Privacy Policy

FountainCap Research & Investment (Hong Kong) Co., Limited (the “Manager”), the funds advised or managed by the Manager and its or their Affiliates and/or delegates (together, for the purposes of this Privacy Notice, “FountainCap”, “we”, “us” or “our”) value our clients and investors and potential clients and investors (“you”). We strive to maintain your trust and confidence in FountainCap.

We collect certain personal data about you from i) information you provide to us on correspondences, through our website, applications or other forms and ii) information obtained from third parties or other sources, such as publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities. The categories of personal data we may collect include names, residential or business addresses, email or other contact details, signature, nationality, tax identification or ID number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, information on investment activities, or other personal information, such as information on political affiliations or criminal convictions that may be contained in the relevant materials and documents provided to us, or obtained through background searches.

Cookies are small files placed on the hard drive of your device, which may track and record information of your activities on our website (including your preference and behaviour, navigation on the website, login identity, etc.). Cookies and similar technology help FountainCap to provide customized services and information. If you prefer not to accept cookies from us, you may set your browser accordingly. If you choose to disable cookies in your browser, you may not be able to access all pages or use certain features on the website.

The personal data supplied by you is required for our operation. Your personal data may from time to time be used for the purposes of:

  1. managing and administering your investment with us,  
  2. managing and maintaining our relationships with you and for ongoing investor service,
  3. investigating and resolving complaints and managing contentious regulatory matters, investigations and litigation,
  4. compliance with the applicable legal and regulatory requirements (including those deriving from anti-money laundering and counter-terrorism legislation),
  5. improving our website and user experience, or
  6. which are directly relating to the above.

This use of your data is necessary 1) for performance of your contract with us, 2) in order for us to comply with any legal or regulatory obligations, or 3) for our legitimate business interest in managing our business including legal, regulatory, personnel, administrative, IT, business development and marketing, management and for the prevention and detection of crime or other breaches of laws and regulations provided our interests are not overridden by your interests.

Failure by you to provide or keep up-to-date personal data may result in FountainCap being unable to offer certain services.

We respect your privacy. We maintain physical, electronic and procedural safeguards to protect your personal data against unauthorized or unlawful processing. More information on the aforementioned safeguards is available upon request. Your personal and investment information will be accessible only to our employees, Affiliates and/or service providers on a need-to-know basis. All such employees, Affiliates, and service providers will be bound to maintain the privacy and security of your personal data in conformance with our privacy policy and applicable laws. We may also share your personal data in order to cooperate with legal or regulatory authorities or pursuant to a court order, subpoena, or similar legal process or government request.

You have the right to access, review, correct and/or erase (where the records are no longer required) any personal data held by FountainCap about you.

You are free to decide whether to allow us to use your personal data for directing marketing. We will not use your personal data for directing marketing unless we have received your consent to do so. You may withdraw your consent therefor by mail or by email.

All personal data is managed in accordance with and the use therefor is subject to the Personal Data (Privacy) Ordinance of Hong Kong and other applicable laws.

For information on our use of personal data in accordance with the Personal Data (Privacy) Ordinance of Hong Kong, please click here.
For information on our use of personal data in accordance with the Data Protection Law of the Cayman Islands, please click here.
For US individuals, please click here.
For residents of United Kingdom and the EEA, please click here.

How long your personal data will be held for will vary. The retention period will be determined by various criteria, including the purposes for which FountainCap and/or the service providers are using it (as it will need to be kept for as long as is necessary for any of those purposes) and legal obligations (as laws or regulations may set a minimum period for which FountainCap and/or the service providers have to keep your personal data).

You acknowledge and agree that FountainCap may process personal data that has become available to FountainCap in the process of you using this website, communicating with us and/or establishing business relationship with us in accordance with FountainCap’s personal data privacy policy. Such data procession may include, among other things, the transfer of personal data to countries which may not have data protection laws equivalent to those in Hong Kong or your jurisdiction of domicile. Where we conduct such transfers, they will be made in accordance with applicable data protection laws.

If you have any inquiries with respect to this Privacy Notice or any requests related to your personal data FountainCap maintains, please contact our Chief Compliance Officer at

Before entering, visiting and using our webpage, you must represent and agree that you or the institution you represent is a Qualified Investor, which is (i) a Professional Investor Under Cap 571 of Hong Kong "Securities & Futures Ordinance" Schedule 1, each as amended, (ii) either an “accredited investor” as defined in Rule 501(a) of the Securities and Exchange Commission (“SEC”) Regulation D and a “qualified purchaser” or “knowledgeable employee,” as those terms are defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Company Act”), and Rule 2a51-1 thereunder, and Rule 3c-5 thereunder, respectively, (iii) the Qualified Investor as defined under the latest applicable PRC laws and regulations, or (iv) a person or entity who meets certain eligibility qualifications based upon your country of residence. If you or your organization is in any doubt about your qualification as a Qualified Investor, you should obtain independent professional legal advice.

The term “website,” as used on this page, includes all information and materials issued and published by FountainCap Investment & Research (Hong Kong) Co., Limited (“FountainCap” or the “Company”). If you continue to read and access the information presented in this website, you will be deemed to have declared and agreed you are a "Qualified Investor" and that you will comply with the following terms and conditions. If you do not agree to the following terms and conditions, please do not enter, access or use this website.

FountainCap is licensed and regulated by the Securities and Futures Commission (hereinafter referred to as the "SFC") in Hong Kong. FountainCap is also registered with the U.S. Securities Exchange Commission (hereinafter referred to as the "SEC") as a Registered Investment Adviser. The information, tools and materials introduced on this website are provided by the Company and are not reviewed and approved by the SFC or the SEC. The above mentioned regulatory statuses do not imply a certain level of skill or training. The information, tools and materials described on this website are for general information only and do not constitute an invitation or offer to advertise or distribute, sell, offer, advise or buy any securities, funds or other investment instruments of the Company or third parties. The information, tools and materials described on this website are not intended to provide any form of advice, including but not limited to investment, taxation, accounting or legal advice. Past performance is not an indicator of future results. You should consult your own financial, tax and legal advisers as needed prior to making investment decisions and should carefully read the relevant product contracts and offering materials to ensure you can bear the risk of investment.

Investing in a fund or a security involves risks.  Investors should review the Fund's offering documents in order to obtain further information and understand risk factors of the investment as well as seek appropriate professional investment and tax advice as needed. The securities’ and fund's shares or unit prices will fluctuate, and past fund performance data does not indicate the future performance of the fund or the securities. The information provided on this website does not constitute investment advice or tax advice, and investors should not rely on the information provided by this website to make investment decisions.

The Company believes the information contained in this website is reliable and the Company endeavors to process the information contained in this website carefully, but the Company cannot guarantee and is not responsible for the accuracy, adequacy, completeness and suitability of the information.  No one may redistribute and/or publish any information obtained from this website without the express written permission of the Company.

FountainCap does not warrant and is not responsible for the safety, correctness and non-interruption of the services of this website. You agree by using this website that you voluntarily assume all risks of using this website and that you are responsible for any damages that may result from such risks when using this website. The Company shall not be liable for any loss of data due to technical failure (such as transmission errors, technical defects or third-party cyber-attack, etc.).

The contents of this website will be updated or revised regularly. The Company does not warrant or guarantee the timeliness of information updates to this website. The Company reserves the right to delete or modify the information of this website without any prior notice.

The Company and its directors and employees will not be liable for any direct or indirect damages arising from your access or use of this website or the inability to access or use this website.

The Company shall possess and reserve all the rights of other relevant disclaimers under the relevant laws and regulations.