1. DISCLOSURE OF INFORMATION
    Lookcard Limited (the “Company”) needs to use and share customer’s information to operate effectively including in connection with our provision of products and services to you and for the purposes of client servicing. We will keep information provided by or relating to you confidential, except that we may disclose such information (i) to any Entity Member if applicable; (ii) to any Entity  Member’s professional advisor, insurer, insurance broker or provider of services to facilitate the Company’s operations and provision of products and services across multiple countries (such as operational, administrative, data processing and technological service providers) who are under a duty of confidentiality; or (iii) as required by Law or any Authority.

    “Affiliate” means, in relation to a company, any of its subsidiaries, holding companies or any other subsidiary of any such holding company and (where applicable) any representative and branch office in any jurisdiction.

    “Authority” means, government, quasi-government, administrative, regulatory or supervisory body or authority or court or tribunal having jurisdiction over any Entity Member.

    “Entity Member” means the individual from the Company or any of its Affiliates 

    “Group” means all subsidiary companies; the Company’s cooperative partners and agency.

    “Law” means any law, regulation, rule, directive, order, request, guideline, sanction, embargo and restriction of or agreement with any Authority.

  2. PRIVACY
    To comply with applicable Laws and in the course of providing products and services to you, we will need to collect, hold, use and share Personal Information of your Data Subjects. Our Privacy Policy (https://lookcard.io/docs/privacy-policy/) outlines how the Group processes Personal Information. You agree to make your Data Subjects aware of our Privacy Statement.

    “Data Subjects” means all individuals whose Personal Information we receive in the course of our relationship with you, including your direct and indirect beneficial owners, directors, officers and authorized persons etc.

    “Personal Information” means any information relating to Data Subjects.

  3. COMPLIANCE WITH LAWS AND FINANCIAL CRIME COMPLIANCE
    The Group is committed to complying with Laws (including applicable financial crime compliance laws and regulations such as those related to anti money laundering, anti-bribery and corruption) in all jurisdictions in which the Group operates. As the Group’s ability to comply with Laws is directly linked to the conduct of our clients, we require you to comply with such Laws, and conduct your transaction in a manner which will not place yourself or the Group in breach of such Laws.

    If you become aware of any breach, or any action, investigation or proceeding brought against you with respect to any breach of any applicable Law in connection with our provision of products and services to you or matter set out in this Statement, you will notify us promptly (unless prohibited by Law to do so).

  4. KNOW-YOUR-CUSTOMER & ANTI-MONEY LAUNDERING PROCEDURES
    As financial crimes become more diverse and sophisticated, and terrorist crimes continue to occur in various parts of the world, safeguarding and strengthening countermeasures against money laundering, terrorist financing, and proliferation finance (hereinafter referred to as “anti-money laundering”) are becoming critically more important for the economy and national security of the jurisdictions in which we operate for our valuable customers by preventing the transfer of criminal proceeds and cutting off the supply of funds to terrorist organizations.

    We may, at our sole discretion or as otherwise required by law, conduct appropriate Know-Your-Customer (KYC) and/or Anti-Money Laundering (AML) procedures, for which you will need to register in full and provide us with specified documents to prove and establish your identity. 

    During registration, you may need to provide, including but not limited to, your full name and/ or the full legal name of the entity that you represent or acting on behalf of, whenever applicable, residential address or incorporation/ business address, date of birth or date of incorporation, nationality, contact number, and email address. 

    The KYC documentation that we may request may include, but not limited to the following:

    • Proof of identity or incorporation, including any relevant business registration documents, annual returns etc.
    • Information of address/ financial documents (if applicable).
    • Articles of Association & shareholding chart (if applicable).
    • Proof of source of funds or wealth (if applicable), for example investment statements or pay slips.

      We may suspend, terminate or reject your account or the business relationship until a satisfactory identification document or documentary evidence on the source of funds or wealth is provided. If any of your KYC documentation expires or is no longer valid, we have the right to request an additional valid and non-expired KYC documentation from you. 

      You agree to allow your information (individual or corporate) to be disclosed to lookcard.io platform and its service providers for the purposes of KYC verification and any other screening checks. You further agree, represent and warrant that by providing us your information, including information on any related or connected parties, you undertake that the disclosure of any personal data to the Company is for our purpose and is within the scope of consent given to you by such related or connected parties.

  1. SANCTIONS
    The Group is obliged to comply with sanctions Laws including those of the United States, European Union or any of its member states (“Sanctions”). Any breach of Sanctions may have a serious impact on our reputation, franchise, regulatory relationships and could impair the Group’s ability to provide products and services to and enter into transactions with clients.

    As the Group’s ability to comply with Sanctions is directly linked to the conduct of our clients, you confirm and will ensure that (i) you are not targets or the subject of Sanctions; and (ii) no product, service or transaction (or proceeds of the same) involving an Entity Member has or will be utilized for the benefit of any person that is a target or subject of Sanctions or in any manner that would result in you or any Member being in breach of any applicable Sanctions or becoming a target or subject of Sanctions.

    The Company reserve the right to withhold products, services or transactions processing if such actions may result in a breach of the Group’s Sanctions Policy. 

  2. TAX INFORMATION COMPLIANCE
    The Group has obligations under various tax information reporting Laws (such as the Foreign Account Tax Compliance Act) to collect information from our clients, report information to Authorities and withhold tax from payments to clients in certain circumstances.

    We may require you or your Data Subjects to provide documents and information for the purposes of establishing your tax status and that of your Data Subjects. You will promptly inform us of any changes to such documents and information or change in circumstances that may indicate a change in your tax status or that of your Data Subjects.

    If you or your Data Subjects do not provide documents or information when we request it, we may make our own decision about your tax status and treat you accordingly. We may be required to withhold taxes from payments made to you for onward remittance to applicable Authorities.

  3. INITIATIVES TO PREVENT BRIBERY AND CORRUPTION
    In response to domestic and international laws and regulations related to bribery, and corruption, as well as growing social concerns, we are working to ensure appropriate responses. To promote sound corporate governance, the Company recognizes the social impact of bribery and corruption, prohibits officers and employees from being involved in bribery and corruption, and practices honest and fair conduct.
  4. CUTTING OFF RELATIONSHIPS WITH ANTI-SOCIAL FORCES
    We have firmly established a stance to sever all affiliations with antisocial entities that jeopardize the order and security of civil society.
  5. COMPLIANCE MANAGEMENT SYSTEM
    The Company’s operations and important subjects are deliberated at the compliance committee, and compliance is prompted under Money-Laundering Reporting Officer, Compliance Officer and CEO/ delegate of the Company.
  6. CLIENT CLASSIFICATION
    From time to time, we may request and obtain information from you and/ or third-party or public sources, to determine your regulatory classifications (or that of the funds that you manage) under applicable Laws. These classifications will be notified to you and used by us to comply with our obligations including reporting, business conduct, margin and collateral, and other requirements under applicable Laws.

    You will inform us immediately and in any event prior to entering into any transaction with us if any regulatory classification that we have previously notified you of or information (including contact details) that we have about you and/ or the funds that you manage is known by you to be inaccurate or incomplete. Unless we receive notification otherwise, you shall be deemed to have (i) confirmed such regulatory classifications and that the information that we have about you and/or the funds that you manage is complete and accurate; and (li) agreed and consented to the Group reporting your derivative transactions with us to any Authority (including trade repository(ies)).

  7. PROVISION OF INFORMATION
    You agree to (or will procure that your Affiliates and Data Subjects) provide such documents and information as we may reasonably request in relation to matters covered by this Statement. You will promptly inform us of any changes to documents and information provided to us so that they are up to date, accurate and complete.
  8. NO BREACH
    We are not obliged to do anything or omit to do anything if by doing so it would or might cause us to breach any applicable Law.
  9. TERMINATION AND SUSPENSION
    We may suspend a transaction or service or terminate a transaction, service or our relationship with you if (i) you breach any applicable Law or any matter set out in this Statement or (ii) by executing the transaction, providing the service or continuing our relationship with you, it will cause us to breach any applicable Law.
  10. LEGITIMATE USE
    You agree to use the Company’s Website, products and services only for legitimate purposes. You may not use the Company Website:
    • In any way that breaches any applicable local or international law or regulation.
    • In any way that is unlawful or fraudulent or has any unlawful or fraudulent purpose or effect.
    • To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards.
    • To transmit, or procure the sending of, any unsolicited or unauthorized advertising or promotional material or any other form of similar solicitation (spam).
    • To generate and/or cause congestion to our network traffic more than reasonable and normal usage.
    • To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware; or
    • To interfere with, damage (or attempt to interfere with or damage) or reverse-engineer any code, data or software on or associated with the Website.
  11. PRODUCT DOCUMENTS
    This Statement shall form part of any specific legal documentation governing a product, service or transaction that you have or may enter with us (“Product Documents”). The relevant terms of such Product Documents will prevail to the extent they are in addition to or inconsistent with this Statement.
  12. LANGUAGE
    This Statement is provided in English only. Should any inconsistency arise once the Chinese versions becomes available, the English version shall prevail.
  13. UPDATES
    We reserve the right to amend this Statement from time to time and will make such updates available to you including, without limitation, by way of letter, email or on our website. These updates shall apply to our relationship going forward and automatically.
  14. DISCLAIMER
    The Company’s core management principles emphasize strict compliance with laws and regulations while conducting honest and fair corporate activities that uphold and respect social norms.

    We acknowledge our critical role in society and the economy:

    • To uphold this responsibility, we have established a robust compliance system that earns the trust of our valued customers and ensures honest and fair corporate practices.
    • Strengthening our compliance framework by addressing measures to prevent money laundering, severing ties with anti-social entities, and adhering to stringent global regulations on market transactions and personal information management.
    • Promoting a culture of compliance by fostering awareness among staff through effective communication and comprehensive training programs.