Personal Data Policy Statement – People’s Republic of China
Data Protection Policy
1. Introduction
The objective of this Data Protection Policy (“Policy”) is to provide you with information with respect
to how we collect and process personal information and sensitive personal information in accordancewith the Personal Information Protection Law of the People’s Republic of China (“PIPL”). Referencesin this Policy to “we”, “us” and “our” mean, unless the context otherwise requires means, CLSA Limited
and its Affiliates (including their representatives and/or agents). “Affiliates” shall mean any legalentities at any time directly or indirectly controlling, controlled by or under common control with CLSA
Limited, including but not limited to CITIC Securities International Company Limited and CITIC
Securities Co. Ltd.
We ask that you read this Policy carefully as it contains important information regarding the collection,use, disclosure and transfer (within or outside relevant jurisdiction) of Personal Data (as defined below).
In addition, this Policy is intended to provide you with sufficient information to enable you to notifyand obtain consent from any natural person (a “Relevant Person”) whose Personal Data may have been
provided or may be provided by you or your agent to us from time to time. As used in this Policy, a“data subject” refers to a natural person whose personal, sensitive personal, or privileged information
is processed.
This Policy supplements but does not supersede or replace any other consents you may have previously
provided to us in respect of your Personal Data, and your consents herein are additional to any rights
which we may have at law to collect, use or disclose your Personal Data.
2. Personal Data
In this Policy, “Personal Data” refers to all kind of personal data or personal information (including any
sensitive personal information, each as defined under PIPL) about you or a Relevant Person, whichwould identify you or such natural person (as the case may be), or from which such identity can bereasonably and directly ascertained when put together with other information, which are electronicallyor otherwise recorded, excluding information that has been anonymized.
Examples of such Personal Data you may provide us include your or a Relevant Person’s name, license
details, passport or other identification number, telephone number(s), age, marital status, mailingaddress, email address and any other information relating to you or any Relevant Person which youhave provided or will provide to us in any forms you may have submitted to us, or via any other formof interaction with you.
3. Purposes for the Collection, Use and Disclosure of Personal Data
Generally, we collect, use, disclose and/or process Personal Data for the following purposes:a)processing applications for account opening, account closing, account maintenance andoperations relating to your account(s);b)

processing your applications or requests for services and/or products;c)providing services and/or products to you, including the services and products ofexternal providers;

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including (where you act as agent for another party) those of your underlying
principals; managing indebtedness and payments between you and us;
carrying out your instructions or responding to your enquiries or feedback;f)conducting identity and/or credit checks and assisting other financial institutions toconduct credit check, and carrying out customer due diligence and other checks andscreenings and ongoing monitoring that may be required under any applicable AntiMoney Laundering Act, US Foreign Account Tax Compliance Act (FATCA) or any
applicable law, regulation or directive or internal policies and procedures of CLSA
Limited or its Affiliates (including but not limited to those designed to combat bribery
and corrupt practices, money laundering, terrorist financing and financial crime);g)

preventing, detecting and investigating fraud, misconduct or any unlawful activities,
whether or not requested by any relevant governmental or regulatory authority, andanalysing and managing commercial risks;h)complying with all applicable laws, regulations, rules, directives, orders, instructions
and requests from any governmental, tax, law enforcement or other authorities(whether local or foreign);

i)managing our infrastructure, business operations and employees, and complying with
our policies and procedures that may be required by applicable laws and regulations
including those relating to risk control, compliance, security, audit, finance andaccounting, human resources, systems and business continuity;j)addressing or investigating any complaints, claims or disputes;k)developing new services and/or products and updating you on our products and services
from time to time;l)unless you have indicated your preference to opt out, providing you with marketing,advertising and promotional information, materials and/or documents relating tobanking, investment, credit and/or financial products and/or services that we may beselling, marketing, offering or promoting, whether such products or services exist now
or are created in the future;m)carrying out research, planning and statistical analysis;n)organizing promotional events, conferences, seminars, and company visits;o)enforcing our legal and/or contractual rights against you including, but not limited to,recovering any and all amounts owed to us, andp)

all other incidental and associated purposes relating to the above and any other purpose
which you may agree from time to time,(collectively, the “Purposes”).
We may collect Personal Data for the above mentioned Purposes directly from you or from othersources (e.g. social media, third party’s online platforms, and other publicly available sources) andthrough our Affiliates, service providers, business partners, official authorities, or third parties (e.g.
third-party custodians, sub-custodians, and partner brokers).
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4. The Legal Grounds for Processing Personal Data
We may use your Personal Data for the purposes as set out in clause 3 above and, for each purpose,
based on the following legal grounds, among other things:a)b)c)d)e)Performance of a contract - this is when the processing of your Personal Data is necessary
in order to perform our obligations under a contract;
Legal obligation - this is when we are required to process your Personal Data in order tocomply with a legal obligation, statutory functions, or statutory obligations, such as keeping
records for tax purposes or providing information to a public body or law enforcement agency;
Public interests - we may process your Personal Data where it is for the performance of a task
carried out in the public interest or protection of life, health or assets of natural persons underemergency;
Your consent - we process your Personal Data with your consent, and we will only process
your Personal Data if you agree to us doing so;
Disclosed information – we may process your Personal Data that is disclosed by you orotherwise legally disclosed.

5. Consent
By interacting with us and submitting information to us, or signing up for any products or services
offered by us, you represent and agree that:a)

we shall collect, use, disclose and share Personal Data for the Purposes stated in thisPolicy;b)

we shall be authorised to disclose such Personal Data to our Affiliates, authorised
service providers and relevant third parties in the manner set forth in this Policy and inthe PIPL;c)we shall be authorized to process your sensitive personal information (as defined in thePIPL) for the Purposes stated in this Policy;d)we shall be authorized to disclose your Personal Data outside of relevant jurisdictions;e)

we shall be allowed to disclose and/or transfer your Personal Data to our Affiliates andother third parties as provided below; andf)

each Relevant Person has consented to our collection, use, disclosure and/or process of
his/her Personal Data for the Purposes stated above, and such Relevant Person has been
informed of and has accepted this Policy.

If you do not wish for us to continue to use your Personal Data or the Personal Data provided by you to
us for any of the Purposes at any time in the future, you must notify us to withdraw your consent (seeSection 13). Depending on the circumstances, your withdrawal of consent may result in our inability toprovide you with certain services and/or products that we have been offering to you, and consequently,
may result in the termination of your relationship and/or accounts with us if permitted under theapplicable laws. The withdrawal of consent will not affect the lawfulness of the collection, use, anddisclosure of your Personal Data based on your consent before it was withdrawn.
Where the personal data protection laws of the relevant jurisdictions permit us to collect, use or disclose
the Personal Data without your or the Relevant Person’s consent, such permission granted by law willcontinue to apply.
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6. Disclosure, Sharing and Transfer of Personal Data Overseas
Subject to the provisions of any applicable law, Personal Data may be disclosed or transferred to, sharedwith or kept by the following entities, wherever located, for any of the Purposes or for processing for
any of the Purposes:a)our Affiliates;b)

any third party service providers, including archival management service providers,subject to the provisions of the PIPL; (Upon request by you we may provide you (whereavailable) with the privacy policies of third parties to whom we provide your PersonalData.)c)our professional advisers (including lawyers) and agents or third parties necessary for
us performing/providing services to you (including our executing brokers, clearing
houses and settlement agents) or for any other Purpose as stated in this Policy;d)our auditors;e)any person to whom disclosure is permitted or required by law or any court order;f)

any local or foreign government agencies, regulatory authorities and statutory bodies
having jurisdiction over us; andg)

any of their respective successors and assigns.

To the extent that we may need to transfer Personal Data outside the relevant jurisdiction, we shall doso in accordance with the applicable personal data protection law with reasonably practicablemonitoring to ensure that we provide an adequate standard of protection to the Personal Data.
7. Retention
Personal Data will be held for as long as it is necessary to fulfil the purpose for which it was collectedor as required or permitted by applicable laws. We shall cease to retain Personal Data, or remove themeans by which the Personal Data can be associated with particular individuals, as soon as it isreasonable to conclude that the purpose for which that Personal Data was collected is no longer being
served by retention of the Personal Data and retention is no longer necessary for legal, regulatory or
business purposes.
8. Data Security
We have taken and will continue to take reasonable efforts to protect Personal Data in our possession
or control by making reasonable security arrangements to prevent unauthorised access, collection, use,disclosure, copying, modification, disposal or similar risks.
While we strive to protect your Personal Data, we cannot ensure the security of any Personal Data which
you may have transmitted to us via methods using an unsecure browser, and we urge you to take every
precaution to protect your Personal Data and use a secure browser.
9. Updates to the Data Protection Policy
We may update this Policy to ensure that it is consistent with our future developments, industry trends
and/or any changes in legal or regulatory requirements. Such changes will be posted on our website.
Personal Data Policy Statement – People’s Republic of China Version October 20214Such changes to our Policy shall apply from the time that we post the same on this website
www.clsa.com/privacy-policy-statement and/or https://www.clsa.com/terms-of-business/. Your
continued use of our service will be taken as acceptance of and consent to the updated Policy.
10. Cookies
A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser
when you visit our website. It enables our own system to recognise you when you visit our website
again and improve our service to you. The information is used to track visitor use of the website and tocompile statistical reports on website activity. For further information about cookies visit
www.aboutcookies.org or www.allaboutcookies.org. Cookies may also be used to compile aggregate
information about areas of our website that are visited most frequently. This traffic information can beused to enhance the content of our website and make your use of it easier. If you wish to reject ourcookie, you can configure your browser to do so. However, in a few cases some of our website features
may not function if you remove cookies from your browser.
11. Third Party Websites
We have not reviewed any of the websites linked by our website. We will not be responsible for thecontent of any other websites or pages linked to or linking to our website and usage of any of such
linked websites or pages. Such links are provided solely for your convenience and information.
Following links to any other websites or pages shall be at your own risk. Visitors are advised to checkthe privacy statements of those websites to understand their policies on the collection, usage, transferand disclosure of personal data.
12. Rights of the Data Subjects
Under the PIPL, you have the right to:• be informed about the collection and use of your/or Relevant Person’s Personal Data;• withdraw consent;• know and decide on the processing of your and/or Relevant Person’s Personal Data;• object to the collection, use, or disclosure of your and/or Relevant Person’s Personal Data;• restrict to the collection, use, or disclosure of your and/or Relevant Person’s Personal Data;• consult and duplicate Personal Data;• Personal Data transfer (conditions specified under PIPL are met);• request correction of incorrect Personal Data;• supplement relevant information if in case of incomplete Personal Data;• erasure of Personal Data;
If you would like to exercise any of these rights, you may contact us at the address set out in Section 13
below referencing ‘Data Protection Policy’.
13. Contacting Us
For any queries, clarifications, questions or comments about the collection, use or disclosure of your
Personal Data or this Policy, you may contact us at the address below referencing ‘Data Protection
Policy’:Data Protection Officer
18/F One Pacific Place
88 Queensway
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Hong Kong
Tel: 26008888
Email: dataprotectionofficer@clsa.com

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