Personal Information Collection Statement (“PICS”)

Last Modified: 30.06.2026

Anchorpoint Financial Limited and any of its affiliates from time to time (collectively, “Anchorpoint”, “we”, “us”, “our”) will collect your Personal Data (being information that either identifies you or is about you as an individual) (“Personal Data”) so that we can provide our products and services to you, manage our relationship with our customers and partners, keep you and Anchorpoint secure, meet our business obligations and comply with the law.

You have the option of whether to provide us with your Personal Data. If you refuse to provide your Personal Data, we may not be able to provide you with our products or services and/or perform any obligations under contracts that we enter into with you from time to time. This is because your Personal Data may be needed for us to perform such obligations, undertake necessary know-your-customer (“KYC”) steps and/or comply with certain legal and regulatory requirements.

In this PICS, “Standard Chartered Group” means each of, or collectively, Standard Chartered PLC and its subsidiaries and affiliates (including each branch or representative office). Anchorpoint is part of the Standard Chartered Group.

1. What Personal Data do we collect?

We may collect and process some or all of the following Personal Data about you, as relevant and permitted or required by applicable law:

(a) your identity data, such as, your full name, login credentials, title, date of birth, gender, biometric information, your photographs, voice and video (including CCTV) recordings of you and other identifiers, including official/government identifiers such as national identification number, passport number and tax identification number;

(b) your contact data, such as your business and/or residential address, phone or mobile number and email address;

(d) information about criminal convictions or related information that we identify in relation to our financial crime prevention obligations, for example, details about any criminal convictions or related information. This includes details of offences or alleged offences or convictions;

(e) your social identity data, such as, your group/company data, information on referrals related to you; and

(f) your behavioral data, risk assessment data, KYC & compliance assessment data.

2. Who We Collect Data from

(a) We will collect Personal Data from our customers and other individuals in connection with the purposes set out in this PICS. These customers and other individuals may include the following, and we refer to them collectively as “you”, or “your” in this PICS:

(i) a customer of ours;
(ii) where applicable, a holder of any of our issued stablecoins;
(iii) a representative of, or an individual directly or indirectly related to or associated with: (1) a company, business or organisation that is our customer; or (2) a person or a company, business or organisation that has a relationship with customer; or (3) a company, business or organisation that is our business partner or service provider.

(b) We may also collect your Personal Data from the following sources in connection with the purposes set out in this PICS:

(i) your employer and/or company, business or organisation you represent or is related to you;
(ii) strategic referral partners, including business alliances or other companies or organisations that we or the Standard Chartered Group cooperate with based on our contractual arrangements;
(iii) fraud and crime prevention agencies, customer referral, public blockchain, and information in the public domain;
(iv) when you visit, browse, or use our websites or applications, we may use cookies to automatically collect certain information from your device.

3. Use of Your Data

We may use your data for any of the following purposes:

(a) considering and processing your application(s) (including assessing the merits and/or suitability of your application(s)) for Anchorpoint products and services;

(b) where applicable, processing the issuance, redemption, minting and burning of our issued stablecoins;

(d) meeting our internal operational requirements (including credit and risk management, system or product development and planning, carrying out testing and analysis and for insurance, audit and administrative purposes);

(e) enforcing your obligations, to us or any other member of the Standard Chartered Group;

(f) marketing services, products and other subjects (see clause 5 (Direct Marketing) of this PICS);

(g) responding to inquiries or managing complaints, including monitoring social media platforms and posts to identify conversations, sentiments, and complaints about Anchorpoint;

(h) recording our communications including online messages, emails, and telephone calls for record-keeping and evidential purposes; and

(i) meeting or complying with any obligations, requirements or arrangements for disclosing and using data that apply to us or any other member of the Standard Chartered Group, including those that we or any such member is expected to comply with according to:

(i) any present or future law or regulation within or outside Hong Kong;
(ii) any present or future guidelines or guidance issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong;
(iii) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers applicable to us or any member of the Standard Chartered Group by reason of its financial, commercial, business or other interests or activities in or related to the relevant jurisdiction (each an “Authority”); or
(iv) any investigation, demand or request from an Authority;

(j) meeting any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within the Standard Chartered Group and/or any other use of data and information pursuant to any group-wide programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing, fraudulent activities or other unlawful activities;

(k) enabling an actual or potential transferee, assignee of all or any part of our business and/or assets or participant or sub-participant of our rights in respect of you, to evaluate the transaction intended to be the subject of the transfer, assignment, participation or sub-participation;

(l) in connection with us or any member of the Standard Chartered Group defending or responding to any legal, governmental, or regulatory or quasi-governmental related matter, action or proceeding (including any prospective action or legal proceedings), including where it is in the legitimate interests of us or any member of the Standard Chartered Group to seek professional advice, for obtaining legal advice or for establishing, exercising or defending legal rights;

(m) in connection with investigating an insurance-related matter (including matters related to any member of the Standard Chartered Group);

(n) managing, monitoring and assessing the performance of any agent, contractor or third-party service provider who provides administrative, telecommunications, computer, payment, trust, distribution and/or custody, or other services to us in connection with the establishment, operation, maintenance or provision of any Anchorpoint product or service; and

(o) any other purposes relating thereto.

4. Disclosure of Your Data

Personal Data we hold is kept confidential but we may provide, transfer or disclose such data or information to other parties (whether within or outside Hong Kong) if it will help with any of the uses we’ve listed in clause 3 (Use of Your Data) of this PICS. These other parties include:

(a) any organisation, agent, contractor or third party service provider who provides administrative, telecommunications, identity verification / KYC, computer, payment/transaction, cloud storage or services, data analytics, cybersecurity, blockchain services, trust and custody, or other services to us in connection with the establishment, operation, maintenance or provision of any of our products or services to you;

(b) anyone who works for (or provides services to) us or the Standard Chartered Group;

(d) any person or organisation that Anchorpoint (or another member of the Standard Chartered Group) owes an obligation to (which may exist now or in the future) for the purposes set out in clause 3(i) of this PICS;

(e) any actual or proposed assignee or transferee of all or any part of Anchorpoint’s business and/or assets or participant or sub-participant or transferee of Anchorpoint’s rights in respect of you;

(f) charitable or non-profit making organisations;

(g) any external service provider that we engage to provide marketing services (including anyone who works for such a service provider);

(h) third party service providers with whom you have chosen to interact with in connection with your application for our products and services or your obtaining, holding or using of our issued stablecoin(s);

(i) other third party service providers to whom you have chosen to provide your information held by us in connection with the provision of services to you by those other third party services providers;

(j) any member of the Standard Chartered Group;

(k) any person or company who has a direct or indirect shareholding in Anchorpoint and their affiliates (each, a “Shareholder”) (for example, to find out whether or not you are a customer of theirs or their affiliates and what products and services they provide or could provide to you), and anyone who works for (or provides services to) a Shareholder; and

(l) any other person:

(i) where the public interest requires; or
(ii) with your express or implied consent.

We may also collect, use, disclose or transfer your Personal Data to other persons or organisations in accordance with your requests or instructions. In some cases, the persons to whom we disclose or transfer your information may be located outside of Hong Kong. Whenever we transfer your Personal Data out of Hong Kong, we will ensure that appropriate contractual safeguards are in place pursuant to the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (“PDPO”).

5. Direct Marketing

(a) We would like to use your Personal Data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. The data that we may use in direct marketing includes:

(i) your name and contact details;
(ii) your demographic data;
(iii) the products and services provided to you by us, or any other member of the Standard Chartered Group;

(b) To the extent permitted by applicable laws and regulations, we may directly market the following classes of services, products, and subjects:

(i) services and products offered by any member of the Standard Chartered Group;
(ii) services and products offered by our distributors and business partners; and
(iii) donations and contributions for charitable and/or non-profit making purposes.

(c) Along with us, the following persons may provide or solicit (in the case of donations and contributions) the services, products and subjects set out in clause 5(b) of this PICS:

(i) any member of the Standard Chartered Group;
(ii) our distributors and business partners and other third party service providers; and
(iii) charitable or non-profit making organisations.

(d) We may also provide your Personal Data to any of these people for them to use in direct marketing of the same services, products and subjects to you. We will always first obtain your consent (which includes an indication of no objection) for that purpose. We may receive money or other property in return for providing your Personal Data to these other persons, but we’ll tell you if this is the case when obtaining your consent.

(e) You have the right to ask us not to process your Personal Data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Data. You can also exercise the right at any time after we have collected and used your Personal Data for direct marketing purposes by following the opt-out instructions contained in the relevant communications.

(f) If you have any question or complaint related to our direct marketing, please contact us using the contact details set out in clause 7(b) (Access and Correction of Your Personal Data) below.

6. Personal Data of Another Person

Where you have provided us with another person’s Personal Data, you should provide him/her with a copy of this PICS and inform them of how we may use his/her data.

7. Access and Correction of Your Personal Data

(a) You have the following rights according to the terms of the PDPO:

(i) to check what Personal Data of yours we hold and be provided with a copy of it;
(ii) to require us to make changes to any Personal Data that is inaccurate;
(iii) to withdraw any consent that you have previously given us with respect to our use of your Personal Data;
(iv) to know our policies and practices on Personal Data;
(v) to be told what kind of Personal Data we hold and what you have access to;

(b) If you want to exercise any of the rights in this clause 7, please contact our Data Protection Officer via any of the following means:

(i) email us at dpo@anchorpoint.hk; or
(ii) mail to us at Level 6, Standard Chartered Building, 4–4A Des Voeux Road Central, Hong Kong.

8. Security

(a) Once we receive your data, we’ll do our best to protect it because the security of your Personal Data is important to us. We have technical and organisational security measures in place to safeguard your Personal Data (including Personal Data in transit and storage). These security measures ensure that the confidentiality and integrity of your Personal Data is not compromised. Multiple layers of protection have been put in place to protect against leakage of Personal Data to external parties. When using external service providers, we require that they adhere to certain security standards mandated by us. We may do this through contractual provisions, including any such provisions approved by a privacy regulator, and oversight of the service provider. Regardless of where Personal Data is transferred, we take all steps reasonably necessary to ensure that Personal Data is kept securely.

(b) You should also be aware that the Internet (including applications which use the Internet for data transfer) may not be a secure form of communication and sending us Personal Data over the Internet may carry with it risks including the risk of access and interference by unauthorised third parties. Information passing over the Internet may be transmitted internationally (even when the sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than your country of residence.

(c) Anchorpoint and the Standard Chartered Group retain Personal Data in line with applicable legal and regulatory obligations and for business and operational purposes. In the majority of cases, this will be for 7 years from the end of your relationship with us. You can ask us to delete some or all of your data earlier than this but we can only do so if:

(i) we have no legal or regulatory obligation to retain it; or
(ii) we don’t need it to provide a service that you would still like us to provide to you.

If we can’t delete your data promptly after you ask us, please be sure that we’ll let you know.

We and other members of the Standard Chartered Group may record and monitor electronic communications with you to ensure compliance with legal and regulatory obligations and internal policies.

You should also read our Privacy Notice and Cookie Policy when using our website and any online services.

This PICS is provided to you under Hong Kong’s PDPO.