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Privacy Policy

Pinpoint Asset Management (Singapore) Pte. Ltd and Pinpoint Asset Management Limited are regulated by the Monetary Authority of Singapore (“MAS”) and the Hong Kong Securities and Futures Commission (“SFC”). This Website has not been reviewed by the MAS or SFC or any other regulator.

    Privacy Policy

  1. This Privacy Policy (“Policy”) sets out the basis which Pinpoint Asset Management (Singapore) Pte. Ltd. or its affiliates (collectively, “Pinpoint”, “we”, “us”) may collect, use, disclose or otherwise process personal data of users in accordance with the Personal Data Protection Act of Singapore, the Personal data (Privacy) Ordinance of Hong Kong, Information Technology Act, 2000 and Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 of India, and the Act on the Protection of Personal Information of Japan (collectively, “Relevant Privacy Laws”).

    2. Personal Data

  2. As used in this Policy:
    3. "potential candidates"means any individual who
    • has contacted us through any means to find out more about career opportunities we provide, or
    • may, or has, entered into an interview with us for the career opportunities offered by Pinpoint;
    and
      "investor" means any individual who
      • has contacted us through any means to find out more about any services we provide, or
        may, or has, entered into an agreement with us for the service we provide;
    • "personal data" refers to data about an individual who can be identified from that data, or from that data and other information to which the organization has or is likely to have access.
  3. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, correspondent address, email address, telephone number, education & qualifications, work experience and any personal particulars you may wish to include in your correspondence with us.

    4. Collection, Use and Disclosure of Personal Data

  4. We generally do not collect your personal data unless:
    • it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after
      • you (or your authorized representative) have been notified of the purposes for which the data is collected, and
      • you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or
    • collection and use of personal data without consent is permitted or required by the Relevant Privacy Laws.
  5. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
  6. We may collect and use your personal data for any or all of the following purposes:
    • performing our statutory functions and administering our activities;
    • communicating with our investors or potential candidates;
    • updating your personal and contact information;
    • performing obligations in the course of or in connection with our provision of the services requested by you;
    • verifying your identity;
    • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
    • managing your relationship with us;
    • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
    • statistical, analysis, planning and reporting;
    • any other purposes for which you have provided the information; and
    • any other incidental purposes related to or in connection with the above.
  7. This Policy does not apply to aggregated information that summarizes statistical information which does not include name, contact information, or any other information that would allow any individual to be identified.

    8. Disclosure of Personal Data

  8. We may disclose your personal data:
    • where necessary to enforce the Disclaimer;
    • where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you or managing your relationship with us;
    • to third party service providers, agents and other organizations we have engaged to perform any of the functions with reference to the above mentioned purposes;
    • if required by law or in good faith belief that such action is necessary to:
      • conform to the edicts of the law or comply with legal processes served on us or the Website;
      • protect and defend our rights or property; and
      • act under exigent circumstances to protect the personal safety of users of the Website; or
      • where your consent has been obtained for disclosure.

    Withdrawing Your Consent

  9. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
  10. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
  11. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you or communicate with you regarding any career opportunities, and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
  12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

    13. Access to and Correction of Personal Data

  13. If you wish to make an access request for a copy of the personal data which we hold about you or for information about the ways in which we use or disclose your personal data, or if you wish to correct or update any of your personal data, you may submit your request via email to our Data Protection Officer at the contact details provided below.
  14. Please note that a reasonable fee may be charged for an access request or as stated in the Relevant Privacy Laws. If so, we will inform you of the fee before processing your request.
  15. We will respond to your request as soon as reasonably possible or as stated in the Relevant Privacy Laws. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Relevant Privacy Laws).

    16. Protection of Personal Data

  16. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures.
  17. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

    18. Accuracy of Personal Data

  18. We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

    19. Retention of Personal Data

  19. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
  20. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

    21. Transfers of Personal Data Outside Your Jurisdiction

  21. We generally do not transfer your personal data to countries outside of your jurisdiction. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Relevant Privacy Laws.

    22. Use of Cookies

  22. The Website may place and access certain cookies on your computer and/or any other electronic device used to access the Website. We use cookies to improve your experience using the Website and to improve the efficacy of our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.
  23. Users of the Website are advised that if they wish to deny the use and saving of cookies from this Website onto their computers and/or other electronic devices, they should take the necessary steps within their internet browsers’ security settings to block all cookies from this Website.
  24. You can choose to delete the cookies at any time. However, you may lose any information that enables you to access the Website more quickly and efficiently.

    25. Data Protection Officer

  25. You may contact our Data Protection Officer by email if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request:
    26. Email Address: compliance@pinpointfund.com

    Effect of Policy and Changes to Policy

  26. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
  27. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.