Version: March 2024



Hanmenghui (Henan) Asset Management Co., Ltd. Privacy Policy

Hanmenghui (Henan) Asset Management Co., Ltd. ("we", hereinafter referred to as "HME") respects and protects customers' personal information. When you use HME services, we will inform you through the "HME (Henan) Asset Management Co., Ltd. Online Trading Service Privacy Policy" ("This Privacy Policy") how we process your personal information, including but not limited to Collection, storage, use, processing, transmission, provision, deletion and sharing, etc., and how you manage your personal information. This Privacy Policy is closely related to your use of the service. I hope you read it carefully and make the choices you think are appropriate.

You know and confirm that you have agreed to the terms of this Privacy Policy when using HME services, and agree that we will legally process and protect your personal information in accordance with this Privacy Policy. If you do not agree or understand part or all of this Privacy Policy, you should immediately stop using our services and contact us through the contact information listed in this Privacy Policy.

Part One General Principles

Article 1: Scope of application

This privacy policy applies to the personal information you provide when purchasing our fund products and receiving our services through our online direct sales channels; online direct sales channels include:

Website: www.hme158.com

APP:【HME online trading platform】

Changes in the names and addresses of the above-mentioned websites and APPs will not affect the application of this privacy policy. If we open more online direct sales channels and process your personal information through these channels, this privacy policy will also apply.

Article 2: Third-party behavior

Please note: the third parties that provide you with products and services through the HME online trading platform, the website operators you visit through the HME online trading platform, and the operators who receive your information through the HME online trading platform API Third parties that provide services to you will store, use, process and protect your personal information in accordance with the standards described in their own privacy policies. This privacy policy cannot replace the privacy policies of the above third parties. We will try our best to require third-party service providers to provide an adequate level of security protection for your personal information and will clearly inform you on specific product pages that the services are provided by specific third parties. We also strongly recommend that you understand before using the above-mentioned third-party services. Confirm the privacy protection status of the service provider.

Part Two Privacy Policy

Article 1 This privacy policy will help you understand the following:

1. How we collect information

2. How we use information

3. How we share information

4. How we store information

5. How we protect information

6. How you manage your information

7. Protection of minors’ information

8. Applicable Law and Dispute Resolution

9. Revisions to this Privacy Policy

10. How to contact us

11. Others

Article 2 How we collect information

You agree and authorize us to collect the following necessary service-related information in accordance with currently effective laws, regulations and regulatory requirements when you register, log in and use the services we provide. You can choose not to provide certain or certain information. If you choose not to provide one or more information, it may cause you to be unable to use or unable to use some services of the HME online trading platform normally, but this will not affect your use of other services of the HME online trading platform.

1. Information you provide to us

2. Information collected during your registration, login and use of HME services

In order to improve the security of your use of our services, prevent your personal information from being obtained by criminals, and also to improve the service quality and user experience of the HME online trading platform, we may accept and record the equipment you use Relevant information to ensure the service security and reliability when you use HME services. This device information includes: device attribute information (such as device brand and model, device screen specifications, operating system version, device settings, unique device identifier, etc. Software and hardware feature information), device connection information (IP address, MAC address, browser type, telecom operator, language used, access date and time, and web page records you need). If you use our services on different devices or log in to the HME online trading platform, we may associate the information collected from your various devices so that we can provide you with services on your devices. Provide consistent service.

3. Allow us to collect information from third parties

4. Cookies (cache)

In order to provide you with an easier access experience, when you access the HME online trading platform or use HME services, we may identify you through small data files. This can save you from repeatedly entering registration information. steps, or help determine the security status of your account. These data files may be Cookies, Flash Cookies, or other local storage provided by your browser or associated applications (hereinafter referred to as "Cookies"). Please understand that some of our services can only be achieved through the use of Cookies. You can modify the acceptance of HME's cookies or reject HME's cookies if your browser or browser add-on services allow it (the "Help" section in the toolbar of most browsers will tell you how to prevent Your browser accepts new cookies or how to turn off cookies completely), but this may affect your safe access to HME online trading platform or use of HME services

5.  Sensitive personal information

When you use HME services, we may collect and process your sensitive personal information in accordance with the provisions of this privacy policy in accordance with relevant laws, regulations and business needs. The sensitive information we will collect and the corresponding purpose of collection have been indicated in boldface fonts above. If you do not agree to collect such sensitive information, we may not be able to implement the corresponding services or functions. By using HME services and confirming this privacy policy, you agree to our processing of the sensitive personal information agreed above. We will prompt you again when we collect such sensitive personal information. If your consent is required, we will, in accordance with the requirements of applicable laws, inform you of the purpose and processing methods of our collection of your sensitive personal information, as well as other content that needs to be informed in accordance with the law, and seek your separate consent.

Article 3 How we use information

1. In order to better provide you with services, for our own risk prevention and control, and to protect the legitimate rights and interests of all parties, you agree and authorize us to use your information for the following purposes:

2. When we want to use your information for other purposes not specified in this privacy policy, we will ask for your consent in advance. However, in accordance with relevant laws, regulations and national standards, we may collect and use your personal information in accordance with the law without your consent in the following situations:

Article 4 How we share information

1. Share

We promise to keep your information confidential in accordance with relevant laws, regulations and regulatory requirements. We will provide information to third parties (including competent authorities, regulatory agencies, self-regulatory organizations, and our affiliated institutions or partners) in accordance with the provisions of laws and regulations, the requirements of regulatory authorities, the need to provide services to you, or with your authorization. institutions, etc.) to share your information. Before sharing information, we will conduct a commercially reasonable review of the third party, assess the legality, legitimacy and necessity of the information they collect, and urge them to process your information in accordance with legal provisions and relevant regulatory requirements. If the above conditions are met and relevant legal documents are required to be signed in accordance with laws and regulations, we will sign relevant legal documents with the third party and require the third party to abide by laws and regulations when using your personal information, and try our best to require the third party to take action on your information for safeguard.

For the purpose of providing you with services, we will share your information with HME's affiliated institutions, cooperative institutions or other third parties (such as sales agencies, banks, third-party payment institutions, etc.) under the following circumstances:

4. Public disclosure

We will not disclose your personal information to the outside world except for the explicit requirements of laws and regulations or the explicit requirements of the competent authorities. If public disclosure is necessary, we will inform you of the purpose of public disclosure, the type of information disclosed and the sensitive information that may be involved, and obtain your separate consent.

Article 5 How we store information

In order to meet regulatory requirements, provide you with services, and facilitate you to check your transaction status or history, we will save the necessary information submitted or generated during your application or use of the services.

1. Save the region:

Your personal information collected and generated by us in the People's Republic of China will be stored in the People's Republic of China. If cross-border business is involved, we need to transfer your relevant personal information collected within the country to overseas institutions. We will clearly inform you of the purpose of transferring the information abroad, the identity of the recipient, relevant security measures and other necessary content, and we will ask you in advance. With your separate consent, and in accordance with the provisions of domestic laws, administrative regulations and relevant regulatory authorities, through effective measures such as signing agreements and personal information protection impact assessments, overseas institutions are required to keep the personal information they have obtained confidential again without your permission. Transfer, except for personal information that is prohibited from cross-border transfer by laws and regulations.

2. Storage period Unless otherwise provided by laws and regulations, we will store your information for the following period:

We will store your personal information in accordance with the requirements of applicable laws and regulations, such as: For now,

If different laws, regulations and regulatory requirements require different storage periods, we will store your personal information according to the longer required period. In order to provide you with HME services, we will keep your personal information until it is no longer needed for HME services, or delete or anonymize your personal information after you withdraw relevant consent/authorization or choose to cancel your account; If the retention period stipulated in laws and administrative regulations has not expired, or if it is technically difficult to delete or anonymize personal information, we will stop processing other than storing and taking necessary security protection measures.

For data that exceeds the storage period required by regulations, we will anonymize, seal or delete the data. Your personal information will be anonymized to form data that can be used and circulated. We do not need to notify you and obtain your consent for the storage and processing of such data.

Article 6 How we protect information

1. We have used security measures that comply with industry standards to protect the personal information you provide and prevent data from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably feasible measures to protect your personal information. However, please be aware that although we have taken the above security measures, personal information security incidents may still occur due to the emergence of various factors outside our control or the continuous development of external malicious means. If you find that your personal information has been leaked, especially your account or password, you should immediately contact us through the contact information provided by the HME Online Trading Platform so that we can take appropriate measures.

2. The Internet is not an absolutely secure environment, and emails, instant messaging, and communication with other users are not encrypted. We strongly recommend that you do not send personal information through such methods.

3. Account information is very important personal information, and you can only use your account through your password. Please use a complex password to help us keep your account secure. If you disclose your password, you may lose your identifying information and consequences may be adverse to you. Therefore, please properly set up and keep your account information on the HME online trading platform. If you find that your account and password have been or will be leaked for any reason, you should contact us immediately so that we can take appropriate measures in a timely manner to prevent or reduce related losses.

4. You know and agree that in the process of using HME services, or in the process of using HME partner agency services based on HME services, the HME online trading platform will form or authorize the HME online trading platform to collect and use The information saved in a certain form is jointly owned by you and HME online trading platform. You may not authorize third parties to collect, use or store such information through account lending, or by using technical methods on your own or by authorizing a third party. HME expressly states that Except by consent.

5. Minors’ information management

We will not actively collect personal information from minors under the age of fourteen. Minors using our services must be under the supervision of their parents or other guardians. We will protect the confidentiality and security of minors' personal information in accordance with relevant national laws and regulations.

If you are a minor, please ask your parents or other guardians to read this policy and use our services or provide us with your information with the consent of your parents or other guardians. For the collection and use of minors' personal information with the consent of the minor's parents or other guardians, we will only use or share this information as permitted by law, with the explicit consent of the guardian, or as necessary to protect your rights and interests. If your guardian does not agree with you using our services or providing information to us in accordance with this policy, please terminate your use of our services immediately and notify us in time so that we can take appropriate measures. If you are the guardian of a minor and you have questions about the personal information of the minor under your guardianship, please contact us through the contact information in this privacy policy.

In particular, if you are a child under the age of 14, please obtain the consent of your parents or other guardians before using our services or providing us with your information. For the use of your information with the consent of parents or other guardians, in addition to complying with the provisions of this privacy policy regarding user personal information, we will also adhere to the principles of legitimate necessity, informed consent, clear purpose, security and legal use, and strictly Storage, use, and disclosure will be carried out in compliance with the requirements of laws and regulations such as the "Provisions on the Internet Protection of Children's Personal Information" and will not exceed the period necessary to achieve the purpose of collection and use. After expiration, we will delete or anonymize children's personal information. If your guardian does not agree with you using our services or providing information to us in accordance with this policy, please terminate your use of our services immediately and notify us in time so that we can take appropriate measures.

6. Security incidents

Article 7 How you manage your information

In accordance with China's relevant laws, regulations, and standards, we greatly respect your concerns about personal information and provide you with methods to manage your personal information and exercise your rights. You have the right to access, correct, delete, revoke, manage your information and protect your privacy and security

1. View and copy personal information

Subject to exceptions provided by laws and regulations, we will strive to provide you with smooth access to your personal information whenever you use our services. You can exercise your access rights in the following ways:

In order to protect your information security and our legitimate rights and interests, you are not allowed to use other methods or authorize third parties to access or collect your personal information stored by HME Online Trading Platform without our consent.

2. Correction of personal information

When you need to update your personal information, or find that we have made errors in processing your personal information, you have the right to make updates or corrections and submit your correction request to us. You can submit your correction application through the online transaction page (My Account), HME trading platform (My Account), HME platform or the contact information provided in this privacy policy

3. Delete personal information

You can make a request to us to delete personal information under the following circumstances:

You can request us to delete your personal information through the contact information provided by HME Online Trading Platform. As permitted by laws, regulations and regulatory provisions, if we decide to respond to your deletion request, we will also notify our partner organizations or third-party organizations that have obtained your personal information from us and require them to delete it in a timely manner, or require them to obtain your personal information. otherwise agreed. When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but will delete the information when the backup is updated as required by laws and regulations.

However, please note that if we need to save your personal information in accordance with applicable laws, or if it is technically difficult to delete personal information, we will retain such personal information, but will not store it and take necessary security measures. Processing behavior other than measures

4. Withdrawal of consent

You can request to withdraw part or all of your authorization through the contact information provided by HME Online Trading Platform

After you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawal of consent or authorization, and we will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the effectiveness of previous personal information processing based on your consent or authorization.

5. Cancel account

You can apply for cancellation through the contact information provided by the HME online trading platform, or cancel your account in the HME APP-Account-Settings function. Canceling your account on the HME online trading platform will only cancel the corresponding account under our direct sales channel, and your accounts under other agency sales channels will not be affected.

In order to protect your or others' legitimate rights and interests, we need to verify your identity before canceling your membership account, and determine whether we support your cancellation application based on your use of HME online transactions. Unless otherwise provided by laws and regulations, we will stop providing you with corresponding services after canceling your account. We retain your personal information in accordance with regulatory requirements and will no longer use it for daily business. You can read relevant regulatory requirements on the registration page.

6. Respond to your requests

7. Rights of relatives of deceased users

Unless the deceased user has other arrangements during his or her lifetime, we guarantee that the deceased user’s close relatives have the right to access, copy, correct, and delete the relevant personal information of the deceased user in accordance with the law for their own legitimate and legitimate interests. You need to provide true and valid We will refer to relevant laws and regulations, regulatory requirements and the relevant rules of this privacy policy after verifying the materials you provide.

8. Exceptions

According to relevant laws, regulations, regulatory requirements, etc., we may not be able to respond to your request under the following circumstances if required by the competent state authorities or regulatory authorities, or if there are other circumstances agreed upon below:

9. Protection of minors’ information

We attach great importance to the protection of minors’ personal information. Please see this Privacy Policy - Minors’ Information Management


Article 8 Applicable Law and Dispute Resolution

1. Applicable law: The implementation, interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of the People's Republic of China.

2. Dispute resolution: If any dispute arises between you and us regarding the content of this Privacy Policy or its implementation, the two parties shall resolve it through friendly negotiation; if the two parties are unable to resolve the dispute through negotiation, both parties agree that the dispute shall be submitted to the Shanghai Arbitration Commission for arbitration. The arbitration is final and binding on both parties.


Article 9 Amendments to this Privacy Policy

Our privacy policy may change. Without your explicit consent, we will not reduce your rights in accordance with laws and regulations. We will post any changes to this privacy policy on the HME online trading platform. For major changes, we will show you the changed privacy policy in a pop-up window when you log in to the HME online trading platform. Please note that only after you click the consent button in the pop-up window, we will collect, use, share and save your personal information in accordance with the changed privacy policy. Significant changes referred to in this Privacy Policy include but are not limited to:

This privacy policy revision will take effect upon publication and will replace the previous relevant content. You should pay attention to relevant announcements, prompt information, agreements, rules and other related content changes from time to time. If this policy is updated, we will notify you by one or more methods such as publishing on our official website, push notifications, pop-up prompts, sending emails/short messages, etc. In order for you to receive timely notifications, it is recommended that you notify us in time when your contact information is updated. You know and confirm that if you do not agree with the updated content of the Privacy Policy, you should immediately stop using the corresponding services and cancel the relevant accounts. We will stop collecting your relevant personal information; if you continue to use our services, it means that you Have fully read, understood and accepted the updated Privacy Policy and are willing to be bound by the updated Privacy Policy.

Article 10 How to contact us

If you have any questions, comments or suggestions about this privacy policy, or if you have any comments or suggestions on the collection, use, sharing, access, correction, deletion, withdrawal and other related matters of your personal information when using HME services, or if you encounter any problems when using HME services, you can contact us through the following contact information. Under normal circumstances, we will reply within fifteen days.

Customer service email : support@hme158.com

If the above contact information changes, please refer to the latest notice on the official website.

Article 11 Others

If the terms of this privacy policy are inconsistent with the personal information protection and authorization terms stipulated in any service agreement adopted by the HME online trading platform (including but not limited to the "Hanmenghui (Henan) Asset Management Co., Ltd. Direct Selling Online Trading Service Agreement") In the event of any inconsistency or conflict, the relevant provisions of this Privacy Policy shall prevail. If there is any inconsistency or conflict between the provisions of this Privacy Policy and legal provisions or regulatory requirements related to personal information, the relevant legal provisions or regulatory requirements shall prevail.