• Legal and regulatory reasons - Where we are required or permitted by law, regulation, court order or regulatory or governmental request to disclose your personal data; or where disclosure is necessary to establish, exercise or defend legal rights or to protect the rights, property or safety of Lux Capital, our users or others.
• With your consent or at your direction - Where you instruct or consent to us sharing your information with a third party, for example in connection with a particular introduction or collaboration.

We do not sell your personal data in exchange for money. If, in the future, we engage in any data sharing that could be considered a "sale" or "sharing" under certain laws, we will provide the required notices and options.

7. International Transfers

Lux Capital is based in Hong Kong and operates globally. As a result, your personal data may be transferred to, stored in or accessed from jurisdictions outside your country of residence, including locations that may have different data protection laws.

Where required by applicable law (for example, for data relating to individuals in the EU/EEA or UK), we will ensure that appropriate safeguards are in place for such transfers, such as:

• Standard contractual clauses approved by relevant authorities; or
• Other lawful transfer mechanisms recognised under applicable law.

By using our Website or providing your information to us, you acknowledge that your personal data may be transferred and processed as described in this section.

8. Data Retention

We retain personal data for as long as reasonably necessary to:

• Fulfil the purposes for which it was collected;
• Provide the Services and manage our relationship with you;
• Comply with legal, regulatory, tax, accounting or reporting obligations; and
• Resolve disputes and enforce our agreements.

When personal data is no longer required, we will take reasonable steps to delete or anonymize it. Where deletion is not immediately feasible (for example, data in backup archives), we will securely store and isolate it from further processing until deletion is possible.

9. Your Rights and Choices

9.1 Rights Under Hong Kong Law

Under the PDPO, you generally have the right to:

• Request access to personal data we hold about you; and
• Request correction of personal data that is inaccurate.

Requests should be made in writing using the contact details in Section 12. We may charge a reasonable fee as permitted by law for processing access requests.

9.2 Rights Under the GDPR / UK GDPR (If Applicable)

If you are located in the EU/EEA or the UK, you may also have the following rights:

• Access: obtain confirmation as to whether we process your personal data and receive a copy of that data;
• Rectification: have inaccurate personal data corrected and incomplete data completed;
• Erasure: request deletion of your personal data, subject to legal restrictions;
• Restriction: request that we limit the processing of your personal data in certain circumstances;
• Objection: object to processing based on our legitimate interests and object at any time to processing for direct marketing;
• Data portability: receive certain personal data in a structured, commonly used and machine-readable format and have it transmitted to another controller, where technically feasible;
• Withdrawal of consent: where processing is based on your consent, withdraw your consent at any time. This will not affect the lawfulness of processing before withdrawal.

To exercise any of these rights, please contact us using the details in Section 12. We may need to verify your identity before responding. You also have the right to lodge a complaint with your local data protection supervisory authority.

9.3 Marketing Communications

You may opt out of receiving marketing or promotional emails from us at any time by:

• Clicking the "unsubscribe" or similar link in any marketing email; or
• Contacting us using the details in Section 12.

Even if you opt out of marketing communications, we may still send you non- marketing messages where necessary, such as important service or legal notices.

10. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised or unlawful access, processing, alteration, disclosure or destruction. These measures may include:

• Access controls and authentication;
• Encryption and secure communication protocols;
• Regular monitoring and review of systems and security measures;
• Limiting access to personal data to those who need it for legitimate business purposes.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

11. Third-Party Websites

Our Website may contain links to websites, services or content operated by third parties. We do not control and are not responsible for the privacy practices of such third parties.

If you follow a link to any third-party website or service, please review their privacy policies before providing any personal data.

12. Contact Us

If you have any questions, comments or requests regarding this Privacy Policy or our handling of your personal data, or if you wish to exercise your rights, please contact us at:

Please include your name, contact details and a clear description of your request.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or other operational needs.

When we make changes, we will update the "Last updated" date at the top of this page. Where required by law, we may also provide additional notice (for example, by posting a prominent notice on the Website or contacting you directly).

Your continued use of the Website or Services after any changes become effective will indicate your acknowledgement of the updated Privacy Policy. If you do not agree with the updated policy, you should stop using the Website and Services.