JH Capital Limited (“Company”, “we,” “our,” or “us”) is committed to protecting your privacy, confidentiality and security of the personal data we hold by complying with the requirements of the Personal Data (Privacy) Ordinance with respect to the management of personal data. We are equally committed to ensuring that all our staff uphold these requirements. This Privacy Policy sets out our policies and practices in relation to personal data, the kind of personal data we hold and explains how your personal data may be collected, used, and disclosed by us.

This Privacy Policy applies to our Website, its associated subdomains, alongside our membership program of Vincero Investment Academy (collectively, “Service”). By accessing or using our Service, you signify that you have read, understood, and agree to our collection, retention, use, handling and disclosure of your personal data as described in this Privacy Policy.

1. Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are referenced, it shall have the following respective meaning:

-IP address: Every device connected to the Internet is assigned a number known as an internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the internet.
-Personal Data: any data (a) relating directly or indirectly to a living individual; (b) from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and (c) in a form in which access to or processing of the data is practicable.
-Website: the website of Vincero Investment Academy, the current URL of which is:

2. What Personal Data Do We Collect?
We collect Personal Data from you when you visit our Website, subscribe to the membership program of Vincero Investment Academy or our Service, and/or register on site, place an order, respond to a survey or fill out a form.

The Personal Data we collect will include:
-Name / Username*
-Phone Numbers*
-Email Addresses*
-Mailing Addresses
-Billing Addresses*
-Bank account / credit card numbers*

3. How Do We Use The Personal Data We Collect?
Any of the Personal Data we collect from you may be used in one of the following ways:
-To deliver our products and services to you
-To personalize your experience (your information helps us to better respond to your individual needs)
-To improve our Website (we continually strive to improve our Website offerings based on the information and feedback we receive from you)
-To improve customer service (your information helps us to more effectively respond to your customer service requests and support needs)
-To process transactions, collect payments and sending billing information
-To manage your account
-To administer a contest, promotion, survey or other site feature
-To send periodic emails

4. Whether the supply of Personal Data is voluntary or obligatory?
Please note that it is obligatory for you to provide the Personal Data marked with asterisks in Clause 2 above. In the event that you do not provide such Personal Data, we may not be able to provide you with our Service or that the Service provided to you may be partial or undermined.

5. Do we share the Personal Data we collect with third parties?
We may share the Personal Data that we collect as stated in Clause 2 with third parties such as advertisers, contest sponsors, promotional and marketing partners for business operation purposes. If we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your Personal Data to our successors-in-interest which provides the same or similar services.

We may engage trusted third party service providers to perform functions and provide services to us, such as hosting and maintaining our servers and the Website, database storage and management, e-mail management, storage marketing, credit card processing, customer service and fulfilling orders for products and services you may purchase through the Website. We will likely share your Personal Data as stated in Clause 2 with these third parties to enable them to perform these services for us and for you. The third party service providers are under contractual obligations to handle personal data which mirror such obligation owed by the Company to the data subject.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the Website in a shared location, and type of the device used to visit the Website. They may aggregate information about our advertising and what you see on the Website and then provide auditing, research and reporting for us and our advertisers. 

We may also disclose Personal Data about you to government or law enforcement officials or private parties as we, in our sole discretion, consider necessary or appropriate in order to respond to claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

6. Where and when is Personal Data collected from customers and end users?
We will collect Personal Data that you submit to us. We may also receive Personal Data about you from third parties as described above.

7. How Do We Use Your Email Address?
By submitting your email address on the Website, you agree to receive emails from us. You can cancel your participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do. By submitting your email address, you also agree to allow us to use your email address for customer audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.

8. How Long Do We Keep Your Personal Data?
We keep your Personal Data only so long as we need it to provide the Services and fulfil the purposes described in this policy. This is also the case for anyone that we share your Personal Data with and who carries out services on our behalf. When we no longer need to use your Personal Data and there is no need for us to keep it to comply with our legal or regulatory obligations, we will either remove it from our systems or depersonalize it so that we can’t identify you.

9. How Do We Protect Your Personal Data?
We implement a variety of security measures to maintain the safety of your Personal Data when you place an order or enter, submit, or access your personal information. All supplied personal, sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential. After a transaction, your private information (credit cards financials, etc.) is never kept on file. We cannot, however, ensure or warrant the absolute security of any information you transmit to us or guarantee that such information may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

10. Could my information be transferred to other countries?
Our Company is incorporated in Hong Kong. Personal Data collected via our Website, through direct interactions with you, or from use of our help services may be transferred from time to time to third parties for the purposes stated in this Privacy Policy, located throughout the world, and may be viewed or processed anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border transfer and processing of such data.

11. Is the information collected through the Vincero Investment Academy Service secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. The Company has adopted protective measures such as restricting access of personal data to relevant employees on a “need-to-know” basis, providing relevant training to the employees to handle personal data properly and applying encryption to personal data when necessary.

However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. To the fullest extent permissible under applicable law, we shall not be liable for any loss, damage, claims, liabilities whatsoever in respect of any unauthorized access, use or disclosure of your information and Personal Data.

12. Can I access or correct my Personal Data?
You can contact us in order to (1) obtain access to or correct your Personal Data, (2) change your preferences with respect to communications and other information you receive from us, or (3) delete the Personal Data maintained about you on our systems (subject to terms of this Privacy Policy), by cancelling your account.

Any request to obtain access to your Personal Data shall be made under the form prescribed by the Privacy Commissioner for Personal Data (which can be downloaded from the website – and subject to the terms of such prescribed form. The completed form shall be sent to our responsible officer by email at

To protect your privacy and security, we may take reasonable steps (such as requesting a unique password, the presentation of your identity document, etc) to verify your identity before handling your request. You are responsible for maintaining the secrecy of your unique password and account information at all times.

We may charge a fee for complying with your request for access to your Personal Data and refuse to comply with the request until the fee is paid. The fee depends on the scope and complexity of your request, and will reflect the costs which are directly related to and necessary for complying with the request. We may also refuse to comply with the request in accordance with the Personal Data (Privacy) Ordinance.

You should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible for us to locate. Promptly after receiving your request, all personal information stored in databases we actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate, as soon as and to the extent reasonably and technically practicable.

13. Sale of Business
We reserve the right to transfer your Personal Data and non-personal information to our successors-in-interest which provides the same or similar services in the event of a sale, merger or other transfer of all or substantially all of the assets of the Company.

14. Governing Law
This Privacy Policy is governed by the laws of Hong Kong without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in Hong Kong in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy.

The laws of Hong Kong, excluding its conflicts of law rules, shall govern this Agreement and your use of the Website. Your use of the Website may also be subject to other local, state, national, or international laws.

15. Changes to this Privacy Policy
By accessing or using our Service, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not engage with our Website, or use our Service. Continued use of the Website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your Personal Data will mean that you accept those changes.

16. Links to Other Websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by our Company. We are not responsible for the content, accuracy or opinions expressed in such websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us. Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no longer applicable. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

17. Cookies
Our Company uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and functionality of our Website but are non-essential to their use. However, without these cookies, certain functionality like videos may become unavailable or you would be required to enter your login details every time you visit the Website as we would not be able to remember that you had logged in previously. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all.

18. Blocking and disabling cookies and similar technologies
Wherever you’re located you may also set your browser to block cookies and similar technologies, but this action may block our essential cookies and prevent our Website from functioning properly, and you may not be able to fully utilize all of its features and services. You should also be aware that you may also lose some saved information (e.g. saved login details, site preferences) if you block cookies on your browser. Different browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the cookie from your browser, you will need to do this yourself from within your browser, you should visit your browser’s help menu for more information.

19. Remarketing Services
We may use remarketing services. What Is Remarketing? In digital marketing, remarketing (or retargeting) is the practice of serving ads across the internet to people who have already visited a website. It allows your company to seem like they’re “following” people around the internet by serving ads on the websites and platforms they use most.

20. Payment Details
In respect to any credit card or other payment processing details you have provided us, we commit that this confidential information will be stored in the most secure manner possible.

21. Third-Party Services
We may display, include or make available third-party content (including data, information, applications and other products services) or provide links to third-party websites or services (“Third-Party Services”).

You acknowledge and agree that the Company shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect thereof. The Company does not assume and shall not have any liability or responsibility to you or any other person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them entirely at your own risk and subject to such third parties’ terms and conditions (including privacy policy for personal data).

22. Facebook Pixel
Facebook pixel is an analytics tool that allows measurement of the effectiveness of advertising by understanding the actions people take on a website. Facebook pixel may collect information from your device when you access a website. Facebook pixel collects information that is held in accordance with its Privacy Policy.

23. Enquiries
Any enquiries regarding the personal data privacy policy and practice of the Company may be addressed to our responsible officer by email at


Last updated: July 2021
Copyright © 2021 JH Capital Limited