This Privacy Policy sets out how CapBridge Pte. Ltd. Ltd (or its successors and assignees) (“CapBridge”, “We“, “Us“, or “Our“) complies with the provisions of the Personal Data Protection Act 2012 and Personal Data Protection Regulations 2014 of Singapore (the “Singapore Personal Data Protection Laws“) regarding the collection, use, and disclosure of any personal or non-personal information and data you (“You” or “Your”) will provide when You access and use this website located at https://capbridge.sg and all associated sites linked thereat (the “Site”) and/or any of CapBridge’s services and/or products, regardless of whether or not You create an account. For the avoidance of doubt, this Privacy Policy applies (i) regardless of the medium used to access and utilise Our Site and (ii) to both fundraising entities and investors accessing and utilising Our Site.
1. Introduction
a) This Privacy Policy is intended to be read together with the Site’s Disclaimers, Exclusion of Liability and Terms of Service for Investors or Fundraising Entities, whichever is applicable (“Conditions“). In the event of any inconsistency between the provisions of this Privacy Policy and the Conditions, the provisions of the Conditions shall prevail. By accessing and using CapBridge’s website, You are deemed to have read, accepted, and agreed to be legally bound by the terms of this Privacy Policy and the Site’s Conditions as they change from time to time, regardless of whether You have registered for an account with CapBridge.
b) You agree and consent to CapBridge and Our authorised service providers and third parties to collect, use and disclose and/or retain your information in the manner set forth in this Privacy Policy. This Privacy Policy supplements but does not supersede nor replace any other consent which You may have previously provided to Us nor does it affect any right that We may have at law in connection with the collection, use, disclosure and/or retention of Your information.
c) CapBridge reserves the right to amend the Privacy Policy at any time without prior notice to You. Should any material revision(s) be made to this Privacy Policy, We will notify You of Our revision(s) via Our public website (CapBridge.sg) or via the email address that You have provided us. Any use of the Site after such amendment shall be deemed acceptance of the amended Privacy Policy in its entirety. If You do not agree to this Privacy Policy, please immediately discontinue Your access to, and use of, the Site.
d) This Privacy Policy does not apply to third-party websites You may access through, or in the course of Your use of, the Site. Your rights in relation to those third parties will be governed entirely by the privacy statements and/or terms and conditions of those third-party websites.
e) CapBridge has the right (but not the obligation) to assign its rights under this Privacy Policy to an affiliated entity (which shall include, but is not limited to, 1x Exchange Pte Ltd). In such event, and in the event Our obligations under this Privacy Policy and the provision of Our services are novated to such entity, You will be notified of such change (and any corresponding change to the Privacy Policy) through the email address You have provided to Us, or via a prominent notice on the Site. Your continued use of the Site after such notification constitutes Your consent to abide and be bound by the Privacy Policy and the services being provided by such affiliated entity.
2. Collection of InformationWhen (i) You access or use the Site or any part thereof, (ii) You communicate with CapBridge or any of its officers, employees or agents whether through written, published or electronic means, the telephone or otherwise, and/or (iii) CapBridge contacts You via means such as phone calls, emails, or messages for business, CapBridge or its third-party processors may collect or receive personal or non-personal information or data about, in connection with or from, You, including, without limitation, through cookies, pixel tags, website and data analytics, and other technology, in accordance with the Singapore Personal Data Protection Laws.
Personal information or data may include without limitation:
a) personally identifiable information and data (e.g., Your name, e-mail address, mailing address, contact number, birth date, age, occupation, educational level, income level, gender, industry of work, payment details);
b) anonymous information about Your usage of and interaction with Our website (e.g., computer and connection information, device capability, bandwidth, statistics on page views, frequency of use and traffic to and from Our website);
c) electronic identification data (e.g., Internet Protocol (IP) address and cookies); and
d) Your user profile (e.g., identification key and password) (“Personal Data“).The provision of such Personal Data by You is not mandatory, but may be required in order to use or access certain web pages and/or sections of Our Site or Our services, or to purchase Our products or services. Non-personal information or data may include without limitation Your browser information, IP address, how You use the Site or any part thereof, and aggregated information. CapBridge will, as far as possible, inform You at each collection point as to what information is required and what information is optional.
3. Use of InformationCapBridge uses the collected information and Personal Data for the following purposes:
a) for the specific purpose for which the information was provided or collected for;
b) to confirm Your identity and ensure that You are eligible to access and use the various services provided on the Site;
c) to process and, where necessary, respond to Your application(s), enquiry(s), or request(s);
d) to provide You with the products and/or services You have requested for or wish to use;
e) to conduct due diligence checks on You in accordance with all applicable laws and regulations, and CapBridge’s internal ‘know Your client’ and anti-money laundering/countering the financing of terrorism policies;
f) to verify and approve the disclosures companies/funds seeking capital for their business through CapBridge’s platform make to potential investors and/or investors;
g) to enable CapBridge to comply with all of its legal and regulatory obligations, including but not limited to financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping requirements;
h) to inform or update You about products, events, activities, or services that You request from CapBridge or that may interest You, where You have consented to be contacted for such purposes;i) to update You about changes to the Site or CapBridge’s operations;j) to assess, monitor, improve, and administer the Site and the services provided through it, and conduct statistical or other forms of analysis for purposes of maintaining or improving the Site and CapBridge’s services in general;k) to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency;
l) to communicate with You through various means, including but not limited to email, messaging, phone calls, on matters relevant to your relationship with or interest in CapBridge;
m) to address or investigate any complaints, claims or dispute;
n) to conduct audits, reviews and analysis of CapBridge’s internal processes, for action planning and managing of commercial risks, and complying with internal policies; and/or
o) any other purposes relating to any of the above.
4. Disclosure of Information
a) CapBridge will not sell Your Personal Data or information to any third party. Information or Personal Data You provide to CapBridge may be disclosed to third parties where:
i) You have expressly or implicitly consented to such disclosure, or may be deemed to have consented to such disclosure for the purposes set out in Section 3 of this Privacy Policy and any other reasonable ancillary purposes;
ii) such disclosure is a necessary part of the process of seeking funding, investors, or backers (including third party entities that would or are likely to be involved in the fundraising process);
iii) necessary to provide You with the products and/or services You have requested for, or to respond to Your queries;
iv) necessary for the operation of the Site or CapBridge’s internal processes;
v) required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
vi) CapBridge 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 Site, CapBridge’s interests, or any CapBridge employee;
vii) CapBridge is the subject of a takeover or acquisition of any of its assets, and Your personal information forms part of CapBridge’s assets to be transferred to the acquiring entity;
viii) CapBridge acquires or is otherwise involved in any transactions involving any business interests, affiliates, or subsidiaries;
ix) permitted under the Singapore Personal Data Protection Laws and/or other applicable laws; and/or
x) You disclose such information to third parties in the course of participating in any competitions or promotional programmes on the Site, regardless of whether such competitions or promotional programmes are initiated and run by the third party or CapBridge.
b) When We disclose Your information and/or Personal Data to third parties, We will take appropriate steps to ascertain whether, and to require them to ensure that, any information and/or Personal Data disclosed to them are kept confidential and secure. Nevertheless, CapBridge is not responsible for removing or destroying Your information and/or Personal Data from the possession or control of any third party who may have previously been provided with Your information and/or Personal Data in accordance with these conditions.
5. How we protect your informationCapBridge is concerned with protecting your privacy and data and has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of Your information and Personal Data. Nevertheless, You acknowledge and agree that communications through the Internet are not entirely secure and that any information or Personal Data transferred to CapBridge is done so at Your own risk. CapBridge does not warrant or guarantee that the information or Personal Data You provide will not be accessed, copied, used, or disposed of in breach of CapBridge’s security measures, and You agree not to hold CapBridge liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, CapBridge will, as far as reasonably possible, promptly notify all affected persons. You accept that You and, where applicable, anyone else with whom You share the same, are responsible for keeping confidential Your username and password to Your account with CapBridge.
6. Web-related Information
a) CapBridge may collect certain information from You without You actively providing the information when You navigate the Site 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 Site. Cookies track information such as users’ profiles, the number of users, their frequency of use and their preferred websites. These cookies will not give CapBridge any of Your personal information. CapBridge reserves the right to use the cookies to recognize Your browser and thereby customise and optimize the Site to Your preferences and to compile statistics about activities carried out on Our Site.
b) The majority of Internet browsers will allow You to configure the settings used for cookies, including the deletion of cookies stored from your computer. 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, if You disable the use of cookies on Your web browser, or remove or block specific cookies from the Site, You may not be able to gain access to all of the information, materials, facilities, and services provided on the Site.
c) A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of Our Site but not on Your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the Site so that We can customise and optimize the Site to Your preferences and to compile statistics about activities carried out on Our Site.
d) CapBridge may also collect Your 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). CapBridge collects Your IP address in order to facilitate its administration and improvement of the Site. The information derived from Your IP address can help CapBridge diagnose server problems, report aggregate information, and determine the fastest route from Your computer to the Site.
7. Notifications and Communications
a) CapBridge will send You email and/or message notifications from time to time. You may not opt out of receiving certain service-related notifications that are:
i) necessary elements of Your transactions on the Site and any product or service of CapBridge’s, such as confirmations of particular actions You have taken;
ii) are required for legal or security purposes; or
iii) meant to inform You of changes to Site policies, the Conditions, disclaimers, or CapBridge’s operations, products, or services.
b) You may opt out of other service-related notifications at any time, including:
i) user surveys or other requests for user feedback; or
ii) marketing offers from CapBridge or that CapBridge sends on behalf of third parties or the companies/funds featured on the Site.
8. Transfer, Storage, and Retention of Information
a) Information collected in accordance with this Privacy Policy and Our Conditions may be transferred, stored, or processed outside of Singapore (for instance, to the servers of Our service providers). CapBridge will comply with its obligations under the Singapore Personal Data Protection Laws and any other applicable laws and regulations in relation to Personal Data transferred, stored, or processed outside Singapore for as long as the data remains in CapBridge’s possession or control during the transfer. CapBridge will take appropriate steps to ascertain whether, and to ensure that, the recipient of the Personal Data who is located outside Singapore is legally obliged to provide to the Personal Data a comparable standard of protection as set out in the Singapore Personal Data Protection Laws. However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore in order to provide You with the services You request, You are deemed to acknowledge and consent to such transfer, storage, or processing in providing Your Personal Data to CapBridge during Your use of the Site. You may at any time inform CapBridge that You wish to withdraw Your consent to such transfer, storage, or processing of Your Personal Data.
b) While CapBridge will take reasonable care in preventing the loss, misuse or alteration of Your Personal Data, You acknowledge that data transmission over the Internet is insecure and that CapBridge cannot, and does not, guarantee the security of the data transmitted over the Internet in connection with Your use of and activities on this Site.
c) CapBridge will retain all information collected for as long as You continue to use the Site or CapBridge’s services. If You are a member and terminate Your CapBridge account, CapBridge will retain the information, including Personal Data, collected during Your membership for as long as reasonably necessary for any business or legal purpose. Once there is no longer any legal or business requirement to retain the information, we will destroy the information collected from you.
9. CommunicationsCapBridge may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between You and CapBridge for purposes of resolving queries in the future and/or for the purpose of ensuring security, staff training and complying with its legal and/or regulatory responsibilities.
10. Your Rightsa) You have the right to ask CapBridge not to process Your Personal Data for any purposes by contacting our Data Protection Officer. CapBridge will inform You (before collecting Your dat
a) 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.
b) The Site may, from time to time, contain links to and from other websites, including without limitation the websites of companies/funds featured on the Site and CapBridge’s partner networks, advertisers, and affiliates. If You follow a link to any of these third party websites, please note that CapBridge does not accept any responsibility or liability for any Personal Data disclosed to and/or on those websites. Please also note that these websites have their own privacy policies and that CapBridge does not accept any responsibility or liability for these policies. Please check these policies before You submit any Personal Data to these websites.
c) You may choose to stop receiving or change the frequency of email, direct mail, phone and mobile marketing communications.
11. Access to and Correction of Personal Data
a) Upon request, We will provide the individual with access to their Personal Data or other appropriate information on their Personal Data in accordance with the requirements of the Singapore Personal Data Protection Laws.
b) Upon request, We will correct an error or omission in the individual’s Personal Data that is in Our possession or control in accordance with the requirements of the Singapore Personal Data Protection Laws.
c) We may charge for processing a request for access in accordance with the requirements of the Singapore Personal Data Protection Laws. Such fee depends on the nature and complexity of Your access request. Information on the processing fee will be made available to You when you make the access request to Us.
d) You may contact Our Data Protection Officer (see Section 13 of this Privacy Policy for contact details) to
i) request access to your Personal Data,
ii) request for correction of your Personal Data, and/or
ii) exercise your rights with respect to the processing of your Personal Data.
12. Withdrawal of ConsentIf You wish to withdraw Your consent to any collection, use and/or disclosure of Your Personal Data as set out in this Privacy Policy, You may contact Our Data Protection Officer (see Section 13 of this Privacy Policy for contact details). Upon reasonable notice being given by You of any withdrawal of any consent given or deemed to have been given in respect of Our collection, use and/or disclosure of Your Personal Data, We will inform You of the likely consequences of withdrawing Your consent, such as the fact that CapBridge will no longer be in a position to continue to provide products and services to You. We will cease (and cause any of Our data intermediaries and agents to cease) collecting, using and/or disclosing the Personal Data unless it is required or authorised under applicable laws and/or regulations.
13. Data Protection OfficerIf You believe that information We hold about You is incorrect or out of date, or if You have concerns or further queries about how We are handling Your Personal Data, or any problem or complaint about such matters, please contact Our Data Protection Officer at DPO@capbridge.sg.
14. AccuracyWhen submitting Personal Data to CapBridge, the individual should ensure that such Personal Data are current, complete, truthful, and accurate. CapBridge will also make reasonable efforts to ensure the Personal Data collected is accurate, truthful, and complete if the Personal Data is likely to be used by CapBridge to make a decision that affects the individual concerned or disclosed by CapBridge to another organisation. You may contact Our Data Protection Officer (see Section 13 of this Privacy Policy for contact details) if You believe that the Personal Data which is in Our possession is incorrect, outdated and/or incomplete, so as to keep us informed of the updates to your Personal Data.
15. Other JurisdictionsIf You are subject to the data protection and privacy policies, laws and regulations applicable in any other territory or jurisdiction (“Privacy Laws”) to which Your Personal Data relates, CapBridge shall:
a) comply with the relevant Privacy Laws regarding the collection, use, retention of Your Personal Data;
b) comply with all standards set by the Privacy Laws in relation to the privacy and security of Personal Data;
c) refrain from any action or inaction that could cause CapBridge to breach any applicable Privacy Laws;
d) do and execute, or arrange to be done and executed, each act, document and thing as necessary to keep CapBridge in compliance with the applicable Privacy Laws; and
e) immediately report the theft or loss of Personal Data (including the Personal Data of your own officers, directors, shareholders, employees or service providers).
16. Governing Law and Dispute Resolution Process
a) This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Singapore.
b) Any dispute arising out of or in connection with this Privacy Policy or in the performance thereof shall be resolved via the Dispute Resolution Process as set out in the Conditions.
