Effective Date: [Insert Date]
Company: China Global Trust Limited
Registered Address: Room 609, 6/F, Hong Kong Plaza, 188 Connaught Road West, Hong Kong
Email: info@chinaglobaltrust.com
Phone: +852 2623 3302

China Global Trust Limited (“CGT”, “we”, “us”, or “our”) is committed to protecting your privacy and handling personal data responsibly. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website, contact us, or engage with our services.

By using our website or communicating with us, you acknowledge the practices described in this Privacy Policy.

1. Who We Are

China Global Trust Limited is a Hong Kong company providing trust and fiduciary-related services, including trustee, custodial, escrow, and related administrative solutions, subject to applicable laws and internal compliance procedures.

For the purposes of applicable data protection requirements, CGT acts as the data controller in relation to personal data collected through this website and in connection with our business communications and services.

2. Personal Data We Collect

We may collect and process the following categories of personal data:

2.1 Information you provide directly

This may include:

• your name
• company name
• job title
• email address
• telephone number
• correspondence details
• information submitted through contact forms, email communications, or other inquiries
• identification and due diligence information where required for onboarding, compliance, or service provision

2.2 Information collected automatically

When you visit our website, we may automatically collect limited technical information, including:

• IP address
• browser type and version
• device type
• operating system
• referring website
• pages viewed
• date and time of access
• basic website interaction data

2.3 Compliance-related information

Where relevant to our services, legal obligations, or risk management procedures, we may collect information necessary for:

• identity verification
• anti-money laundering and counter-terrorist financing checks
• sanctions screening
• fraud prevention
• source of funds and source of wealth review
• conflict and risk assessment

3. How We Use Personal Data

We may use personal data for the following purposes:

• to respond to inquiries and requests
• to communicate with prospective clients, counterparties, intermediaries, and service providers
• to provide information about our services
• to assess whether we can establish or maintain a business relationship
• to carry out client onboarding, due diligence, compliance, and risk assessment procedures
• to administer and manage our business relationships
• to perform contractual obligations
• to maintain internal records and document communications
• to improve our website, service quality, and security
• to comply with applicable legal, regulatory, audit, accounting, and reporting obligations
• to protect our legal rights and interests

4. Legal Basis for Processing

We process personal data where it is necessary:

• for our legitimate business interests
• to take steps prior to entering into a contract or to perform a contract
• to comply with legal and regulatory obligations
• to establish, exercise, or defend legal claims
• based on consent, where consent is required by applicable law

5. Disclosure of Personal Data

We do not sell personal data.

We may disclose personal data, where appropriate and subject to confidentiality and legal safeguards, to:

• affiliated entities and internal personnel on a need-to-know basis
• professional advisers, including legal, compliance, audit, tax, and accounting advisers
• banks, payment providers, custodians, trustees, administrators, and other financial or professional counterparties
• identity verification, AML, sanctions screening, and due diligence service providers
• IT, website hosting, cybersecurity, and document management service providers
• regulators, governmental authorities, courts, law enforcement agencies, or other authorities where required by law or regulation
• prospective acquirers, successors, or restructuring parties in connection with a corporate transaction, subject to appropriate safeguards

6. International Transfers

Your personal data may be stored or processed in jurisdictions outside Hong Kong where our service providers, advisers, counterparties, or group-related support functions operate.

Where personal data is transferred internationally, we take reasonable steps to ensure that appropriate safeguards and confidentiality measures are in place.

7. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including:

• to respond to inquiries
• to manage ongoing relationships
• to comply with legal, regulatory, tax, accounting, and record-keeping obligations
• to resolve disputes and enforce our rights

Retention periods may vary depending on the nature of the relationship, the sensitivity of the information, and applicable legal or compliance requirements.

8. Data Security

We apply reasonable administrative, technical, and organizational measures to protect personal data against unauthorized or unlawful access, loss, misuse, alteration, disclosure, or destruction.

However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

9. Cookies and Website Analytics

Our website may use cookies and similar technologies to:

• support website functionality
• understand website usage
• improve user experience
• enhance website performance and security

You may control cookies through your browser settings. Disabling certain cookies may affect website functionality.

10. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices, content, or security of external websites. We encourage you to review their privacy policies separately.

11. Your Rights

Subject to applicable law, you may have the right to:

• request access to personal data we hold about you
• request correction of inaccurate or incomplete data
• request deletion of personal data in appropriate circumstances
• object to or request restriction of certain processing
• withdraw consent where processing is based on consent
• request information about how your personal data is used

To exercise any of these rights, please contact us using the details below. We may request information to verify your identity before processing your request.

12. Children

Our website and services are not directed to children, and we do not knowingly collect personal data from individuals who are under the age of legal majority without appropriate authorization.

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 business operations. Any updated version will be posted on this page with a revised effective date.

14. Contact Us

If you have any questions about this Privacy Policy or our handling of personal data, please contact us at:

China Global Trust Limited
Room 609, 6/F, Hong Kong Plaza, 188 Connaught Road West, Hong Kong
Email: info@chinaglobaltrust.com
Phone: +852 2623 3302