Privacy notice

Who is responsible

This site at jmdbuywozx.com is operated by JMD Corporate Services Limited, Business Registration No. 63808437, Room 1401, 14/F, Chung Ying Building, 20 Connaught Road West, Sheung Wan, Hong Kong. For the personal data described in this notice, JMD is the controller.

What this notice covers

This notice covers only your use of this website. It does not cover onboarding, identity verification, the exchange itself, or the custody and registration of shares. Those are dealt with in the Terms and Conditions of the Exchange Offer and in the privacy notice of the exchange portal.

What we collect on this site

This is an informational site. It has no account, no login and no form. We do not ask you for your name, your wallet address or any document.

We do process the following:

Technical data

IP address, browser type and version, operating system, device type, screen size, referring page, pages viewed and the time of the request. This is generated automatically by your browser when it requests a page.

Correspondence

If you write to us at the address below, we process your email address, your message and anything you choose to include in it.

We use no analytics. There is no measurement tool on this site, no tracking pixel and no advertising tag. We do not know which pages you read, how long you stay or where you go next.

We do not knowingly collect special categories of data through this site, and you should not send any to us by email.

Cookies and similar technologies

In normal browsing this site sets no cookies at all. It stores nothing on your device: no cookie of ours, no third-party cookie, no local storage. The bot-management and rate-limiting features that would place a cookie are deliberately switched off in our Cloudflare configuration.

One exception exists. If the security layer presents you with a challenge, because your request resembled automated traffic, Cloudflare sets a single cookie once you pass it:

cf_clearance

Records that the challenge was passed, so that you are not asked again on every page. It is set only after a challenge, never during ordinary browsing, and is strictly necessary to give you access to the site you asked for. Cloudflare processes it in the United States.

There is no consent banner. Consent is required only for cookies that are not strictly necessary. We set none of those, and the one cookie above exists solely to let a legitimate visitor through a security check.

This site loads its typeface from Google Fonts, a service of Google LLC. Your browser requests the font files directly from Google's servers, which means your IP address, the page you are on and basic browser information are disclosed to Google when a page loads. Google states that font requests are not used to identify individuals and that no cookie is set by the font service. We do not receive any of that data.

When a share price feed is connected, the page also calls a market data endpoint, which likewise sees your IP address.

Why we process it, and on what basis

• To deliver the site to you. Serving pages, maintaining security and preventing abuse. Our legitimate interest in operating a functioning and secure website.
• To answer you. Replying to correspondence you initiate. Our legitimate interest in responding, and the steps taken at your request before entering into a contract.
• To comply with law. Where we are required to retain or disclose information.

We do not use your data for automated decision-making or profiling, and we do not sell it.

Data collected on the exchange portal

If you proceed to the exchange portal, you will be asked for identity documents, proof of address, a declared wallet address and other information required by anti-money-laundering rules. That collection happens on the portal and is governed by its own notice.

Under the Terms and Conditions of the Exchange Offer, that data may be shared with JMD, with Troops, Inc., with the stock transfer agent, with custodians and with competent authorities, for the purpose of recording you in the share register and complying with disclosure obligations.

Who receives your data

We share the technical data described above only with the parties that make this site work:

• OVH SAS ("OVHcloud"), a French company, which hosts the site on its servers in Warsaw, Poland;
• Cloudflare, Inc., a United States company, which sits in front of the site as a content delivery network and security layer, and therefore processes your IP address and request data to serve pages and to filter malicious traffic;
• the market data vendor supplying the share price, where such a feed is connected;
• the font provider, unless fonts are self-hosted;
• our professional advisers, and any authority to which we are legally required to disclose.

We do not disclose your data to anyone else, and no one buys it from us.

Transfers outside your country

JMD is established in Hong Kong, the exchange counterparty in the Bahamas, and the stock transfer agent in the United States. Data may therefore be processed outside the country in which you live, including outside the European Economic Area, the United Kingdom and Switzerland.

The site is hosted by OVHcloud in Warsaw, Poland, so the hosting itself involves no transfer out of the European Economic Area. Cloudflare, however, operates a global network and processes request data, including any cookie described above, in the United States, and Google serves the fonts from its own infrastructure.

Where a transfer to the United States takes place, it rests on the following:

Cloudflare, Inc.

Certified under the EU-U.S. Data Privacy Framework, the UK Extension to it and the Swiss-U.S. Data Privacy Framework. Its standard Data Processing Addendum also incorporates the European Commission's Standard Contractual Clauses, so that a second basis remains available should a certification lapse.

Google LLC

Certified under the EU-U.S. Data Privacy Framework since September 2023, and under the UK Extension and the Swiss-U.S. Framework since September 2024, with Standard Contractual Clauses available as an alternative basis.

Transfers to the Bahamas and to Hong Kong, where those arise under the exchange offer rather than under this site, are governed by the Terms and Conditions of the Exchange Offer.

Given the narrow categories of data that leave this site, an IP address and the technical details of a page request, no separate transfer impact assessment has been carried out for these transfers.

How long we keep it

Server logs

Six months from the date of the request. Logs are kept to keep the site available and to investigate abuse, and are of no use to us beyond that period.

Correspondence

Twenty-four months from the last message in the exchange, so that we can follow up on a question and show what was said.

Records we must keep by law

For the period the applicable law requires, which may be longer than the periods above and overrides them.

Retention of onboarding and identity data is not governed by this notice. It is set by the exchange portal and by anti-money-laundering law, which in most jurisdictions requires such records to be held for several years after the relationship ends.

When a period expires the data is deleted or irreversibly anonymised.

Your rights

Depending on where you live, you may have the right to ask us for a copy of your data, to have it corrected or deleted, to restrict or object to its processing, to receive it in a portable form, and to withdraw consent where processing rests on consent. Withdrawing consent does not affect processing carried out before you withdrew it.

These rights arise under the Hong Kong Personal Data (Privacy) Ordinance, and, where they apply to you, under the EU General Data Protection Regulation, the UK GDPR and the Swiss Federal Act on Data Protection.

To exercise any of them, write to privacy@jmdbuywozx.com. We will respond within the period the applicable law allows. We may need to verify your identity first.

Security

The site is served over an encrypted connection. We apply access controls and keep the software we rely on up to date. No transmission over the internet is ever entirely secure, and we cannot guarantee absolute security.

Please note that we will never ask you for a seed phrase, a private key or a wallet password, by email or by any other means.

Children

This site is not directed at children and the exchange offer is not open to anyone under the age of majority in their jurisdiction. We do not knowingly process the data of children. If you believe we have, write to us and we will delete it.

Changes to this notice

We may update this notice. The version in force is the one published on this page, and the date below shows when it last changed. Where a change is material we will make it apparent on the site.

Contact and complaints

JMD Corporate Services Limited
Room 1401, 14/F, Chung Ying Building
20 Connaught Road West, Sheung Wan, Hong Kong

For anything concerning personal data, including any request to exercise the rights above, write to privacy@jmdbuywozx.com. For anything else, info@jmdbuywozx.com.

We have not appointed a data protection officer. One is required only of public authorities, of organisations whose core activity involves large-scale systematic monitoring, and of those processing special categories of data on a large scale. This site does none of these: it has no analytics, sets no cookies of its own and collects nothing beyond what your browser sends to load a page.

Representative in the European Union

JMD is established in Hong Kong. Where the General Data Protection Regulation applies to this site, our representative in the Union under Article 27 is:

Efforce Ltd (Malta)
171, Old Bakery Street
Valletta VLT 1455, Malta
Malta company registration number C86901

You may address the representative on any matter relating to the processing described in this notice, in addition to or instead of contacting us directly.

If you are unhappy with how we have handled your data you may complain to the Office of the Privacy Commissioner for Personal Data in Hong Kong, or to the supervisory authority in the country where you live.