Privacy Policy & Cookies

This Privacy Policy explains how Capital Asset Management Limited HK ("CustodyPrimo", "we", "us") collects, uses, shares and protects your personal data, and how we use cookies on our website.

1. Who we are

Capital Asset Management Limited HK is the data controller responsible for your personal data. You can reach us at info@custodyprimo.com.

2. Data we collect

• Identity & verification data — name, date of birth, nationality, government identifiers and documents collected for KYC/AML purposes.
• Contact data — email address, phone number and correspondence.
• Financial & transaction data — wallet addresses, transactions, holdings and instructions.
• Technical data — IP address, device and browser information, and usage data collected via cookies.

3. How we use your data

We process personal data to provide our services, open and administer accounts, meet legal and regulatory obligations (including anti-money-laundering and counter-terrorist-financing requirements), prevent fraud, communicate with you, and improve our services.

4. Legal bases

Depending on the context, we rely on the performance of a contract, compliance with a legal obligation, our legitimate interests, and/or your consent.

5. Sharing your data

We may share personal data with identity-verification and compliance providers, technology and infrastructure providers, professional advisers, and regulators or authorities where required by law. We require third parties to protect your data and to use it only for the purposes we specify.

6. International transfers

Your data may be processed outside your country of residence. Where it is, we put appropriate safeguards in place to protect it in accordance with applicable law.

7. Retention

We keep personal data for as long as necessary to provide our services and to meet legal, regulatory and record-keeping obligations, after which it is securely deleted or anonymised.

8. Your rights

Subject to applicable law, you may have the right to access, correct, delete or restrict processing of your personal data, to object to certain processing, and to data portability. To exercise these rights, contact info@custodyprimo.com.

9. Cookies

We use cookies and similar technologies to operate our website, remember your preferences, and understand how the site is used.

• Strictly necessary — required for the site to function and cannot be switched off.
• Performance & analytics — help us understand and improve how visitors use the site.
• Functional — remember choices you make to personalise your experience.

You can control cookies through your browser settings. Disabling some cookies may affect how the website works.

10. Security

We maintain technical and organisational measures designed to protect personal data against unauthorised access, loss or misuse.