“Personal data” means data relating directly or indirectly to an individual from which it is practicable for the identify of the individual to be directly or indirectly ascertained.

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“You” and “Your” when used in this Privacy Policy include any person who accesses the Sapien Ventures Web Site and submits personal data.

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Our Commitment to Privacy

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Our Privacy Policy was developed as an extension of our commitment to seek to combine the highest quality products and services with the highest level of integrity in dealing with our clients and partners. The Policy is designed to assist you in understanding how we collect, use and safeguard the personal data you provide to us and to assist you in making informed decisions when using the Sapien Ventures Web Site and our products and services. We endeavour to continuously assess our privacy practices in light of new technologies, business practices and our customers’ needs. Our Privacy Policy may therefore be amended from time to time. You should check our Privacy Policy regularly to ensure you are aware of our latest policies.

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What Information Do We Collect?

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When you visit the Sapien Ventures Web Site, we may collect two types of information from you: personal data you knowingly choose to disclose that is collected on an individual basis and the Sapien Ventures Web Site use information collected on an aggregate basis as you and others browse the Sapien Ventures Web Site.

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1. Personal Information You Choose to Provide

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Registration

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During the registration process prior to using the Sapien Ventures Web Site, we require that you supply a unique subscriber ID and password, your name, e-mail address, mailing address and demographic information (country, age, sex, personal and household income, marital status, academic qualifications, employment status and occupation). Failure to provide such information may result in our being unable to provide you with our services including access to the Sapien Ventures Web Site. On occasion, we may also collect additional personal data from you in connection with optional contests, surveys, or special offers. You agree that we may store and deal with any information you provide as part of the registration process or in connection with optional contests, surveys or special offers in accordance with this Privacy Policy.

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In addition to providing the foregoing personal data to us, if you choose to correspond further with us through e-mail, we may retain the content of your e-mail messages together with your e-mail address and our responses. We provide the same protection for these electronic communications that we employ in the maintenance of information received by mail and telephone.

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2. Sapien Ventures Web Site Use Information

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Cookies

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The Sapien Ventures Web Site utilises Web server logs and will use a standard technology called “cookies” (see explanation below, “What Are Cookies?”) to recognize you and your access privileges on the Sapien Ventures Web Site as well as to collect information about how the Sapien Ventures Web Site is used. Information gathered by using cookies and Web server logs may include the date and time of visits, the pages viewed, time spent at the Sapien Ventures Web Site, and the Web Sites you visited immediately before and after the Sapien Ventures Web Site. This information is collected on an aggregate basis. None of this information is associated with you as an individual.

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IP Addresses

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We also log IP addresses, or the location of your computer on the Internet, for systems administration and troubleshooting purposes. We do not use IP address logs to track your session or your behaviour on the Sapien Ventures Web Site.

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How Do We Use the Information That You Provide to Us?

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Broadly speaking, we use personal data for purposes of administering our business activities, providing customer service and making available other products and services to our customers and prospective customers. Occasionally, we may also use the personal data we collect to notify you about important changes to the Sapien Ventures Web Site, new services and special offers we think you will find valuable. The lists used to send you product and service offers are developed and managed under our traditional corporate standards designed to safeguard the security and privacy of our customers’ personal data. You will be given the opportunity to notify us of your desire not to receive these offers.

The main purposes for which personal data may be used by us are:

• Processing your application or registration for our services, enquiry or feedback

• Incorporation into our user database

• Provision of contacts and business details in response to enquiries and complaints

• Operations

• Service surveysv

• Direct marketing

• Processing billing and payment

• Meeting requirements to make disclosure under any law applicable in or outside Hong Kong

• Public notices

• Auditing

• Other related purposes

We may use your personal data both in and outside Hong Kong.

Disclosure to Third Parties

Personal data held by us will be kept confidential but we may provide such data to:

• Banks and other financial institutions in connection with the collection of payments;

• Any personnel, agent, adviser, auditor, contractor or service provider who provides services or advice to us in connection with our operations;

• Any person under a duty of confidentiality to us;

• Any person to whom we are required to make disclosure under any law applicable

• Any actual or proposed transferee of our business or the Sapien Ventures Web Site or any part of our business or Sapien Ventures Web Site or participant in our operations.

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You should also note that the privacy protection as set out in this Privacy Policy does not apply to personal data which is passed to third parties, and we are not responsible for the protection of your personal data or lack thereof by such third parties.

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Except as otherwise provided in this Privacy Policy, personal data about you as an individual subscriber will not be provided to any third party without your consent.

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Sharing Information with Sapien Ventures Limited and the Group

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Your personal data may be disclosed to and used by us or other companies controlled by, or under common control with, Sapien Ventures Limited (the “Group”), for the purposes of direct marketing or the provision of customized information regarding the Group’s network of Internet and other products and services.

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What Do We Do with the Information We Gather?

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Statistical Analysis and Banner Advertising

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We may perform statistical analyses of user behaviour in order to measure interest in the various areas of the Sapien Ventures Web Site (for product development purposes) and to inform advertisers as to how many consumers have seen or “clicked” their advertising banners. We also use demographic and preference information to allow advertising banners on the Sapien Ventures Web Site to be targeted, in aggregate, to the readers for whom they are most relevant. This means that readers see advertising that is most likely to interest them, and advertisers send their messages to people who are most likely to be receptive, improving both the viewer’s experience and the effectiveness of the advertisement. For these purposes, we will disclose information to third parties only in aggregate form.

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What Are Cookies?

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Cookies are a feature of Web browser software that allows Web servers to recognise the computer used to access a Web Site. They are small pieces of data that are stored by a user’s Web browser on the user’s hard drive. Cookies can remember what information a user accesses on one Web page to simplify subsequent interactions with that Web Site by the same user or to use the information to streamline the user’s transactions on related Web pages. This makes it easier for a user to move from Web page to Web page and to complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalised.

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How Do We Use Information We Collect from Cookies?

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We use Web Site browser software tools such as cookies and Web server logs to gather information about the Sapien Ventures Web Site users’ browsing activities in order to constantly improve the Sapien Ventures Web Site and better serve our customers. This information assists us to design and arrange our Web pages in the most user-friendly manner and to continually improve the Sapien Ventures Web Site to better meet the needs of our customers and prospective customers.

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Cookies help us collect important business and technical statistics. The information in the cookies lets us trace the paths followed by users of our Website as they move from one page to another. Web server logs allow us to count how many people visit the Sapien Ventures Web Site and evaluate the Sapien Ventures Web Site’s visitor capacity. We do not use these technologies to capture your individual e-mail address or any personally identifying data about you although they do permit us to send focused online banner advertisements and other such responses to you.

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From time to time you may notice offers from outside companies advertised on the Sapien Ventures Web Site. We endeavour to take measures to select product or service providers that are responsible and afford privacy protections to their customers. However, we do not make any representations about the practices and policies of these companies. You may opt-out of sharing your personal data with such affiliates by choosing not to use their service or content.

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How Do We Share Information with Strategic Partners?

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We may enter into strategic marketing alliances or partnerships with third parties who may be given access to personal information including your name, address, telephone number and e-mail for the purpose of providing you information regarding products and services that we think will be of interest to you. In connection with strategic marketing alliances or partnerships, we will retain all ownership rights to your personal data.

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Notice of New Services and Changes

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Occasionally, we may also use the information we collect to notify you about important changes to the Sapien Ventures Web Site, and new services and special offers we think you will find valuable. As our client, you will be given the opportunity to notify us of your desire not to receive these offers by clicking on a response box when you receive such an offer or by sending us an e-mail request at info.

Information Transmissions

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Personal data or e-mail that you send to us may not be secure unless we advise you that security measures will be in place prior to your transmitting the information.

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How Do We Protect Your Personal Data?

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Information Security

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We utilise encryption/security software to safeguard the confidentiality of personal data we collect from unauthorized access or disclosure and accidental loss, alteration or destruction.

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Evaluation of Information Protection Practices

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Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality and quality of our information. This policy may be updated from time to time so please check this statement periodically as it is your responsibility to make sure you are aware of our latest policies.

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Employee Access

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Our corporate values, ethical standards, policies and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons, processes and transactions. Employees designated to handle personal data will be instructed to do so only according to this Privacy Policy.

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We may charge a reasonable fee for processing any data access request.

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How Can You Access and Correct Your Information?

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You may address data access or correction requests, and questions or complaints to:

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Personal Data Privacy Officer
Sapien Ventures  Investment Management Pty Ltd
Level 1, 23-25 O'Connell Street,
Sydney NSW 2000

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Use of Personal Data in Legal Procedures

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If it becomes necessary that we take legal action against you for any reason whatsoever including copyright infringement, you expressly agree that the personal data provided by you can be relied upon in identifying and taking action against you.

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What About Legally Compelled Disclosure of Information?

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We may disclose information when legally compelled to do so, in other words, when we, in good faith, believe that the law requires it or for the protection of our legal rights.

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Data Retention

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We retain personal data so long as the data is still required for the purposes mentioned above.

We reserve the right to retain copies indefinitely for our archives.

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What About Other Web Sites Linked to the Sapien Ventures Web Site?
 

Please note that the Sapien Ventures Web Site contains links to other sites and occasionally allows other sites to be co-branded with the Sapien Ventures name. Please remember that when you use a link to go from our Website to another Web Site or when you use a co-branded site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other Web Site, including Web Sites that have a link to the Sapien Ventures Web Site, is subject to that Web Site’s own rules and policies which may differ from that of the Sapien Ventures Web Site. We are not responsible for the practices employed by websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Website.

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Your Consent

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By using the Sapien Ventures Web Site you consent to our collection and use of your personal data as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on the Sapien Ventures Web Site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.