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  • 1. Scope of Information Collection
  • 2. Purpose of Information Use
  • 3. Information Storage and Protection
  • 4. Information Sharing and Disclosure
  • 5. Your Rights
  • 6. Policy Updates

Privacy Policy

This Privacy Policy applies to the cross-border payment services provided to you by Sunmand Limited, a licensed entity under the Topoverse group (referred to as “we” or “us”). We strictly follow Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and other applicable data protection laws to protect your personal information and corporate data.

Effective date: [2026-10-20]

1. Scope of Information Collection

To provide compliant services and fulfil regulatory obligations, we collect the following necessary information:

  1. Corporate identity information: business licence, certificate of incorporation, shareholding structure, beneficial ownership information, and identity information of authorised representatives;
  2. Business background information: contracts, invoices, logistics documents, and other materials evidencing the authenticity of transactions;
  3. Account and transaction information: account details, transaction instructions, fund flows, reconciliation data, and other business data;
  4. System usage information: device information, log data, and operation records when you access the platform, used to safeguard system security and improve services.

2. Purpose of Information Use

The information we collect will be used only for the following lawful purposes:

  1. Conducting Know Your Customer (KYC) and customer due diligence, and fulfilling anti-money laundering and counter-terrorist financing compliance obligations;
  2. Processing your transaction instructions to complete core services such as cross-border remittance and currency exchange;
  3. Carrying out transaction risk monitoring and review to safeguard the security of fund transactions;
  4. Optimising platform features and service experience to improve system stability;
  5. Responding to your inquiries and complaints and handling related customer service needs;
  6. Complying with mandatory requirements of laws, regulations, and regulators.

3. Information Storage and Protection

  1. We retain your information for the period required by Hong Kong regulatory rules, store data using encryption technology, and maintain strict access controls so that only authorised personnel can access the relevant information.
  2. We have a professional information security team and technical protection systems, conduct regular security audits and vulnerability assessments, and guard against risks such as data leakage, tampering, and loss.
  3. We store your information only in Hong Kong and regulator-approved regions; where cross-border data transfer is required, we strictly follow applicable legal requirements to safeguard data transmission.

4. Information Sharing and Disclosure

We do not sell or rent your information to any third party. We share information only in the following circumstances:

  1. With your explicit authorisation and consent;
  2. To complete transactions, providing necessary transaction-related information to essential service partners such as partner banks, clearing institutions, and payment channels;
  3. Reporting relevant information as required by law by regulators such as the Hong Kong Customs and Excise Department and law enforcement agencies;
  4. Disclosing information within the scope permitted by law to protect our legitimate rights and interests.

5. Your Rights

Under Hong Kong's Personal Data (Privacy) Ordinance, you have the following rights:

  1. To enquire about and access the personal information we hold about you;
  2. To request correction of inaccurate or incomplete personal information;
  3. To request deletion of your personal information (except where retention is required by laws and regulations);
  4. To object to processing of your personal information beyond the agreed purposes;
  5. To withdraw your authorisation for information processing (without affecting processing already carried out based on the prior authorisation).

If you wish to exercise the above rights, please contact us via the officially published contact details, and we will respond within the statutory period.

6. Policy Updates

  1. We may update this Privacy Policy in accordance with regulatory requirements and business development, and the updated policy will be published through official channels. If you continue to use our services after the update, you are deemed to have agreed to the updated Privacy Policy.
Topoverse

Topoverse is a fintech company specializing in cross-border payments, committed to providing secure, compliant, and efficient cross-border payment and FX solutions for trading enterprises along the Belt and Road Initiative.

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Compliance Statement: Topoverse's subsidiary Sunmand Limited (MSO Licence No. 25-04-03272) holds a Money Service Operator licence issued by the Hong Kong Customs and Excise Department under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), and provides cross-border remittance and currency exchange services only. Customer funds are held in segregated accounts at partner banks. We do not provide banking services, accept deposits, issue stored-value facilities, or operate savings or investment accounts for customers. Content on this website is for general information only and does not constitute legal, tax, or investment advice or an offer.

© 2026 Topoverse. All rights reserved.

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