How we handle your data, the terms that govern use of this website, and the regulatory basis on which it is published.
Draft template — not legal advice. This page follows the structure used by
comparable asset managers' websites, but every bracketed item, jurisdiction, and
regulatory reference is a placeholder. It has not been reviewed by counsel and must
not be published in its current form. Have qualified legal and compliance counsel in
each relevant jurisdiction review and finalize this content — including entity names,
licensing details, and applicable law — before this page goes live.
Last updated: [DATE] · Effective: [DATE]
01 · Privacy Policy
Overview
This policy explains what information Hyperleap Capital ("Hyperleap," "we," "us")
collects through hyperleapcapital.com (the "Site"), how we use it, and the choices
available to you. It applies to this Site only, not to any fund, account, or
offering document you may separately receive.
Information we collect
We collect information in two ways:
Information you provide. When you submit the investor-relations
form we collect your name, email address, and any firm, investor-type, and
message details you enter. When you subscribe to research updates we collect
your email address. We do not ask for, and you should not submit, financial
account numbers, government ID numbers, or other sensitive personal data through
these forms.
Information collected automatically. The Site does not set
tracking or advertising cookies. Your theme (light/dark) and language preference
are stored only in your browser's local storage and are never transmitted to us.
Standard web server logs (IP address, browser type, pages requested, timestamp)
are generated by our hosting provider, Cloudflare, for security and reliability
purposes. [If web analytics are added in future, they will be disclosed here
before being enabled.]
How we use this information
To respond to inquiries submitted through the investor-relations form
To send research notes to newsletter subscribers, and nothing else
To maintain the security, integrity, and performance of the Site
To comply with legal, regulatory, and record-keeping obligations
We do not sell personal information, and we do not use it for targeted advertising.
Who we share it with
We use a small number of service providers to operate the Site and process form
submissions, currently:
Cloudflare — hosting, content delivery, and edge compute for the Site and its forms
Resend — relays form and newsletter submissions to our internal inbox by email
We do not share personal information with other third parties except where required
by law, to protect our rights, or with your consent.
International transfers
Our service providers may process data in jurisdictions other than your own,
including the United States. Where required, we rely on appropriate safeguards
(such as standard contractual clauses) for such transfers. [Confirm and cite the
specific mechanism relied upon once hosting/processor jurisdictions are finalized.]
Data retention
We retain investor-relations inquiries and newsletter subscriptions for as long as
needed to respond to you, maintain our records, and meet legal or regulatory
requirements, after which they are deleted or anonymized.
Your rights
Depending on where you live, you may have rights to access, correct, delete, or
receive a copy of your personal information, to object to or restrict certain
processing, and — for California residents — rights under the CCPA/CPRA to know
what is collected and to opt out of its sale or sharing (we do not sell or share
personal information as those terms are defined). To exercise any of these rights,
contact us using the details below; we will respond within the time required by
applicable law.
Children
This Site is directed at institutional and professional investors and is not intended for, and we do not knowingly collect information from, individuals under the age of 18.
Changes to this policy
We may update this policy from time to time. Material changes will be reflected by the "Last updated" date above.
Contact
Questions about this policy or requests regarding your personal information can be
sent to privacy@hyperleapcapital.com.
02 · Terms of Use
Acceptance of these terms
By accessing this Site, you agree to these Terms of Use. If you do not agree, do
not use the Site. [Entity name, e.g. "Hyperleap Capital Management Ltd."], together
with its affiliates, operates this Site.
No offer; not investment advice
Nothing on this Site constitutes an offer to sell, or a solicitation of an offer to
buy, any security or interest in any fund, in any jurisdiction where such offer or
solicitation would be unlawful. Nothing on this Site constitutes investment, legal,
tax, or accounting advice, and nothing should be relied upon in making an investment
decision. Any performance, statistics, or figures shown are illustrative and
historical, and past performance is not indicative of future results.
Restricted access
This Site and the information on it are directed only at persons who qualify as
institutional investors, professional clients, or accredited/qualified investors
under the laws of their home jurisdiction (for example, "professional investors" as
defined under the Hong Kong Securities and Futures Ordinance, or "accredited
investors" as defined under Regulation D of the U.S. Securities Act of 1933). If you
do not meet the applicable definition in your jurisdiction, you must not rely on, or
act on the basis of, any content on this Site. Interests in any Hyperleap fund are
not, and will not be, registered under the U.S. Securities Act or offered to the
public in any jurisdiction, and are available only through a confidential offering
memorandum to eligible investors who satisfy applicable suitability requirements.
Intellectual property
The Site and its content — including text, graphics, the Hyperleap name and mark,
and the design of the Site — are owned by or licensed to Hyperleap and are protected
by intellectual-property law. You may view and print pages for personal,
non-commercial reference only; no other use is permitted without our prior written
consent.
No warranty; limitation of liability
The Site and its content are provided "as is" without warranties of any kind, express
or implied. To the fullest extent permitted by law, Hyperleap disclaims liability for
any loss or damage arising from your use of, or inability to use, the Site, or from
any error, omission, or inaccuracy in its content.
Third-party links
This Site may link to third-party websites. We do not control and are not
responsible for the content or practices of any linked site.
Governing law
These terms are governed by the laws of [JURISDICTION], without regard to its conflict-of-laws principles. [Specify venue/arbitration if applicable.]
Changes to these terms
We may revise these terms at any time by posting an updated version. Continued use of the Site after changes take effect constitutes acceptance.
[Hyperleap Capital (HK) Limited is licensed by the Securities and Futures Commission
of Hong Kong ("SFC") under CE No. [XXXXXXX] to carry on Type 9 (Asset Management)
regulated activity.] [Hyperleap Capital Management LLC is a registered / exempt
reporting investment adviser with the U.S. Securities and Exchange Commission,
CRD No. [XXXXXXX] / relies on the exemption available to advisers solely to private
funds under the Investment Advisers Act of 1940.] Confirm and replace the above with
the firm's actual regulatory status in each jurisdiction in which it operates or
solicits investors, and update as licensing changes.
Nature of this website
This Site is a general corporate and marketing website. It is not a prospectus,
offering memorandum, or research report, has not been reviewed or approved by any
regulator, and is not intended for distribution to, or use by, any person in any
jurisdiction where such distribution or use would be contrary to local law or
regulation, or would subject Hyperleap to any registration requirement in that
jurisdiction.
Private placement basis
Any offer or sale of interests in a Hyperleap fund is made solely on the basis of a
confidential private placement memorandum and related subscription documents, and
only to investors that meet the applicable eligibility and suitability requirements
— for example, "professional investors" under the Hong Kong Securities and Futures
Ordinance and its subsidiary legislation, or "accredited investors" purchasing
pursuant to an exemption from registration under Regulation D of the U.S. Securities
Act. No U.S. or other public offering is being made. In the event of any conflict
between this Site and a fund's offering documents, the offering documents control.
Risk factors
An investment in any Hyperleap fund involves a high degree of risk, including the
risk of loss of the entire investment. The strategies described on this Site are
concentrated in a limited number of positions and themes, may use leverage and short
selling, and may be illiquid, with lock-up periods restricting withdrawal. Figures
and statistics presented on this Site (including AUM, historical returns, and the
performance table) are illustrative and, unless stated otherwise, do not represent
actual fund results. Past performance is not indicative, and is not a guarantee, of
future results. This summary is not a complete statement of risk; a complete
discussion of risk factors is set out in each fund's offering documents, which
prospective investors should read carefully and discuss with their own advisers
before investing.
No investment advice or recommendation
Nothing on this Site is a recommendation or personalized advice regarding the
suitability of any investment for any particular investor. Prospective investors
should conduct their own due diligence and consult their own legal, tax, and
financial advisers before making any investment decision.
Complaints and regulatory contact
If you have a complaint regarding this Site or Hyperleap's conduct, contact
compliance@hyperleapcapital.com.
[Add the relevant regulator's complaint-referral information for each licensed
jurisdiction, e.g., the SFC's complaint procedures for Hong Kong.]