Effective Date: July 21, 2025
This Privacy Policy (“Policy”) describes how Rukhex Technology (BVI) Limited (the “Company,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you access or use RWA Lab (the “Platform”). The Platform is a neutral information and resource hub for Real World Assets (“RWA”) issuance and investment, providing educational materials, curated project lists, and connections to intermediary services.
We are committed to protecting your privacy and handling your personal information in compliance with applicable data protection laws, including but not limited to the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) of Hong Kong, the General Data Protection Regulation (GDPR) where applicable, the California Consumer Privacy Act (CCPA), and other relevant regulations. By accessing or using the Platform, you consent to the practices described in this Policy. If you do not agree with this Policy, please do not use the Platform.
This Policy is designed to be clear, concise, and accessible, in line with the PDPO’s Data Protection Principles (DPPs), which emphasize fair collection, accuracy, appropriate use, security, transparency, and access rights. This Policy may be updated from time to time. We will notify you of material changes by posting the revised Policy on the Platform or through other communication channels. Your continued use of the Platform after changes constitutes your acceptance of the updated Policy.
1. Information We Collect
We collect personal information (as defined under the PDPO, meaning data relating to a living individual from which the individual’s identity can be directly or indirectly ascertained) to provide, improve, and secure the Platform’s services. Collection is limited to lawful purposes and is conducted fairly, with your informed consent where required. The types of information we may collect include:
a. Information You Provide Directly
b. Information Collected Automatically
c. Information from Third Parties
We do not intentionally collect sensitive personal information (e.g., racial or ethnic origin, political opinions, religious beliefs, health data) unless required for compliance purposes and with your explicit consent. All collection adheres to DPP1 of the PDPO, ensuring it is for specified purposes and not excessive.
2. How We Use Your Information
We use your personal information for the following purposes, in accordance with DPP3 of the PDPO (limiting use to the original collection purpose or directly related purposes, unless with your consent):
We process your information based on legal grounds such as your consent, contractual necessity, legitimate interests, or legal obligations. We ensure accuracy of data (DPP2) and retain it only as long as necessary.
3. Sharing Your Information
We do not sell your personal information. Sharing is limited and complies with DPP3 of the PDPO. We may share it in the following circumstances:
We ensure that any third parties receiving your information adhere to appropriate data protection standards. For cross-border transfers, we comply with PDPO requirements (including Section 33, if enforced) by using safeguards to ensure adequate protection in the recipient jurisdiction.
4. Data Security
We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, loss, misuse, or alteration, in line with DPP4 of the PDPO. These include encryption, access controls, and regular security audits. However, no system is completely secure, and we cannot guarantee absolute protection. You are responsible for maintaining the security of your account credentials.
In the event of a data breach involving personal data, we will notify the Privacy Commissioner for Personal Data (PCPD) and affected individuals as required under the PDPO amendments.
5. Data Retention
We retain your personal information only as long as necessary for the purposes outlined in this Policy, or as required by law, adhering to DPP2 of the PDPO. For example:
When no longer needed, we securely delete or anonymize your information.
6. Your Rights and Choices
In accordance with DPP6 of the PDPO and other applicable laws, you have rights regarding your personal information, including:
To exercise these rights, contact us at [email/support address]. We may verify your identity before responding. Under the PDPO, Data Access Requests must be processed within 40 days, and we will not charge a fee unless the request is unfounded or excessive. Requests under other laws are processed within their respective timelines (e.g., 30 days under GDPR, 45 days under CCPA).
You can also manage preferences by adjusting account settings, unsubscribing from emails, or disabling cookies.
7. International Data Transfers
The Platform may be hosted in Hong Kong, and your information could be transferred to countries with different data protection laws. We use safeguards like contractual clauses or adequacy assessments to ensure compliance with PDPO requirements for cross-border transfers.
8. Children’s Privacy
The Platform is not intended for individuals under 18 years old (or the age of majority in your jurisdiction). We do not knowingly collect information from children. If we become aware of such collection, we will delete it promptly.
9. Third-Party Links and Services
The Platform may link to third-party websites or services (e.g., intermediary resources). We are not responsible for their privacy practices. Review their policies before interacting.
10. Contact Us
For questions, concerns, to exercise your rights, or to make a Data Access Request, contact us via “Contact Us”.
You have the right to lodge a complaint with the Privacy Commissioner for Personal Data (PCPD) in Hong Kong if you believe your rights have been violated.
11. Changes to This Policy
We may update this Policy to reflect changes in our practices or legal requirements. Changes will be posted on the Platform, and we encourage you to review it periodically.
By using the Platform, you acknowledge that you have read and understood this Policy.