Legal

Privacy Policy

Version v1.0 | Effective 17 September 2026

Template note: this is a general-purpose privacy policy template provided to meet the compliance requirements of the project. Before launch it must be reviewed by a Hong Kong practising solicitor or compliance adviser, and adapted to the fund's actual operating entity, place of incorporation and data processing flows.

1. Scope

This policy applies to your visit to the x.capital website (the "Website") and to the information you submit through it. The Website is intended for Professional Investors as defined under Hong Kong's Securities and Futures Ordinance (Cap. 571). The fund manager (the "Manager", "we", "us") is the controller of your personal information.

2. Information we collect

Information you provide: name, institution, email, phone, reason for contact and message in the due-diligence form; domain, asking price and contact details in the domain sale form; name, email and institution in download registration.
Investor qualification records: the choice you made in the qualified investor confirmation dialogue and the time of confirmation.
Technical information collected automatically: where you consent to analytics cookies, we may collect anonymised statistics such as pages visited, time on page, device type and browser type.

We do not knowingly collect sensitive information such as your identity document number, bank account details or transaction passwords. Identity verification and source-of-funds checks in connection with the Fund take place offline or through dedicated compliance channels at the formal signing stage.

3. How we use information

To respond to your enquiry and arrange due diligence and fund briefings;
To meet investor suitability management and compliance record-keeping obligations;
To send you materials you have requested (such as fund materials);
To assess and respond to a domain sale offer;
Where you have consented, to improve the content and experience of the Website.

We will not use your personal information for any purpose beyond those set out above, and we will not sell your personal information to any third party.

4. Storage and protection

Your information is held in access-controlled systems and encrypted media, and transmitted over the public internet using transport-layer encryption (HTTPS). We retain your information only for as long as necessary to achieve the purposes above, in accordance with the requirements of Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486). Once the retention period ends we will delete or anonymise the information.

5. Sharing

We may share your information only in the following circumstances:

With a custodian, auditor or professional legal adviser where necessary in connection with the Fund, and only to the extent required to meet compliance obligations;
Where required by law, by a regulator or by a court order;
Where you have given your explicit consent.

6. Your rights

You have the right to access, correct or request deletion of the personal information we hold about you, and to withdraw your consent to analytics cookies at any time. To exercise these rights, please email Jack@X.capital. We will respond within a reasonable period, generally no more than 30 days.

7. Cookies

The Website uses cookies to record your investor qualification status and your cookie preferences. See the Cookie Policy for details.

8. Changes to this policy

We may update this policy from time to time. The updated version will be published on this page with a revised effective date at the top. Material changes will be highlighted prominently.

9. Contact us

If you have any question about this policy, please contact Jack@X.capital | Cyberport, Hong Kong.

Related terms: Disclaimer · Cookie Policy