Ltd, a company
incorporated under the Laws of Singapore with Unique Entity Number 201922060C and registered
office at 30 Cecil
Street, #19-08 Prudential Tower, Singapore 049712. We respect your privacy and are committed to
personal data in accordance with the data protection laws applicable to the collection and
personal data under the Policy, including but not limited to the General Data Protection
Regulation, the Data
Protection Act 2018 and the Information Technology Act, 2000 and the rules thereunder. This
Policy explains how
and why we collect personal data about you and how we use it.
By using the Platform / Website or availing of our services you hereby consent to the collection, use, processing, disclosure / transfer and storage of your personal information, by us in the manner described in this Policy.
Our Platform connect investors, distributors and AMCs and make it easier to report on the performance of a wide range of Alternative Investment Funds, Portfolio Management Service Funds and other Structured Products (each referred to as “AIF”) that are invested only through private placement. Our authorisation from AMCs permits us to provide real-time access on the performance of their AIFs in a digital format to their existing Investors and prequalified Distributors. In making our Platform available to users, we are acting as an intermediary between various parties participating in the AIF distribution and reporting process. Our Platform is not available directly to Investors but only through their AMCs who manage their existing AIFs.
Any of the information we collect from you may be used in one of the following ways:
To prove your identity and give you proper access to resources;
To improve our product and services;
To process transactions; and
To administer our products
If you are an investor, in order to create an account on our Platform for you, and whilst you continue to use the Platform and related services, we will collect information about you which will include the following:
Profile data: This will include information you provide to us by completing the registration process and other forms on the Platform, or information which we may receive from your AMC or your Distributor in order to create your account and your profile. This could include (but is not limited to) your name, date of birth, postal address, mobile number, email address and certain tax and regulatory information. We only request and collect profile data that is necessary for us to process in order to operate our user accounts and facilitate reporting of your existing AIFs via the Platform;
Financial data: We will only obtain information about your AIF investments through our Platform from your AMC with whom you have historic investments; and
Transaction data: Details about your communication with your AMC and Distributor in relation to the digital reporting of their AIFs via the Platform.
If you are using our Platform on behalf of a AMC or Distributor, for example as a member of their personnel nominated to access and use our Platform, the profile data we receive in order to set up your account will be limited to your name, email address, and any further relevant corporate details. This information is necessary for us to identify you as the user authorised to use our Platform and the particular AIFs to which your use of the Platform relates.
Contact data: if you contact us via any of our Platform or our Website, by telephone or by email, we will collect information necessary to identify you and respond to your query.
We also collect technical data about our users, which includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Platform. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Policy for further details.
Usage data collected by us includes information about how you use the Platform, our Website and related services.
Marketing and communications data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data ("Aggregated Data"). Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity, and it cannot be used by us to identify you in any way. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Platform feature or the type of AIF investments.
Business contact data: If you are not a user of our Platform but we are in contact with you in relation to our offering or we have come into contact with you in the course of our business, we may collect your personal data, such as information printed on your business card or other information you give us, in order to stay in touch with you.
Other than information listed in Section 2, that we may receive from you, your AMC or Distributor, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic or biometric data), or data relating to criminal convictions and offences.
We may collect, store and use your personal information for the following purposes:
to create and manage your Platform account and update the records we hold about you from time to time;
to pass onto and liaise with the relevant AMCs and Distributors in relation to the digital reporting of your AIF investments through the Platform;
to manage your expression of interest in new AIF investments from your existing AMCs and/or Distributors;
to provide and administer our Platform, our Website and related services;
to contact you in relation to the use of our Platform, including to provide you reminders on important usage issues, and/or asking you to leave a review or take a survey;
to respond to your queries;
to detect and prevent unauthorised access;
to conduct "know your customer" checks;
to carry out anonymised statistical analysis and market research;
to fulfil our regulatory duties, including our reporting obligations;
to administer our contract with you;
to develop and improve our services and products;
to notify you about changes to our service, our terms and conditions and this Policy;
to manage our business, including for accounting and auditing purposes;
to maintain our IT systems and manage hosting of our data;
to collect and recover money owed to us;
to deal with legal disputes involving you, any relevant AMC and/or Distributor; and
to provide you with information, services that you request from us or which we feel may interest you, when you have consented to be contacted for such purposes.
We do not sell your data. From time to time, we may send emails containing information about new features and other news about the AIFMetrics Platform, such as suggestions and recommendations about similar services we offer, which we think may be of interest to you. You have the right to stop us from contacting you for these purposes. We will always inform you if we intend to use your personal data for such purposes, or if we intend to disclose your information to any third party for such purposes. You can usually exercise your right to prevent such marketing by checking certain boxes on the forms we use to collect your data. You can also object to our processing of your personal data for such purposes at any time by contacting us at [email protected].
Some of the above purposes for processing will overlap and there may be several grounds which justify our use of your personal information.
We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose and is permissible under applicable data protection laws. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, to the extent permitted by applicable data protection laws.
We are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:
Legitimate interest: Where applicable data protection laws allows us to collect and use personal information for our legitimate interests, and the use of your personal information is fair, balanced and does not unduly impact your rights. We may rely on this ground to process your personal information when we believe that it is more practical or appropriate than asking for your consent, to the extent permissible under applicable data protection laws. For instance, we rely on the legitimate interest ground to process your personal information in order to protect the security of our networks e.g. when we receive external emails we will scan such emails for any threats. We will also rely on the legitimate interest ground to communicate with you in most instances and if we need to process your personal data to conduct our business in an efficient, compliant and profitable manner. It may also be necessary to process your personal data for legitimate interest of a third party, such as your AMC or Distributor, to the extent permissible under applicable data protection laws.
Contractual relationship: Where it is necessary for us to process your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract). For instance we will process your personal data in order to enable you to use our Platform.
Legal obligation: Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject, to the extent permissible under applicable data protection laws.
Consent: Where we ask for your consent for our use of your personal information for a specific purpose. You always have the right to withdraw your consent.
Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your personal information. Please contact us if you need details about the specific legal ground we are relying on to process your personal information.
We may need to share your personal information with third parties such as:
Your relevant AMC or Distributor;
Law enforcement agencies in connection with any investigation to help prevent unlawful activity; and
In the context of the possible sale or restructuring of our business.
You hereby consent that the disclosure of any personal information or any other information as disclosed under this Policy shall not cause any loss or wrongful gain to you if the same is used for the purposes stated in this Policy.
We require third parties to respect the security of your data and to treat it in accordance with the law. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal information.
6.1. We take generally accepted industry security measures in order to protect the loss, misuse and alteration of the non-public personal information we collect from you, your AMC and/or Distributor; both during transmission and once we receive it. When you enter non-public personal information on our site, we encrypt such information in transit via HTTPS with TLS v1.3. Additionally, all non-public personal information is encrypted when stored on our servers. Finally, passwords are hashed (one-way “encrypted”) when stored in our database. You agree that such measures are secure and adequate. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us on [email protected].
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We are committed to keeping your information secure and using it appropriately. We have adopted this Policy to ensure that your personal information is handled safely and responsibly, and we will:
Respect your trust and the confidential nature of the information you provide through your financial relationship with us;
Limit the collection and use of client information to that which we believe is necessary to serve you, administer our business or tell you about our services;
Restrict employee access to client information to those who need to know in order to provide services to you. They will only process your personal information on our instructions and are subject to a duty of confidentiality and client privacy; and
Maintain appropriate security standards and procedures to protect information about you.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
You authorize us to transfer, share, part with your personal information, across borders and from your country and jurisdiction to any other countries and jurisdictions across the world (including India), with our affiliates / agents / third party service providers / partners and other agencies for purposes specified under this Policy or as may be required by law. We will ensure that any transfer of your data will be subject to appropriate safeguards, that will ensure you have appropriate remedies in the unlikely event of a security breach.
In the future, we may make changes to this Policy, without prior notice. If we decide to change our Policy, we will post those changes to this Policy on the site so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this Policy at any time, so please review it frequently. If we make material changes to this Policy, we will notify you here, by email or by means of a notice on the site prior to the change becoming effective. You agree to accept posting of a revised Policy electronically on our website as actual notice to you. Any dispute over our Policy is subject to this notice.