By visiting https://sammi-shadowtrading.com/ ( "Website" ), enrolling in our courses, or engaging in our services provided by Sammi (collectively, the “Services”), you accept and agree to abide by this Privacy Policy.

We are committed to protecting your privacy and complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.

What Information Do We Collect?

We receive, collect, and store any information you voluntarily submit on our Website or provide us in any other way, including:

Personal Identity & Contact Details: Your name, email address, telephone number, and postal address.

Verification Data (KYC): Where applicable for regulatory, compliance, or anti-fraud purposes, copies of your government-issued identification document (e.g., HKID) and proof of address.

Technical & Browsing Data: The Internet Protocol (IP) address used to connect your device to the internet; login credentials; device and connection information; and browsing history.

Session Information: We use software tools (including cookies and tracking pixels) to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page. Please read our Cookies Policy for more details.

User-Generated Content: Any comments, feedback, testimonials, profit-and-loss screenshots, or trading results that you voluntarily post within our private student groups or submit directly to us.

Why Is the Information Being Collected?

We collect such non-personal and personal information for the following purposes:

To provide provide, operate, and maintain the Website and deliver the Shadow Trading Academy™ course modules, groups, and live/in-person sessions.

To provide our subscribers and students with administrative communications, setup instructions, security alerts, access codes, and updates on policies.

To contact visitors and users with general or personalised service-related notices, operational updates, and event reminders.

To create aggregated statistical data and market insights to improve our training methodologies.

To serve any notice, legal process, or comply with any applicable laws and regulations in Hong Kong.

Upon receiving your express consent, we may also use and/or disclose your personal data for direct marketing purposes which include:

Performing matching between your personal data with our other marketing information such as our promotional offers.

Sending you details of upcoming masterclasses, internal briefings, promotional offers, and special insights.

Administering and inviting you to participate in our branding and marketing initiatives.

Developing marketing programmes and special offers.

We may contact you through your telephone numbers, WhatsApp/text messages, e-mails or correspondence addresses as provided for the above purposes.

Which Third-Parties Do We Share Information With?

We do not sell your personal data. However, to facilitate our Services, we may share your information with trusted third parties who are under a strict obligation of confidentiality:

Payment Gateways: When you purchase our Services, your payment information (such as credit card number, name, and billing address) is securely processed directly by our third-party payment infrastructure provider (e.g., Stripe). We do not store your full credit card details on our servers.

Operational Software Providers: Third-party platforms that host our systems, communication channels, and community groups (including but not limited to WhatsApp, Zoom, Google Calendar, and our CRM/hosting providers).

Professional Advisors: Our legal consultants, tax advisors, and auditors on a need-to-know basis to ensure corporate and regulatory compliance.

How Will We Communicate with You?

We may contact you regarding your account activity, to verify your enrollment, to poll your opinions through surveys, to send crucial market updates, or to enforce any agreement between us. For these purposes, we may contact you via email, telephone, WhatsApp/text messages, and postal mail.

Accessing and Amending Personal Information

You have the right to request access to, correction of, or deletion of any personal information we hold about you. If you wish to exercise this right, or if you would like to opt out of receiving direct marketing communications, please contact our data compliance team at: [email protected].

Amending this Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect legal, regulatory, or operational updates, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here or via email so that you remain aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.