Fundnel Pte Ltd, and Fundnel Technologies Pte Ltd, its related company (“Fundnel” or as appropriate in the context, “we”; “us”; or “our”) operate a private investment platform that offers unlisted securities in growth and pre-IPO stage companies across industries to a qualified network of investors, comprising of both professional and individually accredited investors actively looking to diversify their current portfolio via our internet resource platform at www.fundnel.com (subject to other additions) (the “Website”) (together with the Website, referred to as the “Services”).
The objectives of this Policy are to:
- Provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of your personal data.
- Demonstrate our on-going commitment to protecting your privacy and addressing any privacy concerns that you might have.
- Describe the ways in which we collect, use, disclose and retain your personal data.
- Ensure that we comply with the PDPA.
- Facilitate our compliance with any further developments in the protection of personal data.
Type of Personal Data
Generally, some of the Services require us to know who you are so that we can best meet your needs. When you sign-up on the Website, access the Services, submit information, or through any interaction with us via application or registration forms, emails, telephone calls, short messaging services, texts or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- contact data (name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, personal interests, and any other information provided us in any forms you may have submitted to us, interaction with Fundnel and its agents/employees, or through opening an account with Fundnel);
- other information that you voluntarily choose to provide to us (such as information shared by you with us through emails);
- financial information;
- information received by body corporate under lawful contract or otherwise;
- your use of our Services, including data of investment history, volume, patterns, predictions, trends;
- email and telephone call data records;
- your use of the Website and Services, including cookies, IP address, policy and usage history information; and
- your usage of and interaction with our Website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Website.
The information collected from you by Fundnel may constitute Personal Data under the PDPA.
“Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information. Fundnel will be free to use, collect and disclose information that is freely available in the public domain without your consent.
Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
Collection of Personal Data
Personal Data may be collected by us through processes including, but not limited to the following:
- when you subscribe or register on our Website with us for an account;
- when you access our Website or submit information;
- when you interact with any of our employees;
- when you sign up to be included in an email or other mailing list;
- when you request that we contact you; and
- when individual submits his/her Personal Data to Fundnel for any other reason.
Information that you submit via any of our Website shall be deemed to be collected by us with your permission. Such information may include but is not limited to your name, contact and fax numbers, home, work and email addresses, date of birth, and other information necessary to the provision of Services.
Purposes for which we collect and use Personal Data
Fundnel may collect, use or disclose your personal data only for purposes:
- that a reasonable person would consider appropriate in the circumstances; and
Fundnel collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as a customer, or other person relating to Fundnel).
Consent to Collection of Personal Data
Fundnel shall not collect, use or disclose your personal data unless:
- you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or
- the collection, use or disclosure of your personal data without your consent is required or authorised under the PDPA or other written law.
Fundnel shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or Service to you.
Fundnel shall not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.
As part of our continuous effort to keep you informed on our new product and services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, seminars or other relevant information that may be of interest to you.
You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting Fundnel directly at email@example.com.
Fundnel may collect and use personally identifiable information that you volunteer, or other behavioural data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfil transactions and services requested by you.
In general, Fundnel may use collet, use and/or disclose your Personal Data for the following purposes
- for the specific purpose for which the information was provided;
- to confirm your identity and ensure that you are eligible to access and use the services provided on the Website;
- to process and, where necessary, respond to your application(s), enquiry(s), or request(s);
- to conduct due diligence checks on you in accordance with all applicable laws and Fundnel's internal 'know your client' and Anti-Money Laundering/Countering the Financing of Terrorism policies;
- to verify and approve the disclosures entrepreneurs seeking capital for their business through Fundnel's platform make to potential investors;
- to enable Fundnel to comply with all of its legal and regulatory obligations;
- to inform or update you about products, or services that you request from Fundnel or that may interest you, where you have consented to be contacted for such purposes;
- to update you about changes to the Website or Fundnel's operations;
- to monitor, improve, and administer the Website and the services provided through it, and conduct statistical or other forms of analysis for purposes of maintaining or improving the Website and Fundnel's services in general; or
- to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency.
Disclosure of Information
Fundnel will not sell or rent your personal information to any third party. Information you provide to Fundnel will be disclosed to third parties where:
- you have expressly or implicitly consented to such disclosure, or may be deemed to have consented to such disclosure;
- such disclosure is a necessary part of the process of seeking funding, investors, or backers;
- necessary to provide you with the products and/or services you have requested for, or to respond to your queries;
- necessary for the operation of the Website or Fundnel's internal processes;
- required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
- Fundnel believes, in good faith, that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Website, Fundnel's interests, or any Fundnel employee
- Fundnel is the subject of a takeover and your personal information forms part of Fundnel's assets to be transferred to the acquiring entity; or
- You disclose such information to third parties in the course of participating in any competitions or promotional programmes on the Website.
Additional Privacy Statements for Website and Service Users
Persons who have subscribed for our updates on the Website (“Subscribers”) Note:
This section applies to all Subscribers.
- As part of the signing-up process that is available to Subscribers on the Website, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.
- If you have inadvertently submitted any such information to Fundnel prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to firstname.lastname@example.org, inquire whether Fundnel is in possession of your Personal Data, and you may also require Fundnel to delete and destroy all such information.
- Fundnel will communicate with the Subscribers through email. The Subscribers can change their e-mail address by resubscribing and sending an email to email@example.com for the deletion of previous email.
- All Fundnel employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.
- To the extent necessary to provide Subscribers with the Services, Fundnel may provide their Personal Data to third party contractors who work on behalf of or with Fundnel to provide Subscribers with such Services, to help Fundnel communicate with Subscribers or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your personal information to contractors, solely for the intended purposes only.
- Subscribers may choose to unsubscribe from marketing communications that they receive from Fundnel or manage their preferences via the links provided at the end of every such email and/or promotional communication.
Persons who register and have accounts to use the Website (“Members”) Note:
This section applies to all Members.
All the information provided to Fundnel by a Member, including Personal Data or any sensitive personal information, is voluntary. You understand that Fundnel may use certain information of yours, which has been designated as Personal Data under the PDPA, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. Fundnel also reserves the right to use information provided by or about the Member for the following purposes:
- Publishing such information on the Website.
- Contacting Members for offering new products or services
- Contacting Members for taking product and Service feedback.
- Analysing software usage patterns, trends, history, big data for our business operations, improving product design and utility.
- Analysing anonymised practice information for our commercial use.
- You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on your account page or by contacting us through firstname.lastname@example.org. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Fundnel has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Fundnel may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Fundnel will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
- If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through email@example.com. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymised and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymised data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in Fundnel being unable to provide you with its Services or to terminate any existing relationship Fundnel may have with you.
- If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, you may do so via your email and/or account.
- Fundnel does not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Members (the collection, use, storage and disclosure of which each User must agree to in order for Fundnel to effectively render the Services).
- Fundnel maintains a strict "No-Spam" policy, which means that Fundnel does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
- Fundnel has implemented best international market practices and security policies, rules and technical measures to protect the Personal Data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorised access to the Member’s electronic devices through which the Member avails the Services, Fundnel shall not be held liable for any loss whatsoever incurred by the Member.
- Fundnel implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Fundnel’s business. The reasonable security practices and procedures implemented by Fundnel include, but not limited to: ensuring that any Personal Data is protected by password.
- Fundnel takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.
Casual Visitors Note:
- No sensitive personal data or information is automatically collected by Fundnel from any casual visitors of this Website, who are merely perusing the Website.
- If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Fundnel. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as Fundnel cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.
Confidentiality and Security
Your Personal Data is maintained by Fundnel in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. Fundnel has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of your information. Nevertheless, you acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to Fundnel is done so at your own risk. Fundnel does not warrant or guarantee that the information you provide will not be accessed, copied, used, or disposed of in breach of Fundnel's security measures, and you agree not to hold Fundnel liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, Fundnel will, as far as reasonably possible, promptly notify all affected persons.
No administrator at Fundnel will have knowledge of your password. You accept that you are responsible for keeping confidential your username and password to your account with Fundnel. Be sure to log off from the Website when finished. Fundnel does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorised use of your account, you must immediately notify Fundnel by sending an email to firstname.lastname@example.org. You shall be liable to indemnify Fundnel due to any loss suffered by it due to such unauthorised use of your account and password.
Age of Consent
By using the Website, you represent that you are at least the age of 18 years old, or you have given us your consent to allow any of your minor dependents to use this Website as the case may be. Fundnel strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Website and Services are not intended for use by minors, Fundnel respects the privacy of minors who may inadvertently use the internet or the mobile application.
Fundnel may collect certain information from you without you actively providing the information when you navigate the Website via cookies. Cookies are small data text files stored in your local browser cache that send information about your previous visits to and activities on the Website. These cookies will not give Fundnel any personal information about you. Fundnel reserves the right to use the cookies to recognise your browser and thereby customise and optimise the Website to your preferences.
You can accept or delete cookies. For security reasons, you may wish to deactivate the storing of cookies or adjust your browser to inform you before the cookies are stored on your computer. However, please note that if you do erase or block the cookies, you may not be able to utilise some features on the Website. In such situations, Fundnel shall not be held liable for any loss or damage resulting from your inability to use those features.
Fundnel may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). Fundnel collects your IP address in order to facilitate its administration and improvement of the Website. The information derived from your IP address can help Fundnel diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Website.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, using Fundnel's online payment services.
- Analytical/performance cookies. They allow Fundnel to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps Fundnel to improve the way the Website works, for example, by ensuring that users are able to use custom features.
- Functionality cookies. These are used to recognise you when you return to our Website. This enables Fundnel to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. Fundnel will use this information to make the Website and the advertisements targeted more relevant to your interests. Fundnel may also share this information with third parties for this purpose.
Notifications & Communications
Fundnel will send you email notifications from time to time. You may not opt out of receiving certain service-related notifications that are:
- necessary elements of your transactions on the Website and any product or service of Fundnel's, such as confirmations of particular actions you have taken;
- are required for legal or security purposes; or
- meant to inform you of changes to Website policies or Fundnel's operations, products, or services.
You may opt out of other service-related notifications at any time, including:
- Fundnel's bi-weekly editorial;
- user surveys or other requests for user feedback; or
- marketing offers from Fundnel or that Fundnel sends on behalf of the companies featured on the Website.
Fundnel will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. Fundnel will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.
Transfer, Storage, & Retention of Information
Fundnel will retain all information collected for as long as you continue to use the Website or Fundnel's services. If you are a Member and terminate your Fundnel account, Fundnel will retain the information, including personal data, collected during your membership for as long as reasonably necessary for any business or legal purpose. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
Fundnel may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and Fundnel. Fundnel may do so in order to resolve queries in the future and/or for the purpose of ensuring security, staff training and complying with its legal and/or regulatory responsibilities.
Access and Withdrawal of Personal Data
You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to email@example.com. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages. In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.
We will, at your request, endeavour to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request.
There may be circumstances where Fundnel will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
Accuracy and Correction
You may request for information from Fundnel on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one (1) year before the date of your request. We will endeavour to ensure that your Personal Data we use is sufficiently accurate and complete in making any decision that impacts you.
To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to our Data Protection Officer. We will correct or complete your Personal Data as soon as reasonably practicable. If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at personaldataofficer@Fundnel.com.
You have the right to ask Fundnel not to process your personal data for marketing purposes. Fundnel will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms Fundnel uses to collect your data. You can also exercise the right at any time by contacting Fundnel at firstname.lastname@example.org. The Website may, from time to time, contain links to and from the Websites of its partner networks, advertisers and affiliates. If you follow a link to any of these Websites, please note that these Websites have their own privacy policies and that Fundnel does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these Websites.
You may choose to stop receiving or change the frequency of email, direct mail, phone and mobile marketing communications. You can update and correct your personal information anytime using My Account or by contacting Fundnel at email@example.com.
If a Subscriber or Member uses the Services; or accesses the Website after a notice of changes has been sent to such Prospect or Member, or published on the Website, such Prospect or Member hereby provides his/her/its consent to the changed terms.
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