Privacy Statement

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Personal Information Collection Statement

Pursuant to the Personal Data (Privacy) Ordinance (the “Ordinance”), the following information is provided to you in connection with your dealings with and provision of data or information to Matthews International Capital Management, LLC, Matthews Global Investors (Hong Kong) Limited, Matthews Global Investors (UK) Ltd., and/or their respective affiliated companies (collectively referred to herein as the "Matthews Group").  Please be aware that this Statement replaces any notice or statement of similar nature that may have been provided to you previously. The Matthews Group is committed to maintaining your personal data in accordance with the requirements of the Ordinance and will take all reasonable steps to ensure that your personal data is kept secure against unauthorised access, loss, disclosure and destruction.

(a) From time to time, it is necessary for clients and various other individuals (“data subjects”) to supply the Matthews Group with data in connection with various matters such as account opening or continuations, or provision of services to clients and other individuals.

(b) Although it is not generally obligatory for a data subject to provide personal data, failure to supply such data may result in the Matthews Group being unable to accept and/or process an application for our products or services or continue services to clients and various other individuals or comply with any laws or guidelines issued by regulatory or other authorities.

(c) Data relating to the data subjects are collected or received by the Matthews Group from time to time in the ordinary course of the continuation of the Matthews Group’s relationship with them, for example, when data subjects open account, write cheques, transfers funds, effect transactions, attend seminar/events or generally communicate verbally or in writing by data subjects with the Matthews Group.

(d) The purposes for which data relating to a data subject may be used will vary depending on the nature of the data subject’s relationship with the Matthews Group. They may comprise any or all of the following purposes:

(i) the processing of applications for an account with and/or other financial services provided by the Matthews Group; 

(ii) enabling the Matthews Group to ensure the daily operation of the services provided to the data subjects; 

(iii) promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in paragraph (e) below;

(iv) providing alerts, newsletter and investment education materials requested/signed up by the data subjects; 

(v) designing and organising financial, investment seminars/events/forums; 

(vi) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision of services by the Matthews Group;

(vii) meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to the Matthews Group or any of its affiliates in Hong Kong or elsewhere from time to time;

(viii) complying with any law binding or applying to the Matthews Group within or outside of Hong Kong existing currently and in the future, as well as any present or future contractual or other obligations or requirements with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities that is assumed by or imposed on the Matthews Group by reason of its financial, commercial or business activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities;

(ix) any purpose related to the administration of the products offered by the Matthews Group or the data subject’s participation therein; and

(x) purposes directly related or incidental to the above, including seeking professional advices.

The Matthews Group intends to use the data subject’s data e.g. name, contact details in direct marketing only with respect to Matthews Group products or services it offers. The Matthews Group requires the data subject’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

(i) the name, contact details, web activity on the Matthews Asia website, transaction pattern and behaviour, financial background and demographic data of the data subject held or acquired by the Matthews Group from time to time may be used by the Matthews Group in direct marketing; and

(ii) the following classes of services, products and subjects may be used in direct marketing as described above: (1) financial, investment, securities, and other related services and products that the Matthews Group offers;  and (2) invitations to financial and investment seminars/events/forums.

(f) Data collected may be maintained for such period as may be required under applicable laws or as otherwise needed to fulfill any of the purposes set out in paragraph (d) above.

(g) Data held by the Matthews Group relating to a data subject will be kept confidential but the Matthews Group may provide such information to the following parties whether inside or outside Hong Kong for the purposes set out in paragraph (d):

(i) Matthews Group, its subsidiaries, representative offices and/or affiliates of the Matthews Group; 

(ii) the service providers of the Matthews Group including the registrar, transfer agent, the custodian, administrative service agent, share distributors, securities and investment service providers and the auditor of each products offered by the Matthews Group;

(iii) any agent, contractor or third party service provider who provides administrative, research, design, launch, telecommunications, printing,  mailing, computer, payment, securities clearing and settlement  or other services to the Matthews Group in connection with the operation of its business;

(iv) the intermediaries of the Matthews Group including third party financial institutions (e.g. banks, Independent Financial Advisors, insurers), third party product issuers, correspondent banks which may handle or process payment to/from data subjects;

(v) the employees, officers, directors and agents of the Matthews Group; 

(vi) any party (including but not limited to, any regulatory authorities, governmental authorities, tax, law enforcement authorities) entitled thereto by law or regulation (whether statutory or not);

(vii) (1) the Matthews Group; and (2) external service providers (including but not limited to public relation companies, data processing companies, market research firms, and information technology companies), that the Matthews Group engages for the purposes set out in paragraph (e).

(h) Under the Ordinance, any individual has the right: 

(i) to check whether the Matthews Group holds data about him or her, and of access to such data; 

(ii) to require the Matthews Group to correct any data relating to him or her which is inaccurate; 

(iii) to ascertain the Matthews Group’s policies and practices in relation to data and to be informed of the kind of personal data held by the Matthews Group;

(iv) to object to the use of his/her personal data for direct marketing purposes and the Matthews Group shall not use his/her personal data for marketing purposes after he/she communicates his/her objection to the Matthews Group.

(i) In accordance with the terms of the Ordinance, The Matthews Group has the right to charge a reasonable fee for the processing of any data access request.

(j) You may exercise your opt-out right of ongoing communications by checking the opt-out box on the Matthews Group website, or by notifying the Matthews Group if you wish to object to the use of your personal data for direct marketing purposes. The person to whom such objections, requests for access to data, correction of data or for information regarding policies and practices and kinds of data held are to be addressed as follows:

The Data Privacy Officer
Matthews Global Investors (Hong Kong) Limited
Suite 3602 Two Pacific Place
88 Queensway Admiralty, Hong Kong

(k) Nothing in this Statement shall limit the rights of the data subject under the Personal Data (Privacy) Ordinance.



Capitalized terms not otherwise defined herein shall bear the same meaning as in the Prospectus.

Luxembourg, March 2023

Dear Shareholder,

We are writing to inform you that the Company has decided to update the data protection policy of the Fund in order to comply with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) and any applicable national data protection laws (including but not limited to the Luxembourg law of 1st August 2018 organizing the National Commission for data protection and the general system on data protection, as amended from time to time) (collectively hereinafter the “Data Protection Law”).

You are informed that any personal data that is furnished in connection with an investment in the Fund may be held on computers and processed by the Fund, acting as data controller.

Personal data processed may include: investor’s name, investor’s email address, investor’s country of residence, investor type (if the investor is a legal person, the same categories of personal data may be processed in relation to its contact person(s) and/or beneficial owner(s)) (the “Personal Data”). As part of its compliance with legal obligations such as AML/KYC, the Fund may be required to process special categories of Personal Data as defined by the GDPR, including Personal Data relating to political opinions as well as criminal convictions and offences. Personal data relating to political opinions of data subjects having a public political exposure will be processed by the Fund on the basis of article 9, (2), e) of the GDPR (i.e.  the personal data have manifestly been made public by the data subject).

You are hereby informed that you may refuse to communicate your Personal Data to the Fund, in this case however, the Fund may reject your request for shares in the Fund.

Investors and/or prospective investors who are legal persons undertake and guarantee to process Personal Data and to supply such Personal Data to the Fund in compliance with the Data Protection Law, including, where appropriate, informing the relevant data subjects of the contents of the present section, in accordance with articles 12, 13 and/or 14 of the GDPR.

Personal Data supplied by data subjects are processed in order to enter into and execute the subscription in the Fund (i.e. to perform any pre-contractual measures as well as the contract entered into by the data subjects), for the legitimate interests of the Fund and to comply with the legal obligations imposed on the Fund.

Personal Data may be processed for the purposes of (i) carrying out the services required by the investor, (ii) administering the holdings in the Fund, (iii) maintaining the register of investors, (iv) complying with the Fund’s legal obligations, including its obligations under applicable company law and anti-money laundering legislation as well as other applicable regulation like the FATCA Law and the CRS Law (as defined below under section “Taxation – 4. FATCA and CRS”) (v) client relationship management and (vi) commercial prospection. In addition, the data subjects acknowledge their rights to oppose to the use of Personal Data for commercial prospection by writing to the Fund.

The “legitimate interests” of the Fund referred to above are:

(a)        the processing purposes described in points (v) and (vi) of the above paragraph of this clause;

(b)        the provision of the proof, in the event of a dispute, of a transaction or any commercial communication as well as in connection with any proposed purchase, merger or acquisition of any part of the Fund’s business;

(c)         compliance with foreign laws and regulations and/or any order of a foreign court, government, supervisory, regulatory or tax authority;

(d)        risk management;

(e)        processing Personal Data of employees or other representatives of investors and/or prospective investors which are legal persons; and

(f)         exercising the business of the Fund in accordance with reasonable market standards.

Personal Data shall be disclosed to third parties where necessary for legitimate business interests only. This may include disclosure to the Investment Manager, Global Distributor, Administrative Agent, Distributors or their delegates (the “Data Processor(s)”), Depositary, which may, as the case may be, process Personal Data as Data Processor (when processing Personal Data upon the Fund’s instructions, to assist the Fund in the context of the aforementioned purposes) or as distinct data controller (when processing Personal Data for its own purposes). Personal Data may also be transferred to any third party that acquires, or is interested in acquiring or securitizing, all or part of the Fund’s assets or shares, or that succeeds to it in carrying on all or a part of its businesses, or services provided to it, whether by merger, acquisition, reorganization or otherwise as well as to third parties such as auditors, regulators, and agents of the Investment Manager, Global Distributor, Administrative Agent, or Distributors (altogether the “Recipient(s)”) who , as the case may be, process such Personal Data for the purposes of surveillance of market timing activities, for anti-money laundering purposes, for compliance with foreign regulatory requirements, or for assisting the Data Processors in providing their services to the Fund.

The Recipients may, under their own responsibility, disclose the Personal Data to their agents and/or delegates (the “Sub-Recipients”), which shall process the Personal Data for the sole purposes of assisting the Recipients in providing their services to the Fund and/or assisting the Recipients in fulfilling their own legal obligations.

No Personal Data shall be disclosed by the Processors and/or Recipients to third parties without prior specific written authorization of the Fund.

By subscribing to the Fund, you are informed of the transfer of their Personal Data and the disclosure of your Personal Data by the Fund, its Processors and/or Recipients, to companies situated in countries outside of the European Economic Area, which may or not offer an adequate level of protection, especially the United States of America. In such cases, said transfers shall be made on the basis of adequate contractual arrangements, which may take the form of the European Commission “Model Clauses” as well as, if necessary, supplementary measures. A copy of such “Model Clauses” may be obtained by writing to the Fund at 80, route d’Esch, L-1470 Luxembourg, or at Further details with respect to the companies to which Personal Data might be disclosed as well as the related processes/treatments involving such data can be found in the Matthews’ subscription form.

The Personal Data may also be transferred to third-parties such as governmental, judicial, prosecution or regulatory agencies and/or authorities as well as official national registers, including tax authorities, in accordance with applicable laws and regulations. In particular, Personal Data may also be disclosed to the Luxembourg tax authorities, which in turn may acting as data controller, disclose the same to foreign tax authorities.

You are also informed that under certain conditions set out by the Data Protection Law, you have the right (i) to request access to your Personal Data, (ii) to ask for rectification thereof in cases where such Personal Data are inaccurate and/or incomplete, (iii) to object to the processing of your Personal Data, (iv) to ask for deletion of such data, (v) to restrict the use of your Personal Data and (vi) to ask for data portability.

In relation thereto, you may exercise the above rights by writing to the Fund at the following address: route d’Esch, L-1470 Luxembourg, or at You have also a right to lodge a complaint with the Luxembourg data protection Authority (CNPD) at the following address: 15, Boulevard du Jazz, L-4370 Belvaux, Grand Duchy of Luxembourg; or with any competent data protection supervisory authority of their EU Member State of residence.

Personal Data shall not be held for longer than necessary with regard to the purpose of the data processing, subject to statutory periods of limitation.

You are informed that the Fund and its Processors may tape-record phone conversations with their agents. You are also informed of the use of such tape recordings by the Fund and/or its Processors in legal proceedings as the case may be.

Yours faithfully,

Matthews Asia Funds

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