Note: any use made of the information and material referred to below is strictly subject to the terms of use, conditions and disclaimers referred to below.
www.snowlakecap.com (the “Website”) and any reports contained herein are for information purposes only and should not be considered as investment advice or a recommendation to invest in any particular security or investment product. Information on this Website and in any reports contained herein also is not and should not be construed as an offer to sell, or the solicitation of an offer to buy, any securities or financial instrument.
Snow Lake Capital (HK) Limited (collectively with its affiliates, and its and their respective partners, directors, officers and employers, “Snow Lake Capital,” “we,” “our,” “us” and similar terms) is an investment manager providing investment management and advisory services to funds and managed accounts that are in the business of buying and selling securities and other financial instruments (collectively, the “Funds”). Unless otherwise stated, it should be assumed that as of the date of publication of any report, Snow Lake Capital (possibly along with or through its members, partners, affiliates, employees, and/or consultants) and/or the Funds may have (although it may not have) an investment position in all stocks (and/or options, swaps, and other derivatives related to the stock) and bonds covered therein (either long or short depending on Snow Lake Capital’s investment opinion), and therefore stand to realize significant gains in the event that the price of changes in conjunction with Snow Lake Capital’s investment opinion.
Snow Lake Capital may change its views about or its investment positions in a company (“Company”) at any time, for any reason or no reason. Snow Lake Capital may buy, sell, cover or otherwise change the form or substance of its investment in a Company. Snow Lake Capital disclaims any obligation to notify the market of any such changes.
The information, analysis and opinions expressed on this Website and in any reports contained herein are based on, among other things, publicly available information about a Company, third-party buy-side or sell-side research, our own due diligence, and inferences and deductions through our analysis. Snow Lake Capital does not guarantee in any way that it is providing all of the information that may be available. Snow Lake Capital recognizes that there may be non-public information in the possession of a Company or others that could lead a Company or others to disagree with Snow Lake Capital’s analyses, conclusions and opinions.
The Website and reports contained herein include forward-looking statements, estimates, projections and opinions prepared with respect to, among other things, certain legal and regulatory issues a Company faces and the potential impact of those issues on its future business, financial condition and results of operations, as well as, more generally, a Company’s anticipated operating performance, access to capital markets, market conditions, assets and liabilities. Such statements, estimates, projections and opinions may prove to be substantially inaccurate and are inherently subject to significant risks and uncertainties beyond Snow Lake Capital’s control.
Although Snow Lake Capital believes the Website and reports contained herein are substantially accurate in all material respects and do not omit to state material facts necessary to make the statements therein not misleading, Snow Lake Capital makes no representation or warranty, express or implied, as to the accuracy or completeness of the Website or any other written or oral communication it makes with respect to a Company, and Snow Lake Capital expressly disclaims any liability relating to the Website or such communications (or any inaccuracies or omissions therein). Thus, shareholders and others should conduct their own independent investigation and analysis of the Website and any reports contained herein and of a Company and other companies mentioned. Snow Lake Capital recommends that every investor conduct its own due diligence before buying or selling any security.
Except where otherwise indicated, the Website and reports contained herein speaks as of the date hereof, and Snow Lake Capital undertakes no obligation to correct, update or revise the Website or reports contained herein or to otherwise provide any additional materials. Snow Lake Capital also undertakes no commitment to take or refrain from taking any action with respect to a Company or any other company.
Further, the Website does not constitute an offer to sell, or a solicitation to buy, and interests in any Fund or other vehicle managed or advised by Snow Lake Capital. Any such offer or solicitation may only be made pursuant to any private offering materials and subscription materials, or similar documents, provided by a Fund, which should be carefully reviewed prior to investing. The investment strategies of Snow Lake Capital are speculative and carry the risk of loss of capital and may be unsuitable for investors depending on their specific investment objectives and financial situation. Any investment program described on this Website is suitable only for sophisticated investors.
This Website may not be accessed in any jurisdiction where the distribution of the information contained on the Website would constitute a violation of applicable laws or regulations. By accepting receipt of this communication, the recipient will be deemed to represent that they possess, either individually or through their advisers, sufficient investment expertise to understand the risks involved in any purchase or sale of any financial instruments discussed herein. It is the responsibility of every person accessing this Website to satisfy himself or herself as to the full observance of laws of any relevant country, including obtaining any government or other consent which may be required or observing any other formality which needs to be observed in that country. Reliance on this Website for the purpose of engaging in any investment activity may expose an individual to a significant risk of losing all of the property or other assets invested.
The content on this Website may change and is only a high-level summary; it does not contain all material terms pertinent to an investment decision, including important disclosures of conflicts and risk factors associated with an investment in a Fund managed or advised by Snow Lake Capital. No representation is made with respect to its completeness or timeliness. Certain information has been obtained from third party sources and, although believed to be reliable, has not been independently verified and its accuracy or completeness cannot be guaranteed.
Access to the Website is conditioned on these terms of use (the “Terms of Use”), which you are hereby deemed to have accepted. Snow Lake Capital operates the Website solely for providing general business information to potential employees, customers, service providers and other interested parties.
The Website and its content (“Content”) is owned by Snow Lake Capital, its affiliates and/or third parties. The Website is protected by one or more copyrights, patents, database rights, trademarks, service marks and/or other intellectual property and proprietary rights that are owned by Snow Lake Capital, our affiliates and/or third parties. You may not decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of the Website. You may not publish, broadcast, retransmit, reproduce, repackage, frame, commercially exploit, create any derivative of or otherwise redistribute all or any portion of the Website except as explicitly permitted herein. You may print copies of any accessible portion of the Website only for your own personal use. You may discuss information you learn from the Website with your financial, legal or tax advisors, and others with whom you share investment decisions. You may not remove any copyright, trademark, or other proprietary notice or legend contained on (or printed from) the Website.
If we provide you with a password, you must keep your password and certain Content confidential. You are solely responsible for maintaining the confidentiality and security of your password. You accept full responsibility for any use of your password. You must notify us immediately of any actual or suspected loss, theft, or unauthorized use of your password. You may not disclose any Content that is contained within the password protected portion of the Website to any third party, except to your financial, legal, or tax advisors, and others with whom you share investment decisions. We are not obligated to inquire as to the authority or propriety of any use of or action taken under your password. We will not be responsible for any loss to you that arises from such use or action or from your failure to comply with these provisions.
You represent and warrant that you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these terms; you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of the Terms of Use; and you will not delete any Content.
There are various risks you assume in relying on the Content. Dated Content speaks only as of the date indicated. We make reasonable efforts to provide accurate Content, but at times we may not promptly update or correct the Website even if we are aware it is inaccurate, outdated, or otherwise inappropriate. We may change all or any portion of the Website at any time without notice to you. We do not endorse the opinions of, or warrant the accuracy of facts or other Content contributed by, any third party. You agree we are not liable for any action you take or decision you make in reliance on any Content.
We are not liable for any technological problems and any impact they may have. All or any portion of the Website may not be available and may not function properly at any time. We make reasonable efforts to avoid technological problems, but at any time, the Website may have and may cause technological problems such as viruses and other damaging computer programming routines or engines. We take reasonable security precautions when using the Internet, telephone, or other means to transport data or other communications, but we disclaim liability for any interception of data or communications.
We make reasonable efforts to ensure that the Website is secure, but we do not guarantee the security of the Website. We are not liable for any damage or injury caused by the performance or failure of performance of all or any portion of the Website. We are not liable for any defects, delays, or errors in or resulting from your use of the Website.
We are not responsible for information on any third party web site that is referenced in, or accessible or connected by hyperlink to, the Website. If you access any third party web site through the Website or otherwise, you do so at your own risk. Hyperlinks to or from the Website do not constitute third party endorsement of, sponsorship by, or affiliation with us.
We have the right, but not the obligation, to monitor and record activity on the Website and respond as we deem appropriate. We may monitor and record activity on the Website for any reason or for no reason. We may investigate any complaint or reported violation of our policies. We may report any activity we suspect may violate any law or regulation to regulators, law enforcement officials, or other persons or entities we deem appropriate. We may issue warnings, suspend, or terminate use of the Website, deny access to all or part of the Website or take any other action we deem appropriate.
WE DISCLAIM ALL WARRANTIES WITH RESPECT TO THE WEBSITE THAT THE LAW ALLOWS US TO DISCLAIM.
THIS DISCLAIMER OF LIABILITY APPLIES TO ANY AND ALL DAMAGES OR INJURY, INCLUDING THOSE CAUSED BY ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DELETION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS, COMMUNICATION LINE FAILURE, THEFT, DESTRUCTION OR UNAUTHORIZED ACCESS TO, ALTERATION OF OR USE OF ANY ASSET, WHETHER FOR BREACH OF CONTRACT, TORTIOUS BEHAVIOR, NEGLIGENCE, OR UNDER ANY OTHER CAUSE OF ACTION.
You will be responsible for any liability to us that arises out of your breach of the Terms of Use or your use of the Website. You agree to indemnify, defend, and hold harmless Snow Lake Capital and our affiliates, agents, employees, and third party sources from and against any and all suits, losses, claims, demands, liabilities, damages, costs and expenses (including reasonable attorneys’ fees) that arise from or relate to: (i) your use of the Website, (ii) your breach of the Terms of Use or any representation, warranty, or covenant made by you in the Terms of Use, (iii) your violation of any applicable law, statute, ordinance, regulation, or of any third party’s rights, or (iv) claims asserted by third parties that, if proven, would place you in breach of representations, warranties, covenants, or other provisions contained in the Terms of Use.
The Terms of Use will be governed by and construed and enforced in accordance with the laws of Hong Kong, without regard to conflicts of law principles. The courts of Hong Kong will have exclusive jurisdiction to adjudicate any dispute arising out of the Terms of Use, except with regard to injunctive relief. No person shall bring a putative or certified class action to arbitration nor seek to enforce any pre-dispute arbitration agreement against any person who has initiated a putative class action in court or who is a member of a putative class who has not opted out of the class with respect to any claims encompassed by the putative class action until: (i) the class certification is denied; or (ii) the class is decertified; or (iii) the customer is excluded from the class by the court. Such forbearance to enforce an agreement to arbitrate shall not constitute a waiver of any rights under the Terms of Use except to the extent stated herein.
You will be bound by revised versions of the Terms of Use that we post on the Website. Modifications will be effective immediately upon posting unless we indicate otherwise. Your use of the Website indicates your full acceptance of the Terms of Use in its then-current form each time you use the Website.
You are bound by certain other general conditions. We may assign the Terms of Use in whole or in part at any time without your consent. You may not assign the Terms of Use or delegate any of your obligations under the Terms of Use. Any purported assignment of the Terms of Use in violation of the Terms of Use is void. If any provision of the Terms of Use is found invalid or unenforceable, that provision shall be enforced to the maximum extent possible and the remaining provisions of the Terms of Use shall remain in full force and effect. The Terms of Use constitute the entire understanding, and supersedes all other understandings, between you and us concerning the subject matter hereof.
Copyright Infringement Notification Procedures
If you believe that any Content violates yours or a third party’s copyright, please notify us by providing the following information:
Snow Lake Capital is committed to protecting your privacy and maintaining the confidentiality and security of your personal information. This privacy notice (“Privacy Notice”) explains the manner in which Snow Lake Capital collects, utilizes and maintains nonpublic personal information of individuals who disclose such information to us, including prospective, current and former fund investors. This Privacy Notice only applies to products and services provided by Snow Lake Capital to individuals and which are used for personal, family, or household purposes (not business purposes). Please read this Privacy Notice carefully to understand what we do.
Collection of Individual Information
Snow Lake Capital collects personal information about individuals from the following sources:
Disclosure of Nonpublic Personal Information
Snow Lake Capital may share nonpublic personal information about individuals, including prospective, current and former fund investors, with affiliates, as permitted by law. Snow Lake Capital does not disclose nonpublic personal information about individuals to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to a fund investor or the fund investor’s account).
Snow Lake Capital may share nonpublic personal information, without an individual’s consent, with affiliated and nonaffiliated parties in the following situations, among others:
Protection of Individual Information
Snow Lake Capital maintains physical, electronic and procedural safeguards that comply with federal standards to protect customer information. Snow Lake Capital restricts access to the personal and account information of individuals to those employees who need to know that information in the course of their job responsibilities. Snow Lake Capital will destroy, erase or make unreadable data, computer files and documents containing nonpublic personal information prior to disposal.
Further Information
Snow Lake Capital reserves the right to change its privacy policy at any time. The examples contained within this Privacy Notice are illustrations and are not intended to be exclusive. This privacy policy complies with United States federal law regarding privacy (and for compliance with Hong Kong privacy law, please see the section below). You may have additional rights under other foreign or domestic laws that may apply to you. If you have any questions about this Privacy Notice or our privacy policies, please email Snow Lake Capital at enquiry@snowlakecap.com.
Snow Lake Capital is committed to protecting your privacy and maintaining the confidentiality and security of your personal information.
Snow Lake Capital recognize its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. We will use your personal data which we may from time to time collect in accordance with this Hong Kong Privacy Notice (“Hong Kong Privacy Notice”).
For compliance with United States federal law regarding privacy, see the section above. You may have additional rights under other foreign or domestic laws that may apply to you.
This Hong Kong Privacy Notice explains the manner in which Snow Lake Capital collects, utilizes and maintains personal information of individuals who disclose such information to us, including prospective, current and former fund investors. Please read this Hong Kong Privacy Notice carefully to understand what we do.
We regularly review this Hong Kong Privacy Notice and may from time to time revise it or add specific instructions, policies and terms. Where any changes to this Hong Kong Privacy Notice are material, we will notify you using the contact details you have provided us with and, where required by the PDPO, give you the opportunity to opt out of these changes by means notified to you at that time. Otherwise, in relation to personal data supplied to us through the Website or otherwise, continued use by you of the Website or your continued relationship with us shall be deemed to be your acceptance of and consent to this Hong Kong Privacy Notice, as amended from time to time.
Please note that if you do not provide us with your personal data (or relevant personal data relating to persons appointed by you to act on your behalf) we may not be able to provide the information, products or services you have asked for or process your requests, applications, subscriptions or registrations.
Collection of Individual Information
Snow Lake Capital collects personal information about individuals, including but not limited to your name, mailing address, telephone number, email address, date of birth and login name, from the following sources:
Purpose
From time to time Snow Lake Capital may collect your personal data for the following purposes:
Direct Marketing
Where you have given your consent and have not subsequently opted out, we may also use your name, mailing address, telephone number and email address to send promotional materials to you and conduct direct marketing activities in relation to Snow Lake Capital’s services.
If you do not wish to receive any promotional and direct marketing materials from us or do not wish to receive particular types of promotional and direct marketing materials or do not wish to receive such materials through any particular means of communication, please contact us through one of the communication channels set out in the “Contact Us” section below. To ensure that your request can be processed quickly please provide your full name, email address, log in name and details of the product and/or service you have subscribed.
Identity Card Number
We may also collect your identity card number and process this as required under applicable law or regulation, as required by any regulator having authority over us and, subject to the PDPO, for the purpose of identifying you where it is reasonable for your identity card number to be used for this purpose.
Transfers of Personal Data for Direct Marketing Purposes
Except to the extent you have already opted out we may transfer your name, mailing address, telephone number and email address to our affiliates for the purpose of enabling them to send promotional materials to you and conduct direct marketing activities in relation to their services.
Permitted Disclosure of Personal Information
Snow Lake Capital may share personal information about individuals, including prospective, current and former fund investors, with affiliates, as permitted by law. Snow Lake Capital does not disclose personal information about individuals to nonaffiliated third parties, except as permitted by law (for example, to service providers who provide services to a fund investor or the fund investor’s account).
Without prejudice to other provisions in this Hong Kong Privacy Notice, Snow Lake Capital may share personal information, without an individual’s consent, with affiliated and nonaffiliated parties in the following situations, among others:
Other Transfers Of Your Personal Data
For one or more of the purposes specified above, your personal data may be:
How We Use Cookies
If you access our information or services through the Website, you should be aware that cookies are used. Cookies are data files stored on your browser. The Website automatically installs and uses cookies on your browser when you access it. Two kinds of cookies are used on the Website:
Session Cookies: temporary cookies that only remain in your browser until the time you leave the Website, which are used to obtain and store configuration information and administer the Website, including carrying information from one page to another as you browse the site so as to, for example, avoid you having to re-enter information on each page that you visit. Session cookies are also used to compile anonymous statistics about the use of the Website.
Persistent Cookies: cookies that remain in your browser for a longer period of time for the purpose of compiling anonymous statistics about the use of the Website or to track and record user preferences.
The cookies used in connection with the Website do not contain personal data. You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software. However, if you do so you may not be able to utilize or activate certain functions available on the Website.
Compliance With Laws And Regulations
Snow Lake Capital may be required to retain, process and/or disclose your personal data in order to comply with applicable laws and regulations or in order to comply with a court order, subpoena or other legal process (whether in Hong Kong or elsewhere), or to comply with a request by a government authority, law enforcement agency or similar body (whether situated in Hong Kong or elsewhere). Snow Lake Capital may need to disclose your personal data in order to enforce any agreement with you, or protect our rights, property or safety, or the rights, property or safety of our employees.
Corporate Reorganization
As we continue to develop our business, we may reorganize our group structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate our business or a similar service under either this Hong Kong Privacy Notice or a different Hong Kong Privacy Notice which will be notified to you. Such a third party may be located, and use of your personal data may be made, outside of Hong Kong in connection with such acquisition or reorganization.
Access And Correction Of Personal Data
Under the PDPO, you have the right to ascertain whether we hold your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request us to inform you of the type of personal data held by us. All data access requests shall be made using the form prescribed by the Privacy Commissioner for Personal Data (“Privacy Commissioner”) which may be found on the official website of the Office of the Privacy Commissioner or via this link:
https://www.pcpd.org.hk/english/publications/files/Dforme.pdf
Requests for access and correction of personal data or for information regarding policies and practices and kinds of data held by us should be addressed in writing and sent by post to us (see the “Contact Us” section below).
A reasonable fee may be charged to offset our administrative and actual costs incurred in complying with your data access requests.
Protection of Individual Information
Snow Lake Capital will take all practicable steps to ensure the security of the personal data and to avoid unauthorized or accidental access, erasure or other use. Snow Lake Capital maintains appropriate physical, electronic and procedural safeguards to protect customer information. Snow Lake Capital restricts access to the personal and account information of individuals to those employees who need to know that information in the course of their job responsibilities. Snow Lake Capital will destroy, erase or make unreadable data, computer files and documents containing personal information prior to disposal.
Termination Or Cancellation
Should your account or relationship with us be cancelled or terminated at any time, we shall cease processing your personal data as soon as reasonably practicable following such cancellation or termination, provided that we may keep copies of your data as is reasonably required for archival purposes, for use in relation to any actual or potential dispute, for the purpose of compliance with applicable laws and regulations and for the purpose of enforcing any agreement we have with you, for protecting our rights, property or safety, or the rights, property or safety of our employees, and for performing or discharging our functions, obligations and responsibilities.
General
If there is any inconsistency or conflict between the English and Chinese versions of this Hong Kong Privacy Notice, the English version shall prevail.
Contact Us
If you have any questions about this Hong Kong Privacy Notice or our privacy policies, please email us at enquiry@snowlakecap.com.
Suite 1101-4, 11/F, One Exchange Square, Central, Hong Kong
+852 3700 3300