General Overview

Welcome to the official Website of Dreamer Group (the “Website”).

We fully understand the importance of your Personal Information to you and are committed to protecting your privacy. To this end, we will take appropriate security measures to protect and ensure the security and control of your Personal Information as required by applicable laws and regulations. With this in mind, Dreamer Group (“we”) have developed this Privacy Policy (the “Policy”) to help you fully understand how we collect, use, share, store and protect your Personal Information in the course of your use of the Website and how you can manage your Personal Information so that you can make better choices.

Please note that this Policy applies to your use of the various products and services of this Website in any way. You should read and understand this Policy carefully before using any product or service on this Website and start to use the product or service only after you have confirmed that you fully understand and agree to it. By commencing to use the product or service on this Website, you are deemed to have fully understood and agreed to this Policy. This Policy also applies to products or services of our affiliates that use content of this Website but do not have a separate privacy policy.

“Personal Information” for the purposes of this Policy refers to all information relating to an identified or identifiable natural person that is recorded electronically or by other means, excluding anonymized information. We will use such information in accordance with this Policy.

If you have any comments or suggestions about the contents of this Policy, please contact us through the contact information provided on the Website and we will be happy to respond to you. If you have any questions about the terms of this Policy or disagree with any of the contents of this Policy, you should cease accessing this Website immediately.

This policy will explain to you the following contents:

I. What Personal Information we collect from you.

II. How we collect Personal Information.

III. How we use your Personal Information.

IV. Retention of Personal Information.

V. How we use Cookies.

VI. How we share, transfer and disclose your Personal Information.

VII. How we protect your Personal Information.

VIII. Your rights and privacy choices.

IX. Global transfer of Personal Information.

X. Direct marketing.

XI. Updates to this Policy.

XII. Miscellaneous.

I. What Personal Information we collect from you.

1. We collect Personal Information that is necessary and not excessive for the provision of our services and to fulfil the essential functions of the services we provide. You have the right to opt out of providing such information. If you refuse to allow us to collect any Personal Information from you, we may not be able to provide you with the full functionality of the Website, but you may still be able to access some of the basic content on the Website, which is generally informational and based on other users' consent to this Privacy Policy.
2. If a piece of information cannot be used to identify you personally, either alone or in combination with other information, then that information is not your Personal Information for legal purposes. Where we hold information that can objectively be combined with other information to identify you personally, such information will be treated and protected as your Personal Information in accordance with this Policy for the duration of its use, even if we do not intend or are unable to obtain or combine any other information to ultimately identify you personally.
3. We will not collect and process certain sensitive Personal Information about you (including, for example, information relating to race, religious beliefs, physical or mental health or sexual orientation) unless we have obtained your express consent in accordance with applicable legal requirements.
4. We may also need to collect Personal Information from you if required by law or regulation, or to prevent or prohibit illegal or unlawful activities, and to store and/or compile such information as required. In order to comply with the relevant laws and regulations in the PRC and to provide you with a service and protect your experience, we may collect information that you voluntarily provide, authorize or provide at your request in connection with your use of the services provided by us, and information generated from your use of the products and services on this Website for the following purposes and in the following ways:
   1. If you contact our customer service or operations team, we may require you to provide Personal Information (e.g. name, telephone number, email address and other contact details) as necessary to record your identity and may also record the history and content of your correspondence with us to ensure that we are able to respond to your enquiry in a timely and accurate manner.
   2. To facilitate your ability to copy text, share or receive shared information, we need to access your clipboard permissions locally and read if you have any text that needs to be copied and pasted, so that you can complete the copy and paste operation for quick input, sharing and other functions. We will not upload other information from your clipboard to our server.

II. How Do We Collect Personal Information

1. During your visit to our Website, we generally do not collect your personal information unless you initiate a consultation through the "Contact Us" feature on our Website. At that time, we will directly collect and record your contact information through the relevant web page to provide you with subsequent answers.
2. If you contact us online, we may use Cookie tools to collect information about your computer and your use of our Website. Where this information is linked to your contact details, we will treat it as Personal Information. For more information on Cookie technology, please see the section "How we use Cookies" below.

III. How Do We Use Your Personal Information

1. We may use your Personal Information to:
   1. to carry out the functions of the services we provide;
   2. to fulfill requests from you or us for the provision of services or related matters;
   3. to provide you with direct marketing communications and information about our services and products from us and our partners (in certain circumstances), including promotional offers based on your interests, business characteristics and location, and in each case to obtain your consent (including an indication of no objection) in accordance with applicable law;
   4. to comply with the laws, regulations, regulatory requirements, industry standards etc. that apply to us and/or other members of our Group;
   5. to determine your eligibility to use certain services; and
   6. to manage our day-to-day business requirements.
2. We may compile statistics on visits to the Website and may share these statistics with the public or third parties to demonstrate overall usage trends on the Website. However, these statistics do not contain any identifying information about you.

IV. Retention of Personal Information

1. We will retain Personal Information only for as long as is reasonably necessary for the purposes for which we collect it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements, and to keep such information strictly confidential in accordance with the law.
2. In general, we will only retain your Personal Information for as short a period as is necessary to fulfill the purposes described in this Privacy Policy, unless you have otherwise agreed to an extension of the retention period or as otherwise permitted by law. We may change the period for which Personal Information is stored in order to comply with legal requirements in the following circumstances:
   1. in order to comply with applicable laws and regulations etc.;
   2. in order to comply with a court decision, ruling or other legal process;
   3. in order to comply with the requirements of the relevant government authorities or legally authorized organizations;
   4. for purposes reasonably necessary to enforce the relevant service agreement or this Policy, to protect the public interest, to protect the personal property of our customers, our or our affiliates', other users or employees or other legitimate interests.

V. How Do We Use Cookies

1. Cookies are small text files created by a web server and stored on a user's browser. This type of technology can be used to understand your usage habits, save you from having to repeatedly enter account information, or help determine the security of your account. To make your visit easier, we may use Cookies to collect and store data about your visit to our services when you use our products or services. We will not use Cookies for any purpose other than those described in this Policy.
2. You can manage and delete Cookies according to your preferences and most browsers have features that allow you to disable or delete Cookies from the official Website. It is important to note that blocking Cookies may result in certain features of our Website not working effectively or being unavailable, which may affect your experience.
3. We do not use Cookies to collect and track any information about users or their behavior other than to confirm their identity and login status.

VI. How Do We Share, Transfer, and Disclose Your Personal Information

(I) Sharing

1. We are committed to keeping your information strictly confidential and will not share your Personal Information with companies, organizations or individuals outside the Dreamer Group, except as follows:
   1. Sharing with your consent;
   2. Sharing under legal circumstances. We may share your Personal Information externally as required by law or regulation, as necessary to resolve litigation disputes, or as required by judicial or administrative authorities, for example, if we are obligated to disclose your Personal Information to comply with any legal or regulatory obligations, such as our anti-money laundering and counter-terrorist financing obligations, or if we agree to assist in enforcing any tax or other regulatory filing requirements;
   3. Sharing with our member companies: Your Personal Information may be shared with members of the Dreamer Group who may use your Personal Information only following this Privacy Policy, and we will seek your authorized consent to change the purposes for which Personal Information is processed. Our member companies include, but are not limited to, PS Trust (HK) Limited (located in Hong Kong, China), PS Securities Limited (located in Hong Kong, China), PS Trust Limited (located in Hong Kong, China), PS Trust (Singapore) Pte. Limited (located in Singapore);
   4. Sharing with our partners. certain products or services may be provided by third parties or jointly by us and third parties, and therefore your Personal Information may be shared with the Dreamer Group's partners (i.e. banks, brokerage firms, legal/tax professional advisors, agents, etc. that we contact to provide the corresponding further services when you require);
   5. When you have a query that we need to answer, complain about us, complain about others or are complained about by others, in order to protect your legal rights and those of others, we may store your name and contact details, complaints and communications in the customer service systems provided by third party suppliers and may provide them to consumer protection departments and regulatory authorities in order to resolve complaints and disputes in a timely manner, except where expressly prohibited by laws or regulations.
2. If we need to share your information with a third party in order to provide services to you, we will evaluate the legality, appropriateness, and necessity of the information collected by the third party. We will only share Personal Information that is necessary and subject to the purposes stated in this Policy, and we will seek your authorization again if the third party we are working with changes the purposes for which the Personal Information is processed. We will require third parties to take protective measures for your information and to strictly comply with relevant laws, regulations and regulatory requirements.

(II) Transfer

1. We will not transfer your Personal Information to any company, organization or individual, except as follows:
   1. In accordance with mandatory administrative or judicial requirements of laws and regulations;
   2. In the event of an asset transfer, acquisition, merger, reorganization or bankruptcy and liquidation involving the transfer of Personal Information, we will inform you of the situation in writing and request that the new company or organization holding your Personal Information continue to be bound by this Policy. In the event of a change in the purpose of use of Personal Information, we will require the company or organization to obtain your explicit consent again.

(III) Public Disclosure

1. In principle, we will not disclose your Personal Information publicly, except in the following circumstances:
   1. with your express consent;
   2. as required by applicable law or regulation or to enforce a court judgment, ruling or other legal process or to comply with a lawful compulsory request by a government authority (including other legally authorized organizations);
   3. for purposes that are reasonable and necessary to enforce the relevant service agreement or this Policy, to protect the public interest, to protect the personal property of our customers, our or our affiliates, other users or employees, or other legitimate interests.

(IV) Exceptions To Prior Authorization For The Sharing, Transfer, Or Public Disclosure Of Personal Information：

1. related to national security or national defense security;
2. related to public safety, public health, and significant public interests;
3. related to crime investigation, prosecution, trial and judgment enforcement;
4. to protect your or other individuals' lives, property and other important legitimate rights and interests, but it is difficult to obtain my consent;
5. Personal Information that you disclose to the public on your own;
6. Personal Information collected from lawful public disclosure, such as lawful news reports, government information disclosure and other channels;
7. other circumstances stipulated by laws and regulations.

PLEASE NOTE THAT, ACCORDING TO THE LAW, SHARING OR TRANSFERRING PERSONAL INFORMATION THAT HAS BEEN ANONYMIZED AND ENSURING THAT THE RECIPIENT OF THE DATA IS UNABLE TO RECOVER AND RE-IDENTIFY THE SUBJECT OF THE PERSONAL INFORMATION IS NOT AN EXTERNAL SHARING, TRANSFER OR PUBLIC DISCLOSURE OF PERSONAL INFORMATION, AND THERE IS NO NEED TO SEPARATELY NOTIFY YOU AND OBTAIN YOUR CONSENT FOR THE STORAGE AND PROCESSING OF SUCH DATA. YOU ALSO AGREE THAT THIS POLICY MEANS THAT YOU AUTHORIZE US TO SHARE, TRANSFER, AND PUBLICLY DISCLOSE DATA GENERATED BY THE OPERATION OF THE APPLICATION AND RELATED PRODUCTS/SERVICES TO OTHER USERS AND THE PUBLIC WHO USE THE PRODUCTS AND SERVICES. IF YOU WISH TO RESTRICT SUCH SHARING, TRANSFER, OR PUBLIC DISCLOSURE, PLEASE CONTACT US THROUGH THE CONTACT INFORMATION SET FORTH IN THIS POLICY.

VII. How Do We Protect Your Personal Information

1. We have implemented industry-standard, reasonably practicable security measures to protect your information from unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonably practicable steps to protect your Personal Information. We implement physical, technical and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure and alteration, including, but not limited to, transport layer data encryption, firewalls and encrypted storage, physical access controls, and information access authorization controls. We have security procedures in place to protect your information from unauthorized access. For example, we ensure that all your network communications with us are protected by encryption using encryption technology (SSL). Your Personal Information is encrypted using high strength encryption and stored on our servers. We use trusted protection mechanisms to protect Personal Information from malicious attacks. We use a variety of data desensitization techniques, including content substitution and SHA256, to enhance the security of Personal Information during use, such as Personal Information display and Personal Information association calculations. We use automatic code security check and data access log analysis technology to enhance Personal Information security audit.
2. We have an industry-leading data security management system that focuses on the core of data and revolves around the data lifecycle, enhancing the security of the entire Website in multiple dimensions from organization construction, system design, personnel management, and product technology to protect your Personal Information.
3. We will take all reasonable and feasible measures to avoid collecting irrelevant Personal Information, and we will only retain your Personal Information for as long as necessary to achieve the purposes described in this Policy, unless the retention period needs to be extended or is permitted by law. After the necessary period, we will delete your Personal Information, except as otherwise required by law or regulation. When our products or services are discontinued, we will notify you by push notification, announcement, etc.
4. Please be aware and understand that the Internet is not a completely secure environment, and you should take measures to protect your Personal Information. Please remember to log out of the Website and close your browser window when you have finished your work. This is to ensure that other people who have access to your computer do not have access to your Personal Information and communications. If you discover that your Personal Information has been compromised, please contact us immediately using the contact details provided on the Website so that we can take appropriate action.
5. We have set up a transparent data breach handling system, and in the unfortunate event of a Personal Information security incident, we will inform you of the basic circumstances and possible effects of the security incident, the measures we have taken or will take to deal with it, suggestions for your own prevention and risk reduction, and remedial measures for you, as required by law and regulation. If it is difficult to inform each user individually, we will take reasonable and effective ways to publish the announcement.

VIII. Your Rights and Privacy

1. You have the following rights with respect to our processing of Personal Information about you:
   1. The right of access to Personal Information;
   2. The right to correct Personal Information;
   3. The right to restrict the use of Personal Information;
   4. The right to request the erasure of Personal Information;
   5. The right to object to the processing (including sharing or transfer) of Personal Information;
   6. The right to opt out of direct marketing; and
   7. The right to withdraw consent to the processing of your Personal Information at any time.
2. You may make such a request by contacting us through the contact information displayed on the Website. In accordance with the Personal Information (Privacy) Ordinance, Cap 486, we have the right to charge a reasonable fee for processing requests for access to the aforementioned information.
3. Please note that even if you choose to opt out of receiving direct marketing emails, we may still need to contact you to provide important data or information as a result of services we are providing or will provide to you or your employer.

IX. Global transfer of Personal Information

1. In order to better serve users from around the world, various members of the Dreamer Group work together to provide you with resources and information worldwide, which means that with your authorized consent, your Personal Information may be transferred to, or accessed from, the country in which you use the product or service. Such jurisdictions may have different data protection laws, or not even established relevant laws. You understand and agree that we may need to transfer your Personal Information collected and processed under this Policy outside of your jurisdiction (including allowing your Personal Information to be accessed from other jurisdictions) if required by business or administrative necessity in the future.
2. You understand and agree that if you access the service platforms and pages of international brokerage firms or third parties to obtain their products or services, the international brokerage firms or third parties may offer their products or services through their servers located in other jurisdictions, and if you wish to obtain such products or services, you may need to provide your Personal Information directly to international brokerage firms or third parties located in other jurisdictions based on the demand for the relevant products or services and the privacy policies of the relevant products. If you wish to obtain such products or services, you may need to provide the information directly to an international brokerage firm or third party located in another jurisdiction based on the requirements of the relevant product or service and the privacy policy of the relevant product. You should refer to the privacy policy of the relevant product or service and make your own decision as to whether to accept, use or provide your Personal Information to the international broker or third party. The products or services provided to you by international brokerage firms or third parties are not subject to this Policy, and your use of the platforms, pages, products or services of international brokerage firms or third parties is not protected by this Policy.

X. Direct Marketing

1. In connection with direct marketing, we may use your Personal Information, including but not limited to your name and contact information, geographic location, etc., to send you marketing messages about the services and products we and our partners offer from time to time by telephone, text (SMS), email, postal, fax and push notifications, and any other electronic means. Such services and products may include, but are not limited to, business, corporate, trust services and related information.
2. We will obtain your informed consent (including an indication of no objection) before using your Personal Information for direct marketing or providing information to third parties for direct marketing.
3. If at any time you do not wish us to continue to use or provide your Personal Information to others for direct marketing purposes and do not wish to receive any direct marketing messages, you may opt out of receiving direct marketing messages by notifying us through the contact information displayed on the Website.

XI. Updates to This Policy

1. We may update this Policy from time to time to reflect changes in the way we process your Personal Information or changes in legal requirements. If we make such changes to this Policy, we will post or otherwise publish the revised Privacy Policy on our Website. The revised Privacy Policy will be effective as of the date it is posted on our Website.
2. We recommend that you periodically check this page for updates to our privacy policy. Your continued use of our products and services offered on the Website will be deemed to be an acceptance of the updated privacy policy.

XII. Miscellaneous

1. If any clause is deemed unenforceable, it will not affect any other clauses.
2. The original version of this Policy and all documents relating thereto are written in Chinese and the English version is for reference only. In case of any conflict between versions, the Chinese version shall prevail.
3. This Policy and any dispute or claim arising out of or in connection with it (including non-contractual disputes or claims) shall be governed by the laws of Hong Kong. The courts of the Hong Kong Special Administrative Region shall have exclusive jurisdiction over all disputes and claims arising out of or in connection with the terms of this Agreement.