Privacy and Cookies Policy

Privacy

The Affinity Group respects the privacy and confidentiality of individuals' personal data and will take reasonable steps to implement policies, practices and processes to comply with applicable laws. For these purposes, “Affinity Group” means Affinity Equity Partners (S) Pte. Ltd. (“Affinity”), its holding companies, their subsidiaries, affiliates, related entities, controlling, associated and/or affiliated undertakings, and/or funds advised by any of them, and/or each of their respective partners, principals, directors, officers, employees, advisers, agents and representatives from time to time.

This Privacy and Cookies Policy (together with our Terms of Use and any other documents referred to in it) sets out (i) the basis on which we will process any personal data we collect from you, or that you provide to us; and (ii) information on our use of cookies. Please read the following carefully to understand our views and practices regarding cookies, your personal data, and how we will treat such information. By visiting our website and by interacting with us including through emails, mails, telephone calls or fax messages, you are accepting and agreeing to our practices described in this Privacy and Cookies Policy. If you do not agree to this Privacy and Cookies Policy, please do not access or use this website.

This Privacy and Cookies Policy supplements but does not supersede or replace any other consents you may have previously provided to any member of the Affinity Group in respect of your personal data. Your consents herein are additional to any rights which any member of the Affinity Group may have at law to collect, store, use, disclose or process your personal data.

Collection and processing of personal data

You can use and browse our website without having to disclose your personal data, except as may be necessary to allow us to respond to your requests or in cases where you contact us directly, or where otherwise set out in this Privacy and Cookies Policy.

We collect personal data (which may include sensitive personal data) when you provide it to us, through registration, completion of forms, emails, enquiries and requests, and similar situations in which you have chosen to provide the information to us. The information you give us may include, but is not limited to, your name, address and email. If you choose not to provide such information, it may not be possible for us to respond to your request or enquiry.

We will retain control of, and responsibility for, the use of any personal data you disclose to us. Additionally, we may collect and retain a record of all communications with you. Such data shall remain in our possession, or that of data intermediaries acting on our behalf.

Our website uses Google Analytics, a web analytics service provided by Google, Inc.Information on how Google Analytics collects and processes your data is available here: www.google.com/policies/privacy/partners.

IP addresses 

When you use our website, we may collect and store information about your computer (including your IP address, operating system and browser type) for system administration. This is statistical data about our users' browsing actions and patterns and could possibly lead to your identification.

Cookies

Cookies are small text files which are placed on your computer when you visit our website. Cookies are used primarily for administrative purposes, to allow the website user to navigate efficiently between pages and to allow the website operator to track usage of the site. You can find out more about cookies at www.allaboutcookies.org.

Our website uses cookies to distinguish you from other users of our website by storing, generally non-personally identifiable, information (e.g. session information such as the number of times you visit our website and the location from which you are accessing the website). Note that some limited information may be personally identifiable for the purposes of:

  • managing and customizing your experience on the website/platform;
  • analysing trends and improving our site for our users; and
  • delivering content tailored to your interests and the manner in which you browse our websites and platforms.

Cookies can remain on your computer or mobile device for different periods of time. The Affinity Group may use both “session cookies” and “permanent cookies”. Session cookies exist only while your browser is open and are deleted automatically once they close their browser. Permanent cookies survive after your browser is closed and can be used to recognize your computer or mobile device when you open your browser and browse the internet again. 

Any other information is anonymized and/or aggregated to produce statistical reports that enable us to evaluate the use of our website; and to make improvements to, and increase efficiency when you browse our website.

What do we use cookies for? 

We use cookies: (i) to track your activities on our website and identify sessions; and (ii) the purposes described in this Privacy and Cookies Policy, but they will not generally allow us to obtain information of a personal nature such as your name and address. We will only be aware of such information if you provide the information to us or you have set the preferences in your browser to provide this information automatically.

We use the information collected to analyse trends and improve our site for our users, as more particularly described below.

What are my options in relation to the use of cookies? 

By using this website, you agree to the use of cookies and other technologies as set out in this Privacy and Cookies Policy. If you do not agree to such use please either refrain from using this website or see the section below “Can you control or delete cookies?” to adjust your settings.

You can find more information about the individual cookies we use and the reasons why we use them in the table below.


Type of cookie

Purpose

Functional cookies

These cookies serve a variety of purposes related to the presentation, performance and functionality of this website. Their overall purpose, however, is to enhance visitors’ experience and enjoyment of this website. For example, some of these cookies enable visitors to specify language, product or other website preferences.

Performance cookies

These cookies are used to collect information about how visitors use the website. The information gathered does not identify any individual visitor and is aggregated. It includes the number of visitors to our website, the websites that referred them to our website and the pages that they visited on our website. This information is used to help run our website more efficiently, to gather broad demographic information and to monitor the level of activity on the website.

Cookies necessary for essential purposes

These cookies are essential to provide the users with services available through this website and to use some of its features, such as access to secure areas. Without these cookies, services they have asked for, like transactional pages and secure login accounts, would not be possible.


Can you control or delete cookies? 

You can set your cookie preferences by changing your browser settings so that cookies from this website cannot be placed on your computer or mobile device. To do this, you need to follow the instructions provided by your browser (usually located within the “Help”, “Tool” or “Edit” facility). You should note that if you choose to do this, it may have an impact on the quality of your browsing experience, including limiting the functionality of some web pages or preventing them from loading properly. Additionally, major browsers have attempted to implement the draft “Do Not Track” (DNT) standard of the World Wide Web Consortium in their latest releases. This website is not compatible with DNT and does not process DNT messages.

Further information can also be found on wwww.allaboutcookies.org. To opt-out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

No member of the Affinity Group shall be responsible for the effectiveness of or compliance with any third parties opt-out options.

Purposes of use

All personal data and other information collected may be used by any member of the Affinity Group individually or collectively and may be combined with other information for the following purposes:

  • Responding to your enquiries or requests pursuant to your emails, mails, telephone calls, faxes and/or submission of form(s);
  • Responding to and taking follow-up action on complaints;
  • Performing office and operational administrative matters following your request;
  • Seeking feedback and comments on business and operational matters of any member of the Affinity Group;
  • Managing the infrastructure and business operations of the Affinity Group and complying with internal policies and procedures, including providing you with access and/or use of this website;
  • Conducting data analytics for the purposes of (i) system and process improvements; (ii) risk/fraud management; (iii) regulatory and compliance risk management; (iv) investment insights; and (v) enhancements to human resources processes;
  • Protecting and enforcing our contractual and legal rights and obligations;
  • Dispute resolution, preventing, detecting and investigating non-compliance with laws, regulations and internal corporate policies, including fraud and financial crimes, analysing and managing other commercial risks and risks arising from the Affinity Group’s operations and investment activities;
  • Conducting audits, reviews and analysis of our internal processes;
  • Fulfilling legal, contractual or regulatory obligations of any member of the Affinity Group, including complying with any applicable laws, regulations, rules, codes of practice or guidelines or to assist in law enforcement investigations by relevant authorities; and/or
  • Purposes reasonably related to any of the above.

 

Disclosure of your personal data

To respond to or process your requests to Affinity, we may have to disclose your personal data to a member of the Affinity Group or to third parties such as our service providers and professional advisors, each on a “need to know” basis. You hereby authorise us to transfer your personal data to such third parties, who will process your personal data in accordance with this Privacy and Cookies Policy. Your personal data will not be disclosed to any further parties, unless we have obtained your consent or are legally required to do so.

Security

We endeavour to protect your personal data. We have taken reasonable steps to use technical and organisational security precautions to protect your data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk. As far as reasonably practicable, our security procedures are continuously revised based on new technological developments.

However please be aware though that there is no such thing as “perfect security” on the internet, and third parties may unlawfully intercept or access transmissions or private communications. The Affinity Group will not be responsible or liable for any damage, losses or causes of action arising out of or in connection with the disclosure of your personal data.

Where we store your personal data 

The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by persons operating outside Singapore who work for us or our affiliates or for one of our service providers.

By submitting your personal data, you agree to this transfer, storing and processing. Affinity will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy and Cookies Policy.

Data retention 

We retain your personal data for as long as necessary for the fulfilment of the purposes for which it was collected or to which you have given your consent, except where otherwise provided for by law.

Third party websites 

This website (including this Privacy and Cookies Policy) may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Third parties (including, for example, advertising networks and providers of external services like Google Analytics) may use cookies which are downloaded when you visit our site. These cookies are likely to be analytical, performance or targeting cookies.

Amendments to this Privacy and Cookies Policy

This Privacy and Cookies Policy may be amended, supplemented, modified and updated from time to time. Please check back regularly for any updates.

Severability 

If any provision of this Privacy and Cookies Policy shall be deemed unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from this Privacy and Cookies Policy and shall not affect the validity and enforceability of any remaining provisions.

Governing law and jurisdiction

This Privacy and Cookies Policy and all matters arising out of or in connection with it shall be governed by Singapore law and the courts of the Republic of Singapore will have exclusive jurisdiction in case of any dispute.

Contacting us – withdrawal of consent, access to, and correction of personal data 

If you (i) have any questions or feedback relating to your personal data or our Privacy and Cookies Policy; (ii) would like to withdraw your consent to any use of your personal data as set out in this Privacy and Cookies Policy; or (iii) would like to obtain access or make corrections to your personal data, please contact the following:

AEP Data Protection Officer

Email: webmaster@affinityequity.com