Asian Value Investor
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Privacy Policy

Effective 5 October 2026. Last updated 5 October 2026.

1. Introduction

Asian Value Investor ("we," "our," or "us") is an investor education initiative operated by Icarus Asia Limited, a Hong Kong-based risk and advisory firm. This Privacy Policy explains how we collect, use, store, and protect your personal data when you access our website, subscribe to our newsletter, or use our services.

This Privacy Policy applies to all users globally and incorporates:

  • Hong Kong's Personal Data (Privacy) Ordinance (PDPO)
  • The European Union's General Data Protection Regulation (GDPR)
  • The Privacy Act of 1974
  • The U.S. Federal Trade Commission Act of 1914
  • The Gramm–Leach–Bliley Act, also known as the Financial Services Modernization Act of 1999
  • The U.S. Children's Online Privacy Protection Act or COPPA
  • India's Digital Personal Data Protection (DPDP) Act, 2023

We are committed to protecting your privacy and maintaining the confidentiality of your personal information and have made best attempts at meeting some/all of the above privacy regulations.

This Policy also covers the UK GDPR, the California Consumer Privacy Act as amended by the CPRA, and the Personal Information Protection Law of the People's Republic of China, as set out in the regional notices below. Which of these laws applies to you depends on where you are.

2. Data Controller Information

The data controller responsible for your personal information is:

Icarus Asia Limited

Email: contact@asianvalueinvestor.com

Hong Kong SAR

3. Information we collect

Information you provide directly. Your name, email address and any other details you give us when you subscribe to the newsletter or write to us, and the content of your correspondence.

Technical and usage information. IP address, browser type, device identifiers, operating system, referring URLs, website interaction data, and cookies and analytics data.

4. How we use information

We may use personal data to deliver the newsletter you asked for; respond to your enquiries; improve website functionality; maintain cybersecurity and prevent fraud; comply with legal and regulatory obligations; conduct analytics and internal research; and send editorial updates and, where permitted, marketing communications.

5. Legal bases for processing (GDPR and UK GDPR)

Where GDPR or UK GDPR applies, we process personal data under one or more of the following lawful bases: consent; compliance with legal obligations; legitimate interests; and the establishment, exercise or defence of legal claims. Our legitimate interests include protecting our publication, maintaining network security, understanding how readers use the site, preventing fraud and improving operational efficiency.

6. Cookies and tracking technologies

We use cookies and similar technologies to operate and secure the website, analyse traffic and remember preferences. For more information, see our Cookie Policy.

7. Sharing of information

We may disclose information to professional advisers; regulators and government authorities; courts and law enforcement agencies; technology vendors and cloud providers, including the provider of our newsletter service; and analytics and communications providers. We do not sell personal information. We do not share personal information for cross-context behavioural advertising.

8. International data transfers

As described under "Data Storage Location" below, personal data we hold is stored and processed in the United States. Given the international nature of the web, personal data may also be transferred to and processed in jurisdictions outside your country of residence, including jurisdictions that may not provide the same level of legal protection. Where required, we implement appropriate safeguards, which may include contractual protections, standard contractual clauses, access restrictions, and encryption and cybersecurity controls.

9. Data retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, to comply with legal obligations, to resolve disputes, to enforce agreements or to maintain records. Retention periods vary with the nature of the data and applicable requirements. You can unsubscribe from the newsletter at any time.

10. Your rights

Depending on applicable law, you may have the right to access personal data, correct inaccurate data, request deletion, object to or restrict processing, withdraw consent, request portability, and lodge a complaint with a regulator. To exercise these rights, contact us at the address above.

11. Security

We implement reasonable technical, organisational and administrative safeguards designed to protect personal data against unauthorised access, disclosure, misuse, alteration or destruction. However, no system can be guaranteed to be completely secure.

12. Third-party links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of external websites.

13. Children's privacy

This website is not directed toward children under 16 years of age (under 18 for users in India; see the DPDP section), and we do not knowingly collect personal information from children.

14. Changes to this Privacy Policy

We may update this Privacy Policy periodically. Changes become effective when posted to this page.

15. Data Storage Location

Important Notice:

All personal data is stored and processed exclusively in the United States using Supabase infrastructure. By using our services, you acknowledge and consent to your data being transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction.

DPDP Act, 2023 Compliance (India)

For users located in India, we comply with India's Digital Personal Data Protection (DPDP) Act, 2023. This section outlines your rights as a Data Principal, our consent practices as a Data Fiduciary, and our breach notification obligations under Indian law.

Rights of Data Principals

As a Data Principal under the DPDP Act, you have the right to:

  • Access a summary of personal data being processed and the processing activities undertaken with respect to it.
  • Correction, completion, and updating of inaccurate or incomplete personal data, and erasure of data no longer necessary for the purpose collected.
  • Grievance redressal through a readily available mechanism, with response within statutory timelines.
  • Nominate another individual to exercise your rights in the event of death or incapacity.
  • Withdraw consent at any time, as easily as it was given. Personal data will be erased within 48 hours of withdrawal, unless retention is required by law.

Consent Requirements

  • Consent is requested in a free, specific, informed, unconditional, and unambiguous manner with a clear affirmative action.
  • Each consent notice specifies the personal data collected and the specified purpose for processing.
  • Notices are made available in English and any of the 22 languages listed in the Eighth Schedule of the Constitution of India upon request.
  • For children under 18 and persons with disabilities under lawful guardianship, processing requires verifiable parental or guardian consent. We do not undertake tracking, behavioural monitoring, or targeted advertising directed at children.
  • You may withdraw consent at any time by emailing contact@asianvalueinvestor.com. Withdrawal does not affect the lawfulness of processing performed prior to withdrawal.

Breach Notification Obligations

In the event of a personal data breach, we will notify the Data Protection Board of India and each affected Data Principal without delay and no later than 72 hours of becoming aware of the breach. Notifications will describe the nature of the breach, its likely consequences, mitigation measures taken, and recommended safeguards that affected individuals can take to protect their interests.

Significant Data Fiduciary Obligations

Should we be designated as a Significant Data Fiduciary by the Government of India, we will appoint a Data Protection Officer (DPO) based in India, conduct periodic Data Protection Impact Assessments and independent audits, and publish the DPO's contact details for grievance redressal.

Grievance Redressal

Indian Data Principals may submit grievances to contact@asianvalueinvestor.com. We endeavour to respond within statutory timelines. If your grievance is not resolved, you may escalate the matter to the Data Protection Board of India.

Regional notice: European Economic Area and United Kingdom

Under the EU GDPR and UK GDPR, you have the right to access, rectify, erase, restrict, port and object to the processing of your personal data, and to withdraw consent at any time without affecting the lawfulness of earlier processing. Where we transfer personal data outside the EEA or UK, we rely on adequacy decisions or Standard Contractual Clauses with supplementary measures where required. You may lodge a complaint with your local supervisory authority, for example the Irish Data Protection Commission or the UK Information Commissioner's Office.

Regional notice: California (CCPA/CPRA)

This notice applies to residents of California. The California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the "CCPA"), applies to for-profit businesses that meet at least one threshold: annual gross revenue above US$25 million; buying, selling or sharing the personal information of 100,000 or more California residents or households; or earning 50% or more of annual revenue from selling or sharing California residents' personal information. AVI, which is operated by Icarus Asia Limited, gives this notice so that California readers know what we do and which rights they can use, whether or not a threshold applies to us. We apply the rights below to California residents who ask.

Categories of personal information we collect

In the twelve months before the date of this policy, and going forward, AVI may collect the following categories, and uses each only for the purposes listed in section 4 of this Policy:

  • Identifiers: name, email address, IP address, and online identifiers such as cookie IDs.
  • Internet or other electronic network activity: pages viewed, referring page, search queries entered on the site, browser and device type, and time on page.
  • Commercial information: subscription status and, once memberships open, payment status. Card and bank details are handled by the payment processor, not stored by AVI.
  • Geolocation data: general location inferred from an IP address, not precise location.
  • Communications: the content of emails and messages you send us.

We do not knowingly collect sensitive personal information as the CCPA defines it (for example government identifiers, precise geolocation, racial or ethnic origin, health information, or the contents of private communications to others). Please do not send us such information.

Sources, purposes and disclosure

We collect this information directly from you, from your browser or device when you use the site, and from our service providers, such as the newsletter and hosting providers. We use it for the purposes in section 4 of this Policy. We disclose it for a business purpose to service providers and contractors who process it on our behalf under written terms, and to authorities where the law requires.

Sale and sharing

We do not sell personal information. We do not share personal information for cross-context behavioural advertising, and we have no actual knowledge that we sell or share the personal information of anyone under 16. If this changes, we will update this notice and add a "Do Not Sell or Share My Personal Information" link before doing so.

Your California rights

Subject to the exceptions in the CCPA, you have the right to:

  • Know the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of recipients;
  • Delete personal information we collected from you;
  • Correct inaccurate personal information we hold about you;
  • Opt out of the sale or sharing of your personal information;
  • Limit the use of sensitive personal information to the purposes the CCPA permits; and
  • Non-discrimination: we will not deny you service, charge you a different price or give you a different quality of service because you exercised these rights.

How to make a request

Email us at the privacy address in this Policy (contact@asianvalueinvestor.com) with the subject "California privacy request" and tell us which right you want to use. We will ask for enough information to match your request to our records, usually the email address you subscribed with. You may use an authorised agent: we will ask for your signed permission and may ask you to confirm your identity directly. We respond to requests to know, delete and correct within 45 calendar days. If we need more time we may extend by up to 45 more days and will tell you why. We respond to opt-out requests as soon as feasible and within 15 business days. If we decline a request we will explain the reason. Where a browser sends a legally valid opt-out preference signal, such as Global Privacy Control, we treat it as a request to opt out of sale and sharing for that browser.

Retention

We keep each category only as long as needed for the purpose it was collected for, to meet legal duties and to resolve disputes, as described in section 9 of this Policy. In practice, we keep your email address while you are subscribed and remove it from our active list when you unsubscribe, keeping only a minimal record that you opted out so we do not email you again. We keep correspondence for as long as needed to deal with it and to keep our records, and server logs for a limited period set by our hosting provider.

California "Shine the Light"

California Civil Code section 1798.83 lets California residents ask businesses that share personal information with third parties for their direct marketing purposes which categories were shared. AVI does not disclose personal information to third parties for their own direct marketing.

Regional notice: Hong Kong (PDPO)

This notice applies to personal data that AVI collects, holds, processes or uses in or from Hong Kong, and is also our Personal Information Collection Statement under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). AVI complies with the six Data Protection Principles in Schedule 1 of the PDPO.

Purposes of collection (Principle 1)

We collect personal data only by lawful and fair means, for purposes directly related to running a publication, and only as much as we need. Those purposes are to deliver the newsletter you subscribe to, reply to your messages, operate and secure the site, understand how the site is used, send editorial updates, comply with the law, and, where you have agreed, send marketing messages. Supplying your email address to subscribe is voluntary, but we cannot send you the newsletter without it. Other fields we may ask for, such as your name, are optional unless marked otherwise.

Classes of people we may pass data to

We may transfer your data to service providers who act for us, such as our newsletter, web hosting and analytics providers; our professional advisers; and courts, regulators and law enforcement where the law requires or permits. These recipients may be located outside Hong Kong. We do not sell your personal data.

Accuracy and retention (Principle 2)

We take practicable steps to keep personal data accurate and delete it once it is no longer needed for the purpose it was collected for, unless the law requires us to keep it. You can unsubscribe from the newsletter at any time using the link in each issue.

Use of data (Principle 3)

We use your personal data only for the purposes above or a directly related purpose, unless you give express and voluntary consent to a new use.

Direct marketing

We will not use your personal data for direct marketing, or give it to another person for their direct marketing, unless you have given consent. Before we ask, we will tell you the kinds of data, the classes of goods, services or subjects being marketed and the means of communication, and how to say no. You may withdraw consent and ask us to stop using your data for direct marketing at any time, free of charge, by using the unsubscribe link or emailing contact@asianvalueinvestor.com.

Security (Principle 4)

We take all practicable steps to protect personal data from unauthorised or accidental access, processing, erasure, loss or use, and we require our service providers to do the same. No system is completely secure, and if there is a breach that is likely to cause real harm we will tell the people affected and consider notifying the Privacy Commissioner.

Openness (Principle 5)

This Policy sets out our practices and the kinds of personal data we hold. You can ask us about them at any time.

Access and correction (Principle 6)

You have the right to ask whether we hold personal data about you, to receive a copy, and to ask us to correct data that is inaccurate. We will reply to a data access request within 40 days of receiving it and a data correction request within 40 days, as the PDPO requires. We may charge a fee that is no more than the actual cost of complying with an access request, and will tell you the amount before we proceed. We may refuse a request in the cases the PDPO allows, and if we do we will tell you why in writing. Send requests to contact@asianvalueinvestor.com.

Complaints

If you think we have breached the PDPO, please contact us first at contact@asianvalueinvestor.com so that we can try to put it right. You may also complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk).

Regional notice: Mainland China (PIPL)

This notice applies to individuals in the territory of the People's Republic of China. Article 3 of the Personal Information Protection Law of the People's Republic of China ("PIPL") applies to handling that takes place outside China when it is done to provide products or services to individuals in China or to analyse or assess their behaviour. AVI offers a Simplified Chinese edition of its articles, so we provide this notice to readers in Mainland China.

1. Who is handling your personal information

Asian Value Investor, operated by Icarus Asia Limited in Hong Kong, decides the purposes and means of handling the information described below and is the personal information handler. You can reach us at contact@asianvalueinvestor.com.

2. What we handle, why, and on what basis

We handle only the information needed for the purposes below, with the least impact on your rights.

  • Email address, and name if you give it: to send the newsletter you ask for. Basis: your consent (PIPL Article 13(1)).
  • The content of messages you send us: to reply and keep a record of the exchange. Basis: your consent.
  • Device and usage information such as IP address, browser type, pages viewed and referring page: to run, secure and improve the site. Basis: your consent where we use non-essential cookies or analytics, and the other bases the PIPL allows for security and legal compliance.

We do not handle sensitive personal information, such as biometric data, religious belief, medical or health information, financial accounts, precise location, or the information of minors under the age of 14. Please do not send it to us. If we ever need it, we will tell you why it is needed and how it affects you, and ask for your separate consent first (PIPL Articles 28 to 30).

3. Cookies and similar technologies

We use non-essential cookies and analytics only with your consent, and you can refuse or withdraw it. See the Cookie Policy.

4. Providing your information to others

We provide personal information to service providers who handle it on our behalf, for example for email delivery and web hosting. These providers may only handle it for the purposes we set and under our instructions. Before we provide your information to any other personal information handler for its own purposes, we will tell you the recipient's name and contact details, the purpose, the method and the types of information, and obtain your separate consent (PIPL Article 23). We do not sell personal information.

5. Transfers outside Mainland China

AVI is operated by Icarus Asia Limited from Hong Kong, and personal data is stored and processed in the United States (see "Data Storage Location" in this Policy), so your personal information will be transferred and stored outside Mainland China. Where the PIPL requires it, we will tell you the overseas recipient's name and contact details, purposes, methods and types of information, and how you can exercise your rights against the recipient, and we will obtain your separate consent (PIPL Article 39) and use a lawful transfer mechanism under Article 38, such as a standard contract or certification, unless an exemption applies.

6. How long we keep it

We keep personal information for the shortest time needed for the purpose. We delete it, or stop storing it and protect it, when the purpose has been achieved or can no longer be achieved, when we stop providing the service, when you withdraw consent, or when the law requires (PIPL Article 47). Email addresses of people who unsubscribe are removed from the active list, and we may keep a minimal record that you unsubscribed so that we do not email you again.

7. Your rights

You have the right to know about and decide how your personal information is handled, and to limit or refuse its handling (PIPL Article 44). You may also:

  • access and obtain a copy of your personal information (Article 45);
  • ask us to correct or complete it (Article 46);
  • ask us to delete it in the cases listed in Article 47;
  • withdraw consent at any time. Withdrawal does not affect handling that took place before you withdrew (Article 15). Use the unsubscribe link in each email or write to us;
  • ask us to explain our handling rules (Article 48);
  • ask us to transfer your information to another handler you designate, where the conditions set by the cyberspace authority are met (Article 45).

Email contact@asianvalueinvestor.com. We will confirm your identity, then reply within a reasonable time. If we decline, we will tell you the reason. If we decline, or you are unhappy with how we handle your request, you may bring a claim in a people's court (Article 50) or complain to the authority responsible for personal information protection (Article 65).

8. Children

The site is not directed to children. We do not knowingly handle the personal information of anyone under 14. If you are a parent or guardian and believe a child has given us information, contact us and we will delete it.

9. Automated decisions

We do not use your personal information for automated decision-making that significantly affects your rights or interests, and we do not use it to send targeted advertising.

10. Security

We take the technical and organisational measures that the PIPL requires, in proportion to the risk, to protect personal information from unauthorised access and from leakage, tampering or loss. If a leak, tampering or loss occurs or may occur, we will take remedial steps and notify the authority and the individuals affected where the PIPL requires (Article 57).

11. Representative in the PRC

AVI has not designated an institution or representative in the PRC. If Article 53 of the PIPL requires one, we will name it and give its contact details here.

12. Changes

If we change purposes, methods or the types of information we handle, we will tell you and, where required, ask for your consent again (Article 14).

The Simplified Chinese version of this notice is on the Chinese edition of this page. It is a machine translation published without human review. The English version prevails.

Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us:

Asian Value Investor - Privacy Inquiries

Email: contact@asianvalueinvestor.com

Operated by Icarus Asia Limited

Hong Kong SAR

By using our Service, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.