CONSENT

to the Processing of Personal Data

Acting freely, by my own will and in my own interest, I, a user of the website https://www.vitaliberta.hk (the “Site”), hereby give my specific, informed, and unambiguous consent to Vita Liberta Limited (Company Registration Number: 2888240; Trust or Company Service Provider Licence No. TC007080), incorporated in Hong Kong with its registered office at Room 68, 7/F, Woon Lee Commercial Building, 7 Austin Avenue, Tsim Sha Tsui, Kowloon, Hong Kong (the “Company”), for the processing of my personal data on the terms set out below.

This consent is given in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”) and with the Company’s Privacy Policy, available at https://www.vitaliberta.hk/privacy-policy, which I have read and accept.

1. Categories of Personal Data

This consent covers personal data that I provide to the Company through forms on the Site, by email, by telephone, via messaging applications, in the course of in-person meetings, or by any other means, including:

full name;
contact details (telephone number, email address, messenger identifiers);
passport or other identity-document details; date and place of birth; nationality; gender;
residential and correspondence address;
professional and business data (job title, employer or company name, business registration details, tax identification numbers, professional qualifications);
beneficial ownership and corporate structure information, source of funds and source of wealth information;
financial data (bank account details, payment information, transaction history);
photograph or video where required for identity verification;
technical data collected automatically (IP address, cookie data, browser and device information, access time);
content of correspondence and records of communications with the Company;
any other data necessary for the provision of the services requested.

2. Purposes of Processing

The Company may process my personal data for the following purposes:

the conclusion and performance of agreements for the provision of corporate, legal, accounting, tax advisory, trust, and corporate service offerings, including the incorporation and ongoing administration of Hong Kong companies;
client identification and the conduct of customer due diligence (CDD), enhanced due diligence (EDD), ongoing monitoring, and sanctions and PEP screening, in accordance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance of Hong Kong (Cap. 615) and other applicable requirements;
handling enquiries, sending contractual and administrative notifications, and conducting business correspondence;
the operation and improvement of the Site and services, including analytics and technical support;
compliance with applicable laws, including corporate, tax (including FATCA and CRS) and regulatory requirements;
the protection of the Company’s rights and legitimate interests, prevention of fraud, information security, and dispute resolution.

3. Operations Performed with Personal Data

I agree that the Company may carry out any operations with my personal data that are necessary to achieve the purposes of processing, including collection, recording, organisation, accumulation, storage, adaptation or alteration, retrieval, use, disclosure, anonymisation, blocking, deletion, and destruction. Processing may be carried out by automated or non-automated means.

4. Disclosure to Third Parties

I acknowledge and agree that, in order to achieve the purposes set out above, the Company may disclose and transfer my personal data to the following categories of recipients, subject to confidentiality obligations:

the Company’s personnel, contractors, and affiliated entities;
professional advisors (external lawyers, auditors, accountants, tax advisors);
providers of IT infrastructure and cloud hosting, cybersecurity, identity verification and KYC, payment processing, CRM, analytics, and communications;
the Hong Kong Companies Registry, the Inland Revenue Department, banks, registrars, notaries, and government agents in the relevant jurisdictions, where necessary for the provision of the services;
government authorities, regulators, courts, and law enforcement agencies, where required by applicable law, regulation, court order, or to protect vital interests.

5. Cross-Border Transfer of Data

The Company is established in Hong Kong and provides its services from Hong Kong. If I am located outside Hong Kong, I agree that my personal data will be transferred to and processed in Hong Kong. I also acknowledge that my data may be transferred to the Company’s service providers whose infrastructure is located in other jurisdictions, to the extent necessary for the provision of the services and subject to appropriate contractual and technical safeguards.

This consent takes effect upon its acceptance (by ticking the relevant box on the Site or by other express confirmation) and remains in force throughout:

the period during which the Company provides services to me and our contractual relationship subsists;
the statutory retention periods, including the requirement to retain client identification and transaction records for a period of not less than five (5) years after the end of the business relationship under the AMLO, and not less than seven (7) years under the Inland Revenue Ordinance (Cap. 112);
the period necessary to protect the Company’s legitimate interests in the event of disputes or claims.

I may withdraw this consent at any time by sending a written request to legal@vitaliberta.hk or to the Company’s postal address set out above.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal. Withdrawal does not prevent the Company from continuing to process my data on other lawful grounds — in particular, for the performance of a contract with me, to comply with the Company’s legal and regulatory obligations (including AMLO record-keeping requirements), or to protect its legitimate interests.

I understand that withdrawal of consent may result in the Company being unable to continue providing services to me.

8. My Rights

I confirm that I have been informed of my rights under the PDPO and other applicable data protection laws, including:

the right to access my personal data and obtain a copy thereof;
the right to request correction of inaccurate or incomplete data;
the right to object to processing and to opt out of direct marketing at any time, free of charge;
the right to request erasure of my data in the cases provided for by law;
the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data of Hong Kong (www.pcpd.org.hk) or with another competent supervisory authority in my jurisdiction.

In accordance with Part 6A of the PDPO, the use of my personal data for direct marketing purposes requires my separate prior consent. I may grant or withhold this consent by ticking the box below. Failure to grant consent under this section does not affect the provision of services to me.

☐ I consent to the use of my contact details (email address and telephone number) to send me marketing and informational materials about Vita Liberta Limited’s services, including newsletters and promotional communications. I may withdraw this consent at any time, free of charge, by sending a request to legal@vitaliberta.hk.

10. Confirmation

By ticking the relevant box on the Site or otherwise expressly confirming my acceptance of this Consent, I confirm that:

I have read and understood the terms of this Consent and of the Company’s Privacy Policy;
I am providing my consent voluntarily, without coercion, and with full awareness of its legal consequences;
the data I provide is accurate and relates to me personally (or I am duly authorised to provide it on behalf of the person represented).

Vita Liberta Limited • Room 68, 7/F, Woon Lee Commercial Building, 7 Austin Avenue, Tsim Sha Tsui, Kowloon, Hong Kong

Email: legal@vitaliberta.hk • Telephone: +852 6841 6177Effective date: 29 May 2026