Last Updated: June 2026
This Privacy Policy Statement is drafted in strict compliance with the statutory requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (hereinafter referred to as the "PDPO"). The Platform is committed to securing the privacy of our users and ensuring that all corporate and personal data manually uploaded by users receive the highest standard of protection.
1. Data Collection & Commercial-Grade Encryption
1.1 Voluntary Manual Upload: The Platform does not utilize automatic data scraping or API integration technologies. All financial data and corporate operational information collected by the Platform rely entirely on voluntary manual uploads of PDF or Excel files by the user (including but not limited to bank statements, balance sheets, profit and loss statements, and commercial invoices).
1.2 High-Security Encryption Standards: All files and sensitive data manually uploaded by users are processed using commercial-grade 256-bit SSL/TLS secure encryption technology during transmission (Data in Transit) and storage (Data at Rest) to prevent unauthorized access, interception, or leakage.
2. Strict Purpose Limitation of Data
All financial data and personal information collected by the Platform shall be used strictly and exclusively for the following specified purposes, and shall not be transferred or used for any other commercial or profit-making purposes:
- Conducting preliminary financial health assessments and big data analysis for the purposes of optimizing application structures and evaluating financing feasibility;
- Performing the advisory functions of the Platform in matching you with suitable funding sources;
- Assisting you, where necessary, in communicating with compliant financial institutions to explore the feasibility of debt restructuring or refinancing.
3. Limited Disclosure Authorization Framework
3.1 De-sensitization (Anonymization): You explicitly acknowledge and agree that once you complete the manual upload of documents and confirm the activation of the matching process, the Platform will subject the relevant data to rigorous de-sensitization (anonymization) technical processing to omit unnecessary personally identifiable information.
3.2 Scope of Authorized Disclosure: You hereby grant the Platform an explicit, irrevocable, and limited disclosure authorization. The Platform is authorized to submit the aforementioned de-sensitized data and financial structure reports to the Platform's designated 20 cooperating banks, 5 exclusive private equity funds, and compliant non-bank financial institutions. The sole purpose of such disclosure is for preliminary assessment, risk evaluation, and matching of financing options.
3.3 Third-Party Confidentiality Obligations: The Platform has entered into strict Non-Disclosure Agreements (NDAs) with all cooperating banks, private equity funds, and non-bank financial institutions. These institutions are bound by statutory and contractual obligations to maintain absolute confidentiality regarding the de-sensitized data received from the Platform.
4. Data Access and Correction Rights
Under the PDPO, you have the right to request access to and correction of your personal data held by the Platform. To exercise this right, or if you have any compliance questions regarding the Platform's data processing, please address your request in writing to our Data Protection Officer at dpo@smeisland.com. The Company will process your request within the statutory 40-day period and reserves the right to charge a reasonable administrative fee (settled in HKD) for processing such access requests.
Last Updated: June 2026
Welcome to SME Island (hereinafter referred to as the "Platform"). This Platform is owned and operated by SME Island (HK) Limited (hereinafter referred to as the "Company"). By accessing, browsing, or using the services of this Platform, you unconditionally agree to be bound by all the terms and conditions set forth herein.
1. Advisory Capacity & Non-Lender Status
1.1 Disclaimer of Money Lender Status: The Platform operates strictly and solely as an independent advisory and matching intermediary platform. Neither the Company nor the Platform is, or shall be deemed to be, a licensed money lender under the Money Lenders Ordinance (Chapter 163 of the Laws of Hong Kong). The Platform does not provide any direct or indirect funding or credit facilities.
1.2 Nature of Services: The core services provided by the Platform consist of advisory matching services aimed at optimizing application structures and improving approval probabilities for your enterprise. No debtor-creditor relationship is established between you and the Platform.
1.3 Advisory Service Fee: Any fees charged by the Platform to you shall be legally characterized solely as an advisory matching service fee. All fees are settled exclusively in Hong Kong Dollars (HKD).
2. User Responsibilities & Manual Upload Warranties
2.1 Technical Specifications and Limitations: You explicitly acknowledge and agree that the Platform does not feature any online banking API connectivity, Open Banking integration, or automatic data scraping capabilities. You shall submit corporate financial statements, bank statements, and invoices solely and exclusively via manual upload of PDF or Excel files.
2.2 Irrevocable Warranties of Authenticity: You, as the user, hereby make an irrevocable representation and warranty to the Company that all PDF and Excel files manually uploaded by you are true, accurate, and complete, and you have obtained absolute lawful corporate authorization.
2.3 Legal Consequences of Misrepresentation: If you upload false or misleading data resulting in damages, you shall bear full civil tort liability. Any suspected fraudulent activities will be reported immediately to the Commercial Crime Bureau of the Hong Kong Police Force.
3. Intellectual Property Protection
3.1 Ownership: The overall architecture, source code, matching system algorithmic logic, and UI design are the exclusive property of the Company and protected under the Copyright Ordinance (Chapter 528 of the Laws of Hong Kong).
4. Disclaimer & Limitation of Liability
4.1 No Guarantee of Credit Approval: The final approval, interest rates, and terms are determined entirely and independently by the cooperating banks or financial institutions. The maximum aggregate liability of the Company to you shall under no circumstances exceed the actual fee paid, or HKD 10,000, whichever is lower.
