Privacy Policy

1. Who We Are

Zynergy Asset Management Limited (trading as ZAM Global), CE No. BBM841, is a Hong Kong SFC-licensed corporation for Type 4 and Type 9 regulated activities. Registered address: Hong Kong. We operate the website zamg.ai and the ZAM Global mobile application.

2. Information We Collect

We may collect the following categories of personal data:

• Identity data — name, date of birth, government-issued ID details.
• Contact data — email address, telephone number, mailing address.
• Financial data — investment experience, net worth declarations, risk profile, and account information required for KYC/AML compliance.
• Usage data — IP address, browser type, pages visited, and interaction data collected via cookies and analytics tools.
• Communication data — messages, enquiries, and correspondence you send us.

3. How We Use Your Information

We use personal data to:

• Provide and administer investment advisory and asset management services;
• Meet our regulatory obligations under Hong Kong law, including SFC requirements and AML/CFT obligations;
• Communicate with you about your portfolio, transactions, and service updates;
• Improve and personalise our digital platform;
• Detect fraud and ensure platform security.

4. Legal Basis for Processing

We process personal data where: (a) it is necessary to perform a contract with you or take pre-contractual steps; (b) we are required to do so by law (including SFC licensing obligations); or (c) we have a legitimate interest in doing so and that interest is not overridden by your rights.

5. Data Sharing

We do not sell your personal data. We may share data with: custodians and executing brokers required to settle transactions (e.g. Interactive Brokers); regulatory bodies and law enforcement where legally required; technology and service providers acting as data processors under appropriate contractual safeguards.

6. Data Retention

We retain personal data for as long as necessary to fulfil the purposes set out in this policy and to comply with applicable regulatory requirements (typically seven years following the end of a client relationship under SFC guidelines).

7. Your Rights

Under the Personal Data (Privacy) Ordinance (Cap. 486, Hong Kong), you have the right to access, correct, and request erasure of your personal data, subject to regulatory retention requirements. To exercise these rights, contact us at compliance@zamg.ai.

8. Cookies

Our website uses essential cookies necessary for operation and analytics cookies to understand usage. You may disable non-essential cookies via your browser settings; this may limit certain functionality.

9. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be notified by posting an updated version on this website with a revised date. Continued use of our services following such notice constitutes acceptance.

10. Contact

For privacy-related enquiries: compliance@zamg.ai · Zynergy Asset Management Limited · Hong Kong.