Our Data Privacy Policy

Your data is 100% safe with us

We take personal privacy and data security seriously. All personal data collected from you are handled in accordance with the relevant laws and regulations, including the Personal Data (Privacy) Ordinance (the “PDPO”) of Hong Kong and the General Data Protection Regulation (the “GDPR”) of the European Union.

Personal Data Collection and Use

By subscribing to Daily Reflection on China (the “Publication”) or visiting the Publication’s website (the “Website”), you give us the right to collect, use, store and back-up certain personal information such as your email address (the “Data”). We use such Data to provide services, facilitate communications, and perform administrative tasks such as record-keeping.

Data Security

All Data are kept confidential and secured to prevent unauthorized access. Only authorized persons with the relevant responsibility and authorization can access the Data. Unless requested by law enforcement, the Data will not be disclosed to any third party without your prior approval.

You should keep your login and password for the Website secured at all times, and you should not share the details with anyone. In public areas, you should always exercise caution and not leave your computer unattended whilst logging into your account. You should also avoid using public computers to access your account, unless you can adequately verify that the computer is free from spyware and that you can erase all of your information upon exiting the computer. We are not liable for any loss or damage arising from unauthorized access to your account due to any failure to comply with these precautions.

Use of Cookies

Cookies may be used when you visit the Website. The Website uses cookies to distinguish you from other visitors, and intends to improve your user experience. When browsing the Website, you agree to the use of cookies by the Website.

You can block cookies by changing certain settings of your browser. Doing so allows you to reject all or some cookies. Please be aware that if you block all cookies from the Website, you may not be able to access all or certain parts of the Website.

Data Retention

In general, the Data will be retained for as long as necessary for the provision of our services.

Your Rights

You reserve the rights, at any time, to:

• check whether the Data is held by us and to access such Data;

• obtain information in relation to our use of the Data;

• require us to correct as soon as reasonably practicable any Data that are inaccurate

• require us to restrict the use of the Data in certain circumstances;

• withdraw your consent for us to use the Data;

• require us to delete your Data without undue delay under specified circumstances, including (a) where the Data is no longer required in relation to the purposes for which it is collected, (b) where you withdraw the consent (which forms the basis of processing), (c) where there is no overriding legitimate interest, etc.

Governing Laws and Jurisdiction

This policy shall be governed by the laws of Hong Kong.

Changes to the Policy

This policy may be revised from time to time. The most up-to-date version of the policy is available to you upon request. It is your responsibility to periodically review and understand our latest policy. Please contact us at qiwang@substack.com if you have any questions.

Finally, Substack may also collect personal data from you. Substack’s Privacy Policy can be found here.

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Disclaimer

By reading, using and sharing this newsletter, you confirm that you understand, accept and agree to the following:

Daily Reflection on China (the “Publication”) is a newsletter for news, commentary and analysis on Chinese markets. The Publication is for information purpose only and should not be construed as investment or financial advice. Also this Publication does not constitute a recommendation, offer, or a solicitation of an offer to buy/sell any securities, portfolios of securities, financial products, investment schemes or trading strategies etc.

The information contained in this Publication (the “Information”) may reflect the opinions of the writer(s) and may include estimates and projections that involve subjective judgment and analysis. The Information has been compiled with considerable care to ensure its accuracy and validity. However no representation or warranty, express or implied, is made to the accuracy or completeness of the Information. The owners of the Publication (the “Owner”), its writers, representatives, principals and moderators (collectively the “Team”) accept no liability for any direct or consequential financial losses or damages, including for any loss of capital arising from the use of the Publication. The views and opinions expressed in this Publication are subject to change without notice.

This Publication is the property of the Owner and is protected by applicable intellectual property laws. Any redistribution or reproduction of the Publication is prohibited without the prior written permission of the Owner. The Publication is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution would be considered unlawful or illegal.

The Team may trade the securities and other interests of the companies mentioned in this Publication, and each may act on his/her own without having to disclose such trades or positions. The Team is not registered as a securities broker-dealer or investment advisor with the U.S. Securities and Exchange Commission (SEC).

In addition to producing this Publication, the Owner also works for a fund manager (the “Manager”) licensed by the Securities and Futures Commission of Hong Kong (SFC). The Manager has no ownership stake in and no direct association with this Publication. The views expressed in the Publication are not the views of the Manager.

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