Privacy Policy

We are committed to protecting and respecting your privacy.

Personal Information

By entering into a business agreement or investing with or alongside us, you may be required to provide us with Personal Information in relation to you, your legal and beneficial owners, your directors, officers, employees and agents, which may be subject to applicable data protection laws and regulations. For the purposes of data protection laws and regulations, we are the data controllers or data users of your Personal Information.

This policy sets out the basis on which Personal Information will be processed by us. We ensure that Personal Information is collected, processed and maintained in accordance with the applicable laws and regulations. Please read the following carefully to understand our views and practices regarding Personal Information and how we treat it.

We maintain strict security standards, policies and procedures for the prevention of unauthorized access to Personal Information. We require our directors, officers and employees and third parties we share Personal Information with in connection with our Service to observe and comply with this policy and the applicable laws and regulations in connection with this policy.

Personal Information Collection

In the course of our business relationship with you, we may collect and process Personal Information from you, other persons relating to you and/or third parties, relating to you, your accounts, investments, transactions or fund transfers.

We may collect and maintain such Personal Information from you and/or third party service providers, through physical or electronic means, from our website, during any account opening, customer or investor servicing or complaints handling process, or through other means.

Personal Information Use

We may collect, hold, use, disclose and process your Personal Information from you for any of the following purposes, as applicable:

ensuring the material on this website is presented to you in an effective manner;
providing you with alerts, bulletins, newsletters and other information which you have requested or signed up to;
taking steps to enter and entering into any business agreement between you and us;
performing obligations under any business agreement between you and us;
providing you with and improving our Service;
to the extent permitted by law and regulation and subject to your preferred mode(s) of contact, informing you about any investment opportunities with or alongside us, ensuring the protection of your vital interests;
complying with any laws and regulations applicable to us;
for our or a third party’s legitimate interests and where your interests do not override such legitimate interests;
in connection with any legal or regulatory proceedings or investigations; and
any other legitimate business purposes ancillary to the above or which you have specifically consented to.

Due to legal and regulatory obligations applicable to us, you may be required to provide us with your Personal Information or Personal Information of your legal and beneficial owners, directors, officers, employees and agents, failing which may prevent us from dealing or entering into a business agreement with you.

If you have given us consent to inform you of any investment opportunities with or alongside us and would like to withdraw such consent, please send us a written request at the contact mentioned at the end of this policy. If you have not, or are unsure if you have, given us such consent and would like to give such consent, please send us a written request at the contact mentioned at the end of this policy with your explicit consent.

Where a right of objection is available under the applicable laws and regulations, you have a right to object to us processing your Personal Information where such processing is done for our legitimate interests or direct marketing, as applicable.

Personal Information Disclosure and Transfer

Except as specified below, we do not disclose to any other person your Personal Information, unless we have received your permission to do so. We may disclose and transfer Personal Information to any of us and any third party anywhere in the world:

if we consider it necessary for our business purposes, including without limitation, to enter into a business agreement with you, to facilitate the review, acceptance, administration and management of your investment with or alongside us, to perform our Service on our behalf and, to the extent permitted under the applicable laws and regulations, provide marketing services on our behalf; and/or
facilitate the compliance with or comply with any law, regulation, judgment, order, requirement, guideline, code, standard, policy, circular, notice or any other document of a similar nature issued by any legal, regulatory, statutory, listing, supervisory, law enforcement, prosecuting, tax or any other authority or body of a similar nature in any jurisdiction.

Such third parties may include, without limitation:

our officers, directors and employees;
our banks, securities brokers, auditors, attorneys and other service providers;
our business partners and counterparties;
persons to whom we are required to make disclosure under applicable laws and regulations; and
actual or prospective transferees or participants of our Service.

Personal Information Retention

If we collect and process Personal Information in connection with preparing to enter into or entering into a business agreement with you, we will retain the Personal Information for as long as it is required to fulfill our contractual obligations to you and such other period reflecting the legal statutory limitation period under the applicable laws and regulations.

If we collect and process Personal Information in connection with a legal or regulatory obligation applicable to us, we will retain the Personal Information for as long as it is required to be retained under the applicable law or regulation.

If we collect and process Personal Information with your consent, we will retain the Personal Information for as long as it is necessary and for a reasonable period after you ask us to stop doing so.

Personal Information – Other Persons

If you provide us Personal Information relating to another person, or you authorize someone to do so, you agree that you will inform that person that you have provided such Personal Information to us and provide them with this policy. You should seek the consent of that person before Personal information relating to that person is provided to us. You agree to provide any further data protection information and/or obtain any consents from that person in relation to our use of such Personal information as may be requested by us.

Your Rights in relation to Personal Information

You may have a right to access your Personal Information held by us, a right to amend and/or rectify any inaccuracies in your Personal Information held by us, a right to erase the Personal Information held by us, a right to cease processing or a right to obtain your Personal Information in a structured, commonly used and machine-readable format, by writing to us with your request. You may also have the right to lodge a complaint with a national data protection authority. These rights are subject to availability, exceptions and conditions under the applicable laws and regulations.

If you wish to exercise your rights or have any queries on your Personal Information held by us, please send us a written request at the contact mentioned at the end of this policy.

Personal Information Security

We are committed to the safety and security of your Personal Information. We use a world class cloud information storage system.

We employ appropriate physical, electronic and procedural safeguards to ensure your Personal Information remains confidential and secure under our control or in our possession.

We restrict access to your Personal Information to the relevant and required parties on a need-to-know basis for the purposes specified above.

Where required by applicable data protection laws, we will notify you of any data breach incidents.

Privacy Policy Change

We may revise this policy at any time to comply with the applicable data protection laws and regulations. In the event of any queries or requests in connection with this policy or data protection matters generally, please contact us at [email protected].

Definitions

Capitalized terms in this Policy have the meaning given to them below:

“Personal Information” means any information relating to your identity, or the identity of another person, which could be used to directly or indirectly identify you or such person, which you, or another person on your behalf, provides to us. Such information includes, without limitation, names, addresses, dates of birth, identification numbers, telephone numbers, nationalities, tax residencies, assets, incomes, bank account details, details of regulatory registrations, details of legal and/or regulatory actions and any other information by which you or such person may be personally identified.

“Service” means any advisory, asset management and/or other service(s) provided by us to you.

“We” means any entity advised or managed by or affiliated with TransAsia Private Capital and any of its delegates and agents, including without limitation, TransAsia Private Capital Limited, Trade Finance Corporation Limited, funds advised or managed by or affiliated with TransAsia Private Capital Limited or Trade Finance Corporation Limited, the investment managers, sub-advisors and general partners of such funds, and their respective delegates and agents, and the phrases “us” and “our” have corresponding meanings.

“You” means any person accessing our website, including without limitation, in its capacity as our actual or potential investor, customer or user, and the phrase “your” has a corresponding meaning.

Construction

In this policy:

“person” includes any person, firm, company, corporation, government, state or agency of a state or any association, trust or partnership (whether or not having separate legal personality) or any two or more of the foregoing.