1. Introduction

These Terms of Service contain the terms governing the relationship between the user and the platform Polytech, which is managed by Polytech Global Solutions Limited (HKSAR BRN 80427335), including its subsidiaries and affiliates, and apply to any customer or agent interaction with any services or products of the company.

Company Details
Polytech Global Solutions Limited
HKSAR Business Registration Number: BRN 80427335
Address: Unit 1510, Seapower Tower Concordia Plaza, 1 Science Museum Road, Tsim Sha Tsui (TST), Hong Kong

2. Applicable Legal Requirements

These Terms are made in accordance with the jurisdictional requirements of the Hong Kong Special Administrative Region (HKSAR) and, in particular, with the HKSAR legislative acts directly or indirectly related to the regulation of the business activities of companies:

• Companies Ordinance (Cap. 622): A key regulation governing corporate activities at all stages of a company’s existence (including private companies limited by shares), from its establishment and the issuance of shares to the responsibilities of directors, accounting and financial reporting, auditing, disclosure, reorganization, and liquidation.
• Companies Registry: The statutory body of Hong Kong SAR, which is the leading corporate register and administers legal requirements for companies under the Financial Services and the Treasury Bureau (FSTB).
• Electronic Transactions Ordinance (Cap. 553): Governing the legal use of electronic documents, electronic signatures, and digital transactions made through digital platforms, in accordance with other requirements of contract law and e-commerce rules.
• Consumer Protection Acts: The Trade Descriptions Ordinance (Cap. 362) on unfair trade practices under the control of the HK Customs and Excise Department; the Consumer Goods Safety Ordinance (Cap. 456) on the safety of consumer goods; and the Unconscionable Contracts Ordinance (Cap. 458) on unfair conditions of services provided.
• Individual Ordinances and Notes, described in more detail in related company documents: The Personal Data (Privacy) Ordinance, PDPO (Cap. 486); Codes of Practice and Guidance Notes from the PCPD; the Telecommunications Ordinance (Cap. 106); the Control of Exemption Clauses Ordinance (Cap. 71); the Anti-Money Laundering and Counter-Terrorist Financing Ordinance, Cap. 615 (AMLO); and others.
• Other separate Ordinances for compliance with HKSAR: The Business Registration Ordinance (Cap. 310) on activity registration; the Competition Ordinance (Cap. 619) on competition; the Inland Revenue Ordinance (Cap. 112) on tax obligations; the Employment Ordinance (Cap. 57) on labour relations; and the acts for intellectual property protection, namely the Copyright Ordinance, Cap. 528 and the Trade Marks Ordinance, Cap. 559.
• Sector regulations: Rules and laws issued by sector regulators, such as the Hong Kong Monetary Authority, the Securities and Futures Commission (Securities and Futures Ordinance, Cap. 571), and others.
• Other international and local conformity standards.

3. Regulatory and Jurisdictional Restrictions

The availability of the platform and the ability to use the products and services provided by the company may depend on the location/residence of the customer. Some platform products and features may not be available to certain users, or may be subject to territorial restrictions or additional conditions.

4. Limitation of liability

The company warns that the use of prediction-based and complex financial products is risky and may not be suitable for all users. The use of Polytech services does not guarantee that a customer will achieve expected results, will not suffer losses, or will earn revenue from using platform tools. Materials related to the company are published for informational purposes only and do not constitute an offer or an investment recommendation.

5. Safety standards

As part of ensuring infrastructure risk resilience, the Polytech company adheres to the necessary security measures in accordance with DPP4 of the PDPO and the Protection of Critical Infrastructures (Computer Systems) Ordinance (Cap. 653) requirements for organizations recognized as critical infrastructure operators.

We apply comprehensive corporate ERM security standards including access control, encryption, separation of duties, liquidity reserves, compliance audits, response regulations, stress tests, AI leak prevention, and other monitoring procedures.

We are also guided by well-established cyber threat management models, such as NIST CSF 2.0, the international ISO/IEC 27001 standard, and CIS Critical Security Controls set at an enhanced IG3 implementation level, as well as other information security solutions.

6. Processing of personal data

The Company may collect, store, process, use, disclose, retain, and protect customers' personal data obtained through interaction with the Company’s products. The processing of such data is carried out in accordance with the requirements of the Personal Data (Privacy) Ordinance, PDPO (Cap. 486), and other HKSAR regulations related to the use of sensitive information of Polytech users.

We collect sensitive information fully in accordance with Data Protection Principle 1 (Schedule 1 to the PDPO) in an exclusively lawful and good-faith manner, and at the minimum extent necessary for purposes related to the company's operations.

We are also guided by well-established cyber threat management models, such as NIST CSF 2.0, the international ISO/IEC 27001 standard, and CIS Critical Security Controls set at an enhanced IG3 implementation level, as well as other information security solutions.

7. Intellectual property

All materials published on behalf of the company on the website, in applications, or on social networks, or posted by users within the Polytech Agent Program, including texts, images, audio-visual materials, source and object codes, graphic elements, trademarks, logos, other brand names, and other content, are owned by the company and protected under applicable HKSAR legislation:

• Copyright Ordinance (Cap. 528): Copyright law.
• Trade Marks Ordinance (Cap. 559): Trademark protection.
• Patents Ordinance (Cap. 514): Patent law.
• Registered Designs Ordinance (Cap. 522): Protection of design samples.

Subject to these Terms, we grant our customers a limited, non-exclusive, non-transferable, and revocable license to legally use Polytech materials. Any unauthorized copying, distribution, or other use of the materials without the prior written consent of the Company is prohibited.

8. Acceptance of the Terms

By accessing the Company’s services, you acknowledge that you have read and understood these Terms of Service and that you have the legal capacity to do so. If you disagree with or misunderstand any part of this document and the applicable terms, we recommend that you refrain from using Polytech products.

Before proceeding, carefully evaluate and confirm whether the appropriate product, strategy, or proposed cooperation model is suitable for you. Take into account your goals, financial resources, investment horizon, level of knowledge, and personal experience, your ability to withstand losses, and your attitude towards uncertainty.

9. AML and CFT Compliance

In order to prevent the use of the products and services of the company for the legalization of criminal proceeds and the financing of terrorism, as well as to comply with FATF international standards and the legislation of HKSAR (the AMLO Ordinance and regulations of industry regulators), and based on the risk-based approach, the company implements appropriate AML/CFT control measures commensurate with the nature, scope, and level of the identified risk.

We adhere to the concept of minimal client involvement in legal procedures, and exclusively when there are reasonable grounds or at the request of law enforcement.

10. Service Restrictions

In the event of a reasonable suspicion that a user is violating these Terms or international and local legal requirements, committing fraudulent acts, illegally using payment instruments, concealing or arranging unauthorized transactions, attempting to circumvent established limits, procedures, access control, or security measures, using automated scripts, engaging in Sybil activities, performing vulnerability scans, distributing malicious software, or engaging in other illegal actions, the company has the right to impose temporary restrictions on the account of the violator or refuse to provide services to such user until the matter is resolved.

11. Dispute resolution

All disputes, disagreements, or claims arising out of or in connection with these Terms shall be initially settled by negotiations between the parties, with both parties making reasonable efforts to reconcile.

If a dispute is not settled within 60 (sixty) calendar days of receipt of the written notice of the dispute, it shall be subject to final adjudication by arbitration in Hong Kong administered by the Hong Kong International Arbitration Centre (HKIAC) in accordance with the applicable HKIAC Arbitration Rules.

12. Version Control

The text of these Terms of Service may be modified, supplemented, or completely updated by the company without prior notice and posted on the platform website for the user's review.

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1. Introduction

This Global Privacy Notice (also serving as our HKSAR-regional Personal Information Collection Statement or "PICS") explains how Polytech Global Solutions Limited (HKSAR BRN 80427335), including its subsidiaries and affiliates (collectively, "Polytech" or the "Company"), collects, stores, processes, uses, discloses, and protects the personal data of platform users, agents, and customers.

2. Applicable Legal Requirements

This Notice is compiled in accordance with the jurisdictional requirements of the Hong Kong Special Administrative Region (HKSAR) and, in particular, with HKSAR legislative acts directly or indirectly related to the processing of personal and sensitive information:

• Personal Data (Privacy) Ordinance, PDPO (Cap. 486): The primary law of the HKSAR governing the processing of personal data. Its structure includes the six Data Protection Principles (DPPs), specialized articles, and Ordinance sections. We also account for the 2012 and 2021 amendments to the PDPO regarding direct marketing and unlawful disclosure.
• PCPD Codes and Notes: Codes of Practice and Guidance Notes issued by the Office of the Privacy Commissioner for Personal Data (PCPD).
• Specialized Ordinances: Laws governing specific categories of confidential information, including the Unsolicited Electronic Messages Ordinance (Cap. 593), the Telecommunications Ordinance (Cap. 106), and the Crimes Ordinance (Cap. 200), among others.
• Protection of Critical Infrastructures (Computer Systems) Ordinance (Cap. 653): Cybersecurity management requirements and computer system protection responsibilities applicable to critical infrastructure operators.
• Sector Regulations: Rules and guidelines issued by sector regulators, including the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC), among others.
• Artificial Intelligence Guidance: The Artificial Intelligence: Model Personal Data Protection Framework issued by the PCPD, containing practical recommendations on the responsible implementation of AI in compliance with the PDPO.
• International and Local Compliance Standards: Other relevant global and regional compliance frameworks.

3. Data User and Controller Roles

In accordance with the PDPO, the Company acts as a "data user"—the entity responsible for determining the purposes for which, and the manner in which, personal information is collected, stored, processed, and used. The Company may engage external service providers and data processors to process such data on its behalf.

For the purposes of applicable foreign data protection laws—such as the EU/UK General Data Protection Regulation (GDPR) and similar regulatory regimes—the Company may also be considered a "data controller."

4. Categories of Personal Data

Depending on the nature of the relationship between the customer and the Company, we may collect and process the following categories of personal data:

• Identification and Contact Information: Given name, family name, date of birth, phone numbers, email addresses, other contact details, and social media accounts. This includes account and authentication credentials, as well as information required to comply with Know Your Customer (KYC), Anti-Money Laundering (AML), sanctions, and counter-terrorist financing legislation.
• Technical Data: Information regarding platform and application usage, including IP addresses, login device and software specifications, web activity, user actions, cookies, and similar tracking technologies.
• Transaction Information: Transaction logs, transfer amounts and types, public keys, blockchain identifiers, and other related financial data.
• Third-Party Data: Information obtained from contractors, vendors, open-source intelligence, public registries, payment providers, regulators, financial institutions, KYC/AML compliance vendors, Customer Due Diligence (CDD) providers, sanctions screening databases, anti-fraud services, and commercial databases.
• Communication Records: Customer service cases, correspondence, call logs, agreements, corporate documents, and contracts.
• Other Personal Data: Any additional information voluntarily provided or collected under legitimate grounds.

5. Purposes of Processing and Retention

The Company collects, stores, and uses personal data on lawful grounds to: open and administer customer accounts; determine product access privileges; provide and optimize services; execute, monitor, and settle contracts; communicate with users, agents, and customers; manage payment transactions; maintain corporate, commercial, accounting, and audit records; ensure compliance with regulatory, tax, and reporting mandates; conduct KYC, AML, and sanctions screening for financial crime prevention; detect fraud, unauthorized activities, and other violations; protect and enforce legal rights; analyze, research, and develop products; deliver direct marketing communications; execute corporate transactions (including mergers, acquisitions, reorganizations, financing, or asset transfers); and for other purposes permitted by law.

We retain personal data only for as long as reasonably necessary to fulfill these specified purposes or to comply with applicable legal, statutory, and regulatory data retention obligations.

6. Disclosure of Personal Data

The Company may share personal data, as necessary for the purposes set out in this Notice, with the following entities: affiliated legal entities, payment institutions, treasury service providers, clearing centers, KYC/AML compliance vendors, CDD providers, sanctions screening databases, customer support entities, IT and cloud service providers, auditors, legal counsel, law enforcement authorities, supervisory bodies, regulators, and counterparties in corporate transactions. Data may also be disclosed to other third parties where required by law or authorized by client consent.

7. International Transfers and GBA Mechanisms

Personal data may be processed or accessed in the HKSAR and other jurisdictions where the Company, its affiliates, or its service providers operate. Information transferred outside of Hong Kong is processed in accordance with the PDPO, contractual obligations, and the applicable legal requirements of the receiving jurisdiction (such as the PIPL, GDPR, UK GDPR, or Singapore PDPA).

For data transfers between Hong Kong and Mainland China cities within the Guangdong-Hong Kong-Macao Greater Bay Area (GBA), Polytech applies approved standard contracts, corporate rules, and specialized GBA cross-boundary data flow mechanisms in alignment with Mainland Personal Information Protection Law (PIPL) requirements.

8. Data Security and Critical Infrastructure Compliance

To protect personal data from unauthorized or accidental access, processing, erasure, disclosure, loss, or other misuse, we implement comprehensive corporate Enterprise Risk Management (ERM) security standards. These include strict access controls, data encryption, incident response and escalation protocols, AI data leak prevention mechanisms, and continuous monitoring procedures.

Our practices align with globally recognized cybersecurity frameworks, including the NIST CSF 2.0, the international ISO/IEC 27001 standard, and the CIS Critical Security Controls (Implementation Group 3 / IG3), alongside other advanced information security solutions.

9. Access and Correction Rights

In accordance with DPP6 of the PDPO, users have the right to request access to their personal data held by the Company, as well as to request the correction of any inaccurate data. Data access requests must be submitted using the statutory Data Access Request Form in the manner prescribed by the Privacy Commissioner for Personal Data (PCPD). The Company may require additional information from the applicant to verify their identity and authorization.

10. Version Control

The text of this Global Privacy Notice may be amended, supplemented, or completely updated by the Company without prior notice, with the latest version published on the platform’s website for user reference.

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1. Introduction

This Cookie Notice explains how Polytech Global Solutions Limited (HKSAR BRN 80427335), including its subsidiaries and affiliates (collectively, "Polytech"), uses cookies and similar technologies for analytics and personalization when users visit the website polytech.capital, its individual pages, associated applications, platforms, and other web services.

2. Applicable Legal Requirements

This Notice is compiled in accordance with the jurisdictional requirements of the Hong Kong Special Administrative Region (HKSAR) and, in particular, with the following HKSAR legislative acts directly or indirectly related to cookie processing:

• Personal Data (Privacy) Ordinance, PDPO (Cap. 486): The primary law of the Hong Kong SAR governing the processing of personal data (including via cookies and trackers). Its structure includes the six Data Protection Principles (DPPs), specialized articles, and Ordinance sections. We also account for the 2012 and 2021 amendments to the PDPO regarding direct marketing (using cookies) and unlawful disclosure.
• PCPD Codes and Notes: Codes of Practice and Guidance Notes issued by the Office of the Privacy Commissioner for Personal Data (PCPD), including those specifically related to internet tracking, such as the Guidance on Online Behavioural Tracking.
• Sector Regulations: Rules and guidelines issued by sector regulators, including the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC), among others.
• Other Separate Ordinances: Ordinances governing specific types of confidential information and other regulations similar to those listed in the PICS document.
• International and Local Compliance Standards: Other relevant global and regional compliance frameworks.

3. Technologies Used

Cookies are pieces of data or similar identifiers stored on a user’s device or read from it when visiting our website or accessing Polytech online platforms.

In this Notice, "cookies" also encompass other technologies performing similar functions, including: tracking pixels and web beacons, tags and scripts, localStorage and sessionStorage, mobile device identifiers, fingerprinting technology, link decoration and other referral tracking methods, SDKs, advertising IDs, and other technologies that transmit information about user actions or generate an identifier based on device settings.

4. Processed Data

Depending on the technology used and user preferences, the Company may process unique cookie and device identifiers, IP addresses, login device and software information, language and regional settings, web activity, and user interactions (date and time of visit, session duration, referral sources, pages viewed, interaction with site elements, selected settings and granted permissions, authorization status, and other session details), technical data on errors and performance, data on interactions with advertising or marketing materials, and other related data.

5. Cookie Categories

The Company may collect and process the following categories of cookies and similar technologies, based on their purpose or the nature of their interaction with user data:

• Mandatory Cookies: Necessary for the standard operation of the website, to ensure its security, or to provide functions explicitly requested by the user (for example, correctly loading and displaying web pages, maintaining session consistency, user authentication, and load balancing between servers).
• Functional Cookies: Allow the platform to remember user preferences and provide enhanced or personalized features (for example, saving language, region, interface settings, preferred display formats, or the selected version of the site).
• Analytical Cookies: Used to obtain statistical insights into user interaction with the website’s content (for example, traffic analysis, click maps, features used, error occurrences, and page load durations).
• Marketing and Advertising Cookies: Used to measure, optimize, and tailor marketing activities (for example, measuring the effectiveness of advertising campaigns, tracking conversions, building behavioral profiles, and conducting retargeting or other digital marketing initiatives).
• Social Network and Embedded Content Cookies: Required for the proper operation of external services integrated into the website (such as playing embedded videos, displaying interactive maps, or enabling social media buttons, online chat widgets, and other support services).

6. Processed Data

When visiting the website, viewing embedded content, or using certain features integrated with Polytech, cookies from third-party providers may be set in the user’s browser. The Company pre-evaluates third-party technologies based on their purpose, the categories of data transferred, and their legal basis prior to deploying digital solutions from counterparties and third parties.

7. International Transfers

Cookie and related service providers may be located outside the HKSAR, the user’s jurisdiction, or other regions where the Company and its affiliates operate. Information transferred outside of Hong Kong is processed in accordance with the PDPO, contractual obligations, and the applicable legal requirements of the receiving jurisdiction (which may include the PIPL, GDPR, UK GDPR, Singapore PDPA, or others).

8. Data Security

To protect data associated with cookies, we implement comprehensive corporate Enterprise Risk Management (ERM) security standards. These measures include third-party scripting controls, tag change monitoring, domain and cookie path controls, identifier (ID) expiration management, the deletion of redundant cookies, and other reasonable, risk-appropriate safeguards.

9. Access and Correction Rights

In accordance with DPP6 of the PDPO, users have the right to request access to their personal data collected by the Company through cookies and similar technologies, as well as to request the correction of such data or the withdrawal of consent for non-mandatory cookies. Data access requests should be submitted using the standard Data Access Request Form in the manner prescribed by the Privacy Commissioner for Personal Data (PCPD).

10. Version Control

The text of this Cookie Notice may be amended, supplemented, or completely updated by the Company without prior notice, with the latest version published on the platform’s website for user reference.

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1. Introduction

This Risk Warning contains important legal disclaimers and disclosures regarding potential financial and investment risks for customers of Polytech Global Solutions Limited (HKSAR BRN 80427335), including its subsidiaries and affiliates (collectively, "Polytech" or the "Company"), when using the Polytech platform or interacting with any of the Company’s services or products.

In addition to classifying potential risks, this document outlines applicable legal requirements, provides notice of jurisdictional limitations, details Polytech’s risk management policies, and defines the limits of the Company’s liability.

2. Applicable Legal Requirements

This Risk Warning is compiled in accordance with the jurisdictional requirements of the Hong Kong Special Administrative Region (HKSAR) and, in particular, with HKSAR legislative acts directly or indirectly governing the disclosure of material information and the limitation of liability:

• Control of Exemption Clauses Ordinance (Cap. 71)
• Unconscionable Contracts Ordinance (Cap. 458)
• Supply of Services (Implied Terms) Ordinance (Cap. 457)
• Trade Descriptions Ordinance (Cap. 362)
• Other relevant international and local compliance standards.

3. Regulatory and Jurisdictional Restrictions

The availability of the platform and the user's ability to access the products and services provided by the Company may depend on the jurisdiction where the customer is located or resides. Certain platform products and features may be unavailable to specific users, or may be subject to territorial restrictions or additional conditions.

4. Specific Risks of Prediction-Based Products

The Company explicitly warns that the use of financial prediction-based products carries a high level of risk and may not be suitable for all users.

Speculative trading based on market predictions involves assessing the probability of future events or outcomes. The timing of such events and their actual outcomes are inherently uncertain, despite in-depth analysis, continuous hedging controls, and the implementation of reasonable risk management strategies.

5. General and Operational Risk Categories

The trading, investment, and operational activities of the Company involve certain risks that may affect the interests of retail platform users, agents, and B2B clients.

When assessing potential risks, clients are strongly advised to consider the following cumulative criteria:

• Capital Loss Risk: The risk of partial or total loss of deposited or invested funds.
• Asset Volatility: Fluctuations in asset values, including stablecoins indexed to the USD.
• Market Liquidity: The availability of sufficient trading volume in financial markets.
• Inflation Risk: The potential erosion of the purchasing power of capital over time.
• Counterparty Risk: The risk that a transaction partner defaults on their obligations.
• Regulatory Uncertainty: Ongoing changes in regulatory requirements and rules governing financial instruments.
• Tax Liabilities: The risk of unforeseen or complex tax obligations arising from transactions.
• Technical and Operational Failures: System outages, hardware malfunctions, or maintenance disruptions.
• Cybersecurity Threats: Unauthorized system access, data breaches, and their financial consequences.
• Service Interruption: The risk of early termination, transaction restrictions, or suspension of financial instruments.

6. Risk Minimization Concept

To ensure the resilience of the Polytech infrastructure, we implement comprehensive corporate Enterprise Risk Management (ERM) security standards. These measures include financial protection protocols with segregation of duties, the maintenance of liquidity reserves, rigorous counterparty due diligence, compliance audits, regular stress testing, data leak prevention across AI interfaces, and continuous monitoring procedures.

Our practices align with globally recognized cybersecurity frameworks, including the NIST CSF 2.0, the international ISO/IEC 27001 standard, and the CIS Critical Security Controls (Implementation Group 3 / IG3).

7. Exclusion and Limitation of Liability

All informational materials regarding Polytech products published on the platform website, social media networks, other online channels, or physical media are provided solely for informational purposes. They do not constitute investment advice, a formal proposal, a solicitation, an offer, a guarantee of return, or an assurance that the value of any investment will be preserved.

The Company does not guarantee that the client will achieve their expected financial outcomes. We explicitly disclaim any warranty against financial loss, and we do not guarantee profits from using Polytech products or interacting with platform tools.

8. User Due Diligence

Before utilizing the platform, you must carefully evaluate and verify whether a specific product, strategy, or collaboration model aligns with your financial profile. You should take into account your investment objectives, financial resources, investment horizon, level of knowledge and experience, risk tolerance, and capacity to absorb financial losses.

9. Acknowledgement and Acceptance

By accessing the Company’s tools and services, you acknowledge that you have read, understood, and accepted this Risk Warning. By continuing to use the platform, you demonstrate full awareness of the associated financial risks, including the possibility of a partial or total loss of funds, as well as all other risks disclosed or implied herein.

If you disagree with any part of this Risk Warning, or if you do not fully understand the terms and conditions outlined herein, you must immediately refrain from using the platform and the Company's products.

10. Version Control

The text of this Risk Warning may be amended, supplemented, or completely updated by the Company without prior notice, with the latest version published on the platform’s website for user reference.

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1. Introduction

This Global Anti-Money Laundering and Counter-Terrorist Financing Policy (the "Policy") is intended to acquaint users, agents, and clients of Polytech with the fundamental principles and procedures that Polytech Global Solutions Limited (HKSAR BRN 80427335), including its subsidiaries and affiliates (collectively, "Polytech" or the "Company"), implements to ensure strict compliance with international and HKSAR-regional legislation in the area of AML/CFT regulation.

2. Applicable Legal Requirements

This Policy is formulated in alignment with international Financial Action Task Force (FATF) standards and in accordance with the jurisdictional requirements of the Hong Kong Special Administrative Region (HKSAR), specifically incorporating the following legislative acts governing the detection and prevention of money laundering and associated financial crimes:

• Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) ("AMLO"): The central HKSAR statutory framework establishing mandates for customer screening, beneficial ownership identification, ongoing transaction risk monitoring, and other core AML/CFT procedures.
• Industry Regulations: Rules, guidelines, and circulars issued by competent sector regulators, including the Hong Kong Monetary Authority (HKMA), the Securities and Futures Commission (SFC), and the Customs and Excise Department, among others.
• United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575): The statutory act containing prescriptive measures against the financing of terrorism and terrorist activities.
• United Nations Sanctions Ordinance (Cap. 537): The legislative framework implementing United Nations Security Council sanctions, mandating the rigorous screening of clients, counterparties, and operations against applicable sanctions matrices.
• International and Local Compliance Standards: Other relevant global frameworks and regional compliance standards.

3. Purposes of this Global AML/CFT Policy

The primary objectives of this Policy are to prevent the utilization of Polytech’s products and services for the legalization of illicit proceeds and the financing of terrorism; ensure the robust application of a risk-based approach; facilitate the timely detection and reporting of suspicious activities; maintain independent internal controls; and ensure meticulous documentation and record-keeping in full compliance with AMLO standards.

4. Risk Assessment, CDD, and KYC Frameworks

When evaluating potential compliance risks, the Company analyzes multiple risk vectors, including user identity and background, country of residence or incorporation, products utilized, the nature and patterns of financial transactions, fiat and crypto onboarding and withdrawal methods, the presence of adverse media, Politically Exposed Person (PEP) or Related/Close Associate (RCA) status, and any potential nexus to sanctioned or high-risk jurisdictions.

In scenarios presenting elevated risk profiles, the Company applies stringent Customer Due Diligence (CDD) or Enhanced Due Diligence (EDD) measures, initiating comprehensive KYC/KYB procedures. These procedures encompass client identification, corporate credential verification, source of funds (SoF) and source of wealth (SoW) assessments, and risk rating assignments. Depending on the verification outcomes, the Company reserves the right to mandate enhanced verification, impose operational limits, freeze accounts, or decline service entirely.

To facilitate rigorous risk assessment, the Company may engage specialized external vendors, institutional counterparties, or authoritative commercial and open-source intelligence (OSINT) resources, including: KYC/KYB and AML compliance automation service providers, CDD/EDD vendors, real-time sanctions screening databases, PEP/RCA registries, adverse media aggregators, transaction monitoring systems, blockchain analytics and crypto AML compliance providers, and external AML consulting or outsourcing services.

5. Version Control

The text of this Global Anti-Money Laundering and Counter-Terrorist Financing Policy may be amended, supplemented, or completely updated by the Company without prior notice, with the latest version published on the platform’s website for user reference.

You are currently viewing the active version of the document.