1. Introduction and Scope of Application of the Privacy Policy
Salvus Capital Management, Inc. values the protection of users’ personal information and related business data. This Privacy Policy explains how the company collects, uses, stores, shares, and protects user information in the process of providing stock market research, investment analysis, investment management, and related services.
Users should carefully read this policy before submitting information, applying for services, or using related functions to understand how personal information is processed and their legal rights.
1.1 Scope of Application
This policy applies to individuals, organizations, and their legally authorized representatives who access the company’s website, review research materials, submit service applications, or receive related services.
1.2 User Confirmation
By submitting personal information or continuing to use the service, users indicate that they have read and understood this policy. If you do not agree to the processing methods, you should stop submitting information or using the relevant services.
1.3 Information Processing Principles
The company will process personal information in accordance with the principles of legality, legitimacy, necessity, and transparency, and will take reasonable measures to limit the scope of information collection, purpose of use, and retention period.
1.4 Relationship with Other Documents
These Terms and Conditions shall be understood in conjunction with the Terms of Service, Investment Management Agreement, and other specific documents. Where relevant documents expressly stipulate specific information processing matters, such stipulations shall apply to the extent permitted by applicable law.
2. Types of Information Collected by the Company
To provide appropriate stock market research, investment analysis, and investment management services, Salvus Capital Management, Inc. may collect necessary information related to the services based on user identity, service application, and compliance requirements. The Company will not collect irrelevant information beyond its stated purpose or the scope permitted by law.
2.1 Identity and Basic Information
The Company may collect the following information:
Name, date of birth, and nationality;
Identification and verification documents;
Country or region of residence;
Occupation, institutional affiliation, and authorization relationships.
2.2 Financial and Investment Information
To assess the suitability of the services, the Company may collect information on users’ financial status, sources of funds, investment objectives, investment experience, investment horizon, liquidity needs, and risk tolerance.
2.3 Service and Business Information
The Company may record user-submitted service applications, signed documents, investment restrictions, management instructions, portfolio information, report records, and other information related to service performance.
2.4 Technical and Usage Information
When users access the website or related functions, the Company may automatically collect device type, browser information, login time, IP address, page access records, and system operation logs to maintain service security and improve user experience.
3. Information Collection Methods
Salvus Capital Management, Inc. will collect user information in a legal, reasonable, and purpose-specific manner, based on service applications, eligibility verification, investment management, and internal operational needs. The Company will not obtain personal data through deception, coercion, or unauthorized means.
3.1 User-Provided Information
Users may proactively submit relevant personal and business information to the Company when filling out application documents, completing identity verification, signing agreements, conducting risk assessments, or updating information.
3.2 Records Generated During Service
The Company may generate the following records during the provision of services:
Service application and review records;
Investment objective and risk assessment data;
User instructions and authorization records;
Portfolio and report data;
Agreement performance and internal review records.
3.3 Automatic Information Collection
When users access the website or use related functions, the Company may collect necessary information through system logs, cookies, and similar technologies, including:
Device and browser type;
IP address and access time;
Page browsing and operation records;
Login status and security logs.
3.4 Legitimate Third-Party Sources
To the extent permitted by applicable law, the Company may obtain necessary information from identity verification agencies, public databases, professional service providers, or other legitimate sources, and take reasonable measures to verify the relevance, accuracy, and purpose of use of the information.
4. Purpose of Use of Personal Information
Salvus Capital Management, Inc. will only use user information to the extent that it has a legal basis, a clear purpose, and reasonable necessity. The Company will not use the collected information for activities clearly unrelated to its original purpose, unless authorized by the user or required by applicable law.
4.1 Provision and Management of Services
The Company may use user information to process service applications, verify user eligibility, assess investment objectives and risk tolerance, and provide investment research, investment management, and reporting services in accordance with specific agreements.
4.2 Compliance and Risk Management
To comply with applicable laws and internal management requirements, the Company may use the relevant information for:
Identity and authorization verification;
Funding source and service suitability review;
Fraud, unusual activity, and security risk identification;
Regulatory records, audits, and compliance reviews;
Dispute investigation and liability determination.
4.3 Service Improvement and Internal Operations
The Company may improve its research processes, service quality, website functionality, and internal management by analyzing service usage, user needs, and business records. Related data may also be used for employee training, quality checks, and operational planning.
4.4 Legal Obligations and Rights Protection
Where reasonably necessary, the Company may use user information to fulfill legal obligations, respond to requests from competent authorities, handle complaints or disputes, and protect the legitimate rights, property, and safety of the Company, users, employees, and third parties.
4.5 Anonymization and Statistical Analysis
The Company may, to the extent permitted by applicable law, aggregate, de-identify, or anonymize user information for business analysis, service evaluation, research improvement, and internal statistics. Information that, after processing, cannot reasonably identify a specific individual may be stored and used in accordance with applicable laws, but the Company will not attempt to re-identify the relevant users.
5. Information Sharing and Disclosure
Salvus Capital Management, Inc. will only share user information to the extent necessary to provide services, fulfill legal obligations, or protect legitimate rights. The Company will reasonably limit the content shared and require recipients to process the relevant data in accordance with the agreed purpose.
5.1 Service Providers
The Company may provide necessary information to the following entrusted service providers:
Identity verification and compliance review agencies;
Data storage and technical support service providers;
Audit, legal, and other professional advisors;
Agencies assisting in the performance of investment management services.
5.2 Legal and Regulatory Disclosure
The Company may disclose relevant information to the extent necessary and maintain reasonable records of processing, as required by applicable law, court orders, judicial proceedings, or regulatory authorities.
5.3 Corporate Restructuring and Business Transfer
In the event of a merger, reorganization, asset transfer, or business takeover, relevant information may be transferred to the participating parties in accordance with the law. The receiving party shall continue to process the information in accordance with applicable laws and relevant confidentiality requirements.
5.4 Sharing Restrictions
The Company will not require third parties to use user information for unauthorized independent purposes. Except as permitted by law or with the user’s separate consent, the receiving party shall not sell, disclose, or further disclose relevant information without authorization.
6. Information Storage and Retention Period
Salvus Capital Management, Inc. will store user information in a reasonable, secure, and appropriate manner, based on the purpose of the service, contractual relationships, compliance obligations, and internal management needs. The Company will not retain personal data indefinitely without legal basis or actual necessity.
6.1 Information Storage Methods
User information may be stored in the form of electronic documents, system records, or written materials. The Company will take access restrictions, classification management, backup protection, and other reasonable measures according to the nature of the data to reduce the risk of data loss, damage, or unauthorized use.
6.2 Retention Period
The Company will determine the information retention period based on the following factors:
The actual need to provide and manage related services;
The duration of the agreement and business relationship between the parties;
Legal, regulatory, auditing, and record-keeping requirements;
The need to handle complaints, disputes, or potential liabilities.
6.3 Retention After Service Termination
After a user ceases to use the service or a special agreement terminates, the Company may retain records of identity verification, investment management, authorization instructions, agreement performance, and compliance for a period required by applicable law or reasonably necessary.
6.4 Deletion, Destruction, and Anonymization
When the information retention period expires and there is no legitimate reason to continue retaining it, the Company will take reasonable measures to delete, destroy, or anonymize the relevant data. Information that cannot be immediately deleted due to backup systems, legal retention requirements, or technical limitations will continue to be subject to restricted access and security protection.
6.5 Periodic Review and Retention Management
The Company may periodically review the necessity, accuracy, and retention period of the information it retains, and make adjustments based on business changes, regulatory requirements, or the purpose of the data. For information that is no longer needed, has exceeded its retention period, or lacks a basis for continued retention, the Company will clean up, restrict its use, or dispose of it securely in accordance with internal procedures.
7. Information Security Protection Measures
Salvus Capital Management, Inc. values the confidentiality, integrity, and availability of user information, and takes reasonable technical, managerial, and organizational measures, based on the nature of the data, its processing purpose, and potential risks, to prevent unauthorized access, use, modification, disclosure, damage, or loss of information.
7.1 Technical Security Measures
The Company may take the following protective measures:
Authentication and access control;
Data encryption and secure transmission;
System logs and abnormal activity monitoring;
Data backup and recovery management;
Network, equipment, and system security protection.
7.2 Internal Management Measures
The Company allocates information access permissions based on employee responsibilities and actual work needs, and reduces the risk of misuse or disclosure of data through confidentiality systems, security training, operation records, and regular reviews.
7.3 Third-Party Security Management
When entrusting third parties to process user information, the Company will reasonably assess their information protection capabilities and require them to use the data only within the authorized scope through agreements, fulfilling their obligations of confidentiality, security, and lawful information processing.
7.4 Security Incident Handling
In the event of or suspected information leakage, loss, damage, or unauthorized access, the Company will promptly conduct investigations, control the impact, repair the problem, and retain relevant records. Where applicable laws require, the Company will fulfill its necessary notification obligations as stipulated.
7.5 User Security Responsibility
Users should also take reasonable measures to protect their data and service access permissions, including properly safeguarding login credentials, avoiding submitting information through insecure devices, and promptly reporting any abnormal situations. The consequences arising from a user’s voluntary disclosure of data, negligence in safeguarding data, or violation of security requirements shall be determined according to the actual circumstances and applicable laws.
8. User’s Personal Information Rights
Salvus Capital Management, Inc. respects users’ legally protected personal information rights. Users may make relevant requests regarding the personal information held or processed by the Company, in accordance with applicable laws and actual circumstances. Some rights may be subject to identity verification, legal record keeping, and other legal restrictions.
8.1 Inquiry, Access, and Obtaining Copies
Users may, in accordance with the law, apply to confirm whether the Company is processing their personal information and to inquire about the category, source, purpose of use, and sharing of relevant information. Where permitted by law and technically feasible, users may apply for a copy of their personal information.
8.2 Correction and Updates
If users find their personal information to be incorrect, incomplete, or outdated, they may apply for correction or supplementation. Users are also responsible for promptly updating material information that may affect eligibility verification, investment management, or service suitability.
8.3 Deletion and Restriction of Processing
Where applicable laws apply, users may request the deletion of personal information, restriction of specific processing activities, withdrawal of previous consent, or objection to information processing based on specific legal grounds.
8.4 Request Review and Processing Restrictions
To protect information security, the company may verify user identity and authorization relationships before processing requests. If relevant data must be retained by law, involves agreement performance, dispute resolution, security investigation, or the legitimate rights and interests of others, the company may refuse or restrict requests and handle them in accordance with applicable laws.
9. Cookies, Third-Party Services, and Cross-Border Processing
Salvus Capital Management, Inc. may use cookies and similar technologies to maintain website operation, ensure access security, record user preferences, and analyze service usage. The company will manage these technologies reasonably based on actual functions and applicable laws.
9.1 Cookies and Similar Technologies
The Company may use the following types of technologies:
Necessary cookies to maintain the operation of pages and basic functions;
Functional cookies to save language, display, and access preferences;
Statistical tools to analyze page visits and service performance;
Technical records to identify abnormal access and security risks.
9.2 User Selection and Management
Users can restrict, delete, or refuse some cookies through browser or device settings. Disabling technologies other than necessary cookies generally will not prevent basic access, but some preference saving, page display, or accessibility functions may be affected.
9.3 Third-Party Websites and Services
The Company’s website may contain third-party links, embedded content, or technical services. The relevant third parties independently determine their information collection and processing methods, and users should read their privacy statements before accessing the site. The Company cannot control the independently operated websites and information processing activities of third parties.
9.4 Cross-Border Storage and Processing
Due to the need for technical services, data storage, or professional support, user information may be accessed, stored, or processed in different countries or regions. The Company will take contractual, access restriction, and other reasonable safeguards to the extent required by applicable laws to reduce the information security risks associated with cross-border processing. 10. Minors, Updated Terms, and Other Provisions
This Privacy Policy remains in effect while users access the website, submit information, or use Salvus Capital Management, Inc.’s services, and should be understood in conjunction with the Terms of Service and specific agreements.
10.1 Information on Minors
The company’s services are primarily intended for users with full civil capacity and do not proactively collect information on minors who do not meet the eligibility criteria. If such information is discovered, the company may restrict its processing, delete it, or take other appropriate measures in accordance with the law.
10.2 Updated Terms
The company may modify or supplement this Privacy Policy in accordance with laws and regulations, regulatory requirements, business development, technological changes, or adjustments to information processing methods.
10.3 Effectiveness of Updates
Updates will take effect from the date of publication or indication. Users who continue to submit information or use the services after the terms have been updated indicate that they understand the updated information processing arrangements.
10.4 Processing of User Requests
When users submit access, correction, deletion, or other privacy requests, the company may verify their identity, authorization relationship, and scope of the request, and will process it within the time limit prescribed by applicable law.
10.5 Severability of Terms
If any part of these Terms is deemed invalid, illegal, or unenforceable, this shall not affect the legality, validity, or continued enforcement of the remaining Terms.
10.6 Applicable Law and Rights Protection
The collection, use, storage, and disclosure of personal information shall comply with the applicable laws specified in the formal agreement. These Terms shall not restrict the user’s legally protected and inalienable privacy rights and legitimate remedies.
