Privacy Policy

Please read this Privacy Policy for important information about how we may collect and Use your Personal Data. By continuing to use this Site, you acknowledge that you have read, understood, and agreed to the contents of this Privacy Policy.

Last Updated 14 January 2022

1. Introduction

This privacy policy (the “Privacy Policy”) explains how we may collect, process, and share your Personal Data (as defined below). Falcon House Capital Management Pte. Ltd. (“FHCM” and, for purposes of this Privacy Policy only, together with its affiliates and certain private funds managed or advised by FHCM, the “Falcon House Group”) respects your privacy and is committed to protecting your Personal Data (as defined below). We strongly encourage you to read this Privacy Policy carefully and make sure that you understand its terms. Specifically for users of our Site (as defined below), we will reasonably assume that your continued use of our Site indicates your understanding of this Privacy Policy.

2. Your Personal Data

Your “Personal Data” is any information that relates to, describes, identifies, or can be used, directly or indirectly, to identify or otherwise specifically describe you as an individual, including but not limited to your name, address, date of birth, and personal identification numbers, but it does not include data from which your identity has been removed or which has been otherwise anonymized, or aggregate data from which it is not possible to identify you as an individual.

3. About Us & How Data Protection Laws Apply to Our Use of Your Personal Data

The Falcon House Group is made up of different legal entities, which may be subject to different laws and regulations regarding the collection, processing, and sharing (collectively, the “Use”) of your Personal Data based on the jurisdictions in which they are formed or operate and the jurisdiction in which you live. This Privacy Policy is issued on behalf of the Falcon House Group, so when we refer to “Falcon House”, “we”, “us”, or “our” in this Privacy Policy, we are referring to the relevant entity of the Falcon House Group responsible for Using your Personal Data.

FHCM is a company incorporated with limited liability in Singapore and subject to the Singapore Personal Data Protection Act 2012, as amended (the “PDPA”). Certain private funds that are part of the Falcon House Group are subject to the Cayman Islands Data Protection Law, 2017, as amended (the “DPL”). In addition, depending on your legal residence, you and your Personal Data may be subject to additional laws or regulations. For example, if you are a resident of the United Kingdom or European Union, the General Data Protection Regulation (the “GDPR”) may apply to you; if you are a resident of Hong Kong, the Hong Kong Personal Data (Privacy) Ordinance, as amended (the “PDPO”) may apply to you; or if you are a resident of the State of California, the California Consumer Privacy Act of 2018, as amended (the “CCPA”) may apply to you.

While we strive to comply with all laws and regulations that may apply to you and your Personal Data, owing to the international nature of our business and the various legal residences of persons with respect to whom we may have a lawful need to Use Personal Data, it is not practical for this Privacy Policy to enumerate all the laws and regulations that may apply to you and your Personal Data. Therefore, this Privacy Policy is intended to set out our policies with regard to the Use of your Personal Data in a manner consistent with the the provisions of the PDPA, DPL, GDPR, PDPO, and CCPA (collectively, the “Data Protection Laws”), but is without prejudice to your rights under them or under other laws or regulations that may apply to you and your Personal Data.

If you have questions or concerns about our Use of your Personal Data, or how the Data Protection Laws or other laws or regulations may apply to you and your Personal Data, we encourage you to contact us via one of the methods set-out in Section 13 below, or via the Contact Us page on our Site (as defined below).

4. About this Privacy Policy & Who It Covers

This Privacy Policy will inform you about how we Use your Personal Data and about your privacy rights and how the law protects you and your Personal Data.

This Privacy Policy applies to:

  • Individuals with whom Falcon House may have had contact for business purposes, either on our own account or on behalf of third parties or organizations, including prospective individual investors and persons associated with prospective investors in certain private funds that are members of the Falcon House Group;

  • Individuals who are employed by or otherwise associated with Falcon House’s suppliers, vendors, or professional advisors;

  • Individuals who are involved in transactions or potential transactions which are conducted or evaluated by Falcon House;

  • Individuals with whom Falcon House has contact during a recruitment process;

  • Individuals who have accessed or used our website (the “Site”);

  • Individuals who have opted to receive communications from us; and

  • Individuals who may interact with us in other ways that reference this Privacy Policy (including by providing a hyperlink to this Privacy Policy on our Site).

 

In our normal course of business, we do not expect to interact with children or knowingly Use Personal Data about them, including from our Site (which is not intended for children). However, we are particularly concerned about the safety and privacy of children. If a child under the age of 13 (16 in some jurisdictions, depending on the applicable Data Protection Laws) has provided Personal Data to Falcon House via our Site or by other means, a parent or legal guardian may contact us via one of the methods set-out in Section 13 below, or via the Contact Us page on our Site, and we will use commercially reasonable efforts to destroy or delete it, subject to applicable laws and regulations and this Privacy Policy.

This Privacy Policy does not form part of any contract for services. Specifically, Falcon House makes available separate privacy notices for, and this Privacy Policy does not apply to:

  • Individuals invested in or associated with investors in certain private funds that are members of the Falcon House Group; and

  • Individuals who are employees, contractors, and other personnel of the Falcon House Group.

5. Data Protection Principles

We are committed to complying with the Data Protection Laws and generally accepted business practices regarding the Use of your Personal Data.

Specifically, we will:

  • Only Use your Personal Data lawfully, fairly, and in a transparent manner;

  • Only Use your Personal Data for valid purposes that we have explained to you;

  • Only Use your Personal Data that is relevant to the purposes about which we have told you;

  • Use our commercially reasonable efforts to make sure that your Personal Data is accurate and, to the extent appropriate, kept up to date;

  • Only keep your Personal Data as long as necessary for the purposes we have told you about or to comply with applicable laws or regulations; and

  • Use our commercially reasonable efforts to keep your Private Data secure.

6. Your Personal Data & Our Purposes & Lawful Basis For Using It

We will only Use your Personal Data when the Data Protection Laws and other applicable laws and regulations allow or require us to so.

Most commonly, we will Use your Personal Data in the following circumstances, each of which is a legal basis:

  • Where we need to perform the contract we are about to enter into or have entered into with you;

  • Where it is necessary for our legitimate interests, as explained in the sections below that may apply to you, and your interests and fundamental rights do not override those interests; or

  • Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent alone as a legal basis for Using your Personal Data. Please note that, subject to the Data Protection Laws, we may Use your personal information without your knowledge or consent, in compliance with this Privacy Policy, where such Use is required or permitted by applicable law or regulation.

If you fail or decline to provide certain Personal Data which we may request from you, we may not be able to perform any contract we have entered into with you, or we may be unable to deal with you in such other capacity as may apply to you.

We will only Use your Personal Data for the purposes which we have described in this Privacy Policy, or as otherwise permitted by the Data Protection Laws, unless we reasonably consider that we need to use it for another reason and that reason is not incompatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will use our commercially reasonable efforts to notify you and explain the legal basis which allows us to do so.

As discussed below, Falcon House may Use your Personal Data in different ways depending on the ways in which you interact with us and your relationship with us. Please note that you and your Personal Data may be covered by more than one of the following categories depending on the different ways in which you interact with us and your relationship with us over time.

Visitors to Falcon House’s Site

When you visit our Site, we may Use your Personal Data through automated means.

For example, we may collect your IP address each time you request a page during a visit to the Site; an IP address is often associated with the portal through which you enter the Internet. At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. We may also collect geolocation data (e.g., your physical location) when you visit our Site to the extent that the device on which you are visiting our Site provides such data.

The Site may also use other technical methods to track and analyze the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send our Site users to determine whether such users have opened those e-mails or clicked on links in those e-mails. We may collect the information from use of these technical methods in a form that constitutes Personal Data.

During some visits to the Site, we may use software tools such as web beacons or JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse overs), and methods used to browse away from the page. We may use this information to measure Site activity, to develop ideas for improving our Site, and, subject to the Data Protection Laws, for any other purpose to the extent permitted by applicable law.

If you wish to contact us using the Contact Us page our Site, you will need to provide your name and contact details so that we may accurately record your message, including for legal and compliance purposes in accordance with our applicable policies, and respond to your message.

Our legal basis for Using Personal Data about visitors to our Site is that such Use is necessary for our legitimate interests in maintaining, updating, and securing our Site, and in undertaking business development and promotion.

Please note that our Site may provide links to third-party websites for your convenience and information. Such third-party websites operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. Falcon House is not responsible for the privacy practices of such third-party websites.

Please also see Section 7 (Cookies & Digital Advertising) below.

Visitors to Falcon House’s Offices & Events

When you visit our offices or attend events organized by us, we may Use the following Personal Data about you for the following purposes:

  • Contact information from security lists of visitors to our offices or events in line with our legitimate interest in the security of our offices and events;

  • Video images of you in the entry and exit areas of our offices or events from CCTV footage in line with our legitimate interest in the security of our offices and events;

  • Audio, video, or still photos of you at our meetings or events, which may include meetings events held in our offices or online, in line with our legitimate interests in memorializing such meetings or events and for publicity, marketing, and public relations purposes;

  • Your name and time of entry into and exit from our offices, meetings, or events through a security access system in line with our legitimate interest in the security of our offices and events;

  • Your name and dietary preferences for catering purposes in meetings in our offices or at events in line with our legitimate interest in respecting your dietary needs;

  • Limited health data to assist in the control of infectious diseases, e.g., Covid-19, in line with our legitimate interest in protecting the health of our staff, visitor, and guests and our legal obligations for health and safety;

  • If applicable, health information from completion of an accident log in order to comply with our legal obligations for health and safety; and

  • Your name, organization, and contact information for the purpose of organizing meetings and events, including meetings and events held in our offices, and providing, e.g., name badges, attendee lists, team lists, and table plans.

 

We may share the Personal Data we have about visitors to our offices or attendees at our events with:

  • Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, security, legal, accountancy, data, marketing, event management, and catering services;

  • Professional advisors, including accountants, lawyers, or other consultants;

  • Other companies in the Falcon House Group;

  • Auditors of companies in the Falcon House Group; and

  • Applicable regulators and other governmental agencies anywhere in the world.

 

Please note that when you visit our offices or attend our events, various third parties, including the management of the buildings in which our offices are located or of the venues in which our events are held, may, independently of and separately from Falcon House and any Personal Data we may share with them in accordance with this Privacy Policy, collect and use your Personal Data for their own purposes, including security, event management, and publicity. Any such third party acts as the controller of your Personal Data for such purposes and so are subject to a separate privacy notice which you should obtain from them. Falcon House is not responsible for the privacy practices of such third parties.

Individuals With Whom Falcon House Has Contact for Business Purposes

If you have contact with Falcon House, for example through emailing or meeting a representative of Falcon House, we may Use your Personal Data, such as your name, job title, organization, and contact details.

We may your Use Personal Data that is publicly available, including biographical information or information about your background and professional experience, or which you have provided us to add to Falcon House’s contacts directory. Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you. We will use this Personal Data for the purposes of:

  • Maintaining a directory of contacts;

  • Organizing meetings between you and Falcon House’s representatives;

  • Keeping records of our relationship and communications with you;

  • General business marketing, including reporting on macro trends and other business and economic insights;

  • Sending you periodic updates about Falcon House’s business, events, presentations, and opportunities, including by email and post; you can opt out of receiving such updates at any time by contacting us via one of the methods set-out in Section 13 below or via the Contact Us page on our Site, by asking your Falcon House business contact, or, if applicable, by clicking the “Unsubscribe” link in an email you receive from us.

 

We may share the Personal Data we have about our business contacts with:

  • Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, security, legal, accountancy, data, marketing, and catering services;

  • Professional advisors, including accountants, lawyers, or other consultants;

  • Other companies in the Falcon House Group;

  • Auditors of companies in the Falcon House Group; and

  • Applicable regulators and other governmental agencies anywhere in the world.

 

Our legal basis for Using Personal Data about business contacts is that such Use is necessary for our legitimate interests in undertaking business development and promotion.

Individuals Who Are or Who Are Associated with Falcon House’s Suppliers, Vendors, or Professional Advisors

If you, or a company with which you are associated as an employee or otherwise, is a supplier, vendor, or professional advisor to Falcon House, we may Use your Personal Data, such as your name, job title, qualifications, organization, and contact details.

We may your Use Personal Data that is publicly available, including biographical information or information about your background and experience, or which you have provided us, for the purpose of conducting anti-money laundering checks, administering and maintaining records of goods, services, or advice we have received, and commissioning further services or procuring further goods. Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you, in order to document and keep records of our relationships with our suppliers, vendors, and professional advisors.

We may share the Personal Data we have about our suppliers, vendors, and professional advisors with:

  • Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services;

  • Professional advisors, including accountants, lawyers, or other consultants;

  • Other companies in the Falcon House Group;

  • Auditors of companies in the Falcon House Group; and

  • Applicable regulators and other governmental agencies anywhere in the world.

 

Our legal basis for Using Personal Data about individuals who are, or who are associated with, our suppliers, vendors, or professional advisors is that such Use is necessary for our legitimate interests in operating our businesses.

Individuals Who Are Involved In Transactions Or Potential Transactions With Falcon House

If you, or a company with which you are associated as an employee or otherwise, is involved in a transaction relating to Falcon House’s business, including as a potential investor in a private fund that is part of the Falcon House Group, we may Use your Personal Data.

To the extent applicable, such Personal Data may include your business and personal contact details, interests or marketing preferences, professional opinions and judgements, visual images and photographs required for business purposes, log-in details for user accounts, information relating to your financial status and dealings, nationality information (including copies of identity documents, such as a passport), references provided by third parties, and results of other due diligence we may carry out in accordance with our policies, legal or regulatory requirements, or other reasonable business practice. Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you. We may also make inferences about you from your Personal Data, for example regarding your investment interests and preferences.

We may Use such Personal Data for the purposes of:

  • Performing conflict checks;

  • Verifying the identify of individuals;

  • Undertaking due diligence and performing background checks;

  • Conducting anti-money laundering checks;

  • Evaluating potential transactions;

  • Maintaining records of investments;

  • Trade and transaction reporting;

  • Administering transactions that are entered into;

  • Statistical analysis and market research;

  • Keeping records of our relationship and communications with you;

  • Maintaining records of investments and potential investments;

  • Billing and invoicing purposes;

  • Complying with our regulatory and legal obligations, including assessing and managing risks;

  • Identifying, preventing, and reporting fraud, money laundering, tax evasion, and other unlawful activity;

  • Safeguarding our legal rights and interests;

  • Seeking and receiving advice from our professional advisors, including accountants, lawyers, and other consultants;

  • Organizing and holding meetings and events;

  • Marketing of investment products;

  • General business marketing, including reporting on macro trends and other business and economic insights; and

  • Sending you periodic updates about Falcon House’s business, events, presentations, and opportunities, including by email and post; you can opt out of receiving such updates at any time by contacting us via one of the methods set-out in Section 13 below, via the Contact Us page on our Site, by asking your Falcon House business contact, or, if applicable, by clicking the “Unsubscribe” link in an email you receive from us.

 

We may share the Personal Data we have about counter-parties with whom we may, or may explore, conducting business with:

  • Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services;

  • Credit reference agencies;

  • Financial intermediaries;

  • Background verification or private investigative services, or other risk management services;

  • Other persons who have an interest or involvement in, or are considering an interest or involvement in a transaction in which Falcon House is involved, including co-investors, other providers of financing, and investors in certain private funds that form a part of the Falcon House Group;

  • Professional advisors, including accountants, lawyers, or other consultants;

  • Other companies in the Falcon House Group;

  • Auditors of companies in the Falcon House Group; and

  • Applicable regulators and other governmental agencies anywhere in the world.

 

Our legal basis for Using Personal Data about counter-parties with whom we may, or may explore, conducting business with is that such Use is necessary for our legitimate interest in running our business, including by advising on potential transactions. If we enter into a transaction that you are, or a company with which you are associated is, involved in, we will also need to Use your information for the purpose of completing such transaction and complying with our regulatory and legal obligations.

Individuals with Whom Falcon House Has Contact During a Recruitment Process

We may Use Personal Data about candidates during the application and recruitment process, including Personal Data provided by candidates, from third parties, including recruitment agencies, job sites, former employers, and background verification services, and Personal Data which is publicly available, including from professional networking sites, social media, blogs, and other online or digital sources.

We may Use the following Personal Data about candidates:

  • Personal contact details such as name, title, addresses, telephone numbers, and personal email address;

  • Date of birth;

  • Nationality;

  • Current salary, bonus, annual leave, pension, and benefits information;

  • Current notice period;

  • Desired start date with Falcon House;

  • Desired location of employment or workplace;

  • Passport number and driver’s license;

  • Recruitment information, including copies of right to work documentation, references, and other information included in a CV or cover letter as part of the application process;

  • Employment records, including job titles, responsibilities, work history, working hours, language capabilities, training records, appraisal and fitness and propriety records, and professional memberships;

  • Compensation history; and

  • Audio, video, or still photographs required for business purposes.

 

Additionally, we may collect and retain a record of all our communications with you, in whatever form, which may include notes from and audio or video recordings of our meetings with you.

We will Use your Personal Data to:

  • Evaluate your qualifications for and suitability as a candidate for employment with Falcon House;

  • Arrange interviews, meetings, tests, or events in connection with the recruitment process;

  • Verify your education and work history, professional licenses or memberships, and fitness and propriety;

  • Keep records of our relationship and communications with you; and

  • Take other necessary steps prior into entering into an employment or other contractual arrangement with you.

 

In connection with the recruitment process, we may share the Personal Data we have about candidates with:

  • Third-party service providers which process such Personal Data on Falcon House’s behalf, including providers of telecoms, IT, courier, HR, security, legal, accountancy, data, and catering services;

  • Background verification services;

  • Professional advisors, including accountants, lawyers, or other consultants;

  • Other companies in the Falcon House Group;

  • Auditors of companies in the Falcon House Group; and

  • Applicable regulators and other governmental agencies anywhere in the world.

 

Should you be successful in your application, we will only transfer Personal Data to your employment record if it is relevant to your ongoing working relationship with Falcon House.

Should you be unsuccessful in your application, we will destroy or delete your application details but will keep on file your name, any additional identifiers needed to distinguish you from candidates with the same name, your contact details, and the position for which you applied for future recruitment purposes, unless you specifically request this should not be the case.

Where legally permissible, we may also ask you to voluntarily provide additional Personal Data, including regarding your gender, race/ethnicity, disability status, or status as a veteran. Falcon House will not consider either this information or your choice to provide it in evaluating your qualifications for employment with us. This Personal Data will be Used only for legal and compliance purposes and only shared in accordance with applicable law or regulations.

Our legal basis for Using Personal Data about candidates for employment with us is that such Use is necessary for our legitimate interests in operating our businesses, including our legitimate interest in attracting and retaining the qualified personnel necessary to operate our business.

Once you are no longer a candidate for employment with Falcon House, we will not keep any Personal Data about you for any longer than is necessary for the purposes for which we need to Use such Personal Data and will destroy or delete such Personal Data after such time.

Please note that third-party recruitment agencies or job sites which collect and use your Personal Data, including for the purpose of introducing you as a candidate at Falcon House, act as the controller of your Personal Data for that purpose and so are subject to a separate privacy notice you should obtain from them. Falcon House is not responsible for the privacy practices of such third parties.

7. Cookies & Online Advertising

Our Site’s use of cookies and the ways in which you may disable or remove cookies are discussed in our Cookie Policy. Our Cookie Policy forms an integral part of this Privacy Policy and you should review it carefully.

Falcon House does not track visitors to our Site over time and across third party websites to provide targeted advertising, and therefore our Site does not respond to Do Not Track signals.

8. Automated Decision-Making

We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, including with respect to recruitment processes, based solely on automated Use of your Personal Data, unless we have considered the proposed automated Use in a particular case and concluded in writing that it meets the applicable requirements of applicable Data Protection Laws.

9. Sharing Your Personal Data

We may share your Personal Data:

  • If we are required to do so by law or legal process;

  • To law enforcement authorities, regulators, other government entities, or other competent authorities based on a lawful disclosure request; or

  • When we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected illegal activity, including fraud, money laundering, or tax evasion.

 

We always expressly reserve the right to transfer your Personal Data to a third party in the event that we sell or transfer all or a portion of our business or assets, including in the event of a reorganization, spin-off, dissolution, or liquidation.


Falcon House does not sell your Personal Data to any third party for marketing or any other purposes.

We may share your Personal Data with third parties, including to third-party services providers when it is necessary to administer our relationship with you, or when we believe it is necessary or consistent with our legitimate interests set out in this Privacy Policy.

We use a variety of third party service providers from time-to-time to provide a wide range of services, including telecoms, IT, courier, HR, security, legal, accountancy, data, transportation, and catering services.

Our contracts or other legal arrangements with any third party with whom we share your Personal Data require them to keep your Personal Data secure and confidential and treat it in accordance with applicable Data Protection Laws. Except for when a third-party’s has a direct relationship with you or when they otherwise act as a controller of your Personal Data, we do not allow our third-party service providers to Use your Personal Data for their own purposes. We only permit them to process your Personal Data for the purposes set out in this Privacy Policy and in accordance with our instructions.

If we transfer your Personal Data outside the jurisdiction in which we initially Used it, to a third party or otherwise, we will use our commercially reasonable efforts to protect your Personal Data in a manner similar to that of such initial jurisdiction and subject to applicable Data Protection Laws.

The steps we may take to do this may include:

  • Only transferring your Personal Data to jurisdictions that have been deemed to provide an adequate level of protection for personal data in accordance with applicable Data Protection Laws;

  • Using specific contract language that gives your Personal Data the same protection as it would have in such initial jurisdiction in accordance with applicable Data Protection Laws; or

  • Using a data transfer mechanism, safe harbor, or other similar arrangement that may be approved for the transfer of Personal Data between different jurisdictions in accordance with applicable Data Protection Laws.

10. Data Security

We have put in place commercially reasonable security measures to protect your Personal Data, consistent with generally accepted business practices for a business of our type, and in accordance with applicable Data Protection Laws and our other legal and regulatory obligations.

Such measures include those to prevent your Personal Data from being accidentally lost, Used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a legitimate need to access it in accordance with the purposes we have set out in this Privacy Policy. We have also put in place procedures to deal with any suspected security breach and will notify you and any applicable regulator of a suspected breach where we are required to do so in accordance with applicable Data Protection Laws.

11. Data Retention

We will only retain your Personal Data for as long as necessary to fulfill the purposes we Use it for as described in this Privacy Policy, including for the purposes of satisfying any legal, regulatory, accounting, data retention, record keeping, or reporting requirements.

To determine the appropriate retention period for your Personal Data, we consider the amount, nature, and sensitivity of your Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we Use your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements including any applicable Data Protection Laws.

12. Your Responsibilities & Rights in Connection with Your Personal Data

You have certain obligations and rights when it comes to our Use of your Personal Data.

Your Responsibility To Inform Us Of Changes

In order for us to Use your Personal Data for the purposes set out in this Privacy Policy, it is important that your Personal Data Used by us are accurate and current.

While we will from time-to-time make commercially reasonable efforts to update your Personal Data, including asking you for updates, you also have a responsibility to update your Personal Data with us.  Please keep us informed if your Personal Data changes during the course of your relationship with us.

Your Rights In Connection With Your Personal Data

In accordance with Data Protection Laws that may be applicable to you, but subject at all times to our other legal and regulatory obligations, including those to retain data and keep accurate records, under certain circumstances you may have the right to:

  • Request access to your Personal Data – This enables you to receive a copy of your Personal Data used by us and to check that we are Using it lawfully;

  • Request correction of your Personal Data – This enables you to correct any incomplete or inaccurate Personal Data that we Use;

  • Request destruction or deletion of your Personal Data – This enables you to ask us to destroy or delete your Personal Data where there is no legally valid reason for us to continue to Use it; you also have the right to ask us to destroy or delete your Personal Data where you have exercised your right to object to our Use of it (see below);

  • Object to Use of your Personal Data – This enables you to object to our Use of your Personal Data where we are relying on our legitimate interests (or those of a third party) for such Use and there is something about your particular situation that makes you want to object to our Use on such basis; you also have the right to object if we are Using your Personal Data for direct marketing purposes;

  • Request the restriction of our Use of your Personal Data – This enables you to ask us to suspend the Use of Personal Data about you, for example if you want us to establish its accuracy or our reason for Using it; and

  • Request the transfer of your Personal Data – This enables you to ask us to transfer a copy of your Personal Data to a third party.

 

If you want to review, verify, correct, or request destruction or deletion of your Personal Data, object to the Use of your Personal Data, or request that we transfer a copy of your Personal Data to a third party, please contact us via one of the methods set-out in Section 13 below or via the Contact Us page on our Site.

Depending on your country of residence and the laws there that may apply to our Use of your Personal Data, you may also have the right to lodge a complaint about our Use of your Personal Data with the body regulating data protection in such country.

No Fee Usually Required

You will normally not have to pay a fee to access your Personal Information or to exercise any of your other rights set forth above.

However, we may, in accordance with applicable Data Protection Laws, charge a reasonable fee if we determine that your request for access if clearly unfounded or excessive, including, for example, for repeat copies. Alternatively we may, in our discretion, refuse to comply with your request in such circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data or to exercise any of your other rights set forth above.

This is a necessary security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

 
Your Right To Withdraw Consent

In the limited circumstances where we are relying solely on your consent to the Use of your Personal Data for a specific purpose, you have the right to withdraw your consent to our Use for such purpose at any time.

To withdraw your consent, please contact us via one of the methods set-out in Section 13 below or via the Contact Us page on our Site. Once we have received notification that you have withdrawn your consent, we will no longer use your Personal Data for the specific purpose to which you previously consented, unless we have another legally valid reason for doing so in accordance with applicable Data Protection Laws or other laws and regulations to which we may be subject.

13. Privacy Policy & Personal Data Contact

Please contact us if you have any questions about this Privacy Policy, your Personal Data that we Use, or any other matter covered by this Privacy Policy.

In most cases, FHCM will be the processor or controller of your Personal Data; in cases where another member of the Falcon House Group is the processor or controller of your Personal Data, you may still contact FHCM with your query and you will be directed to the appropriate point of contact at such other member of the Falcon House Group.

You may contact FHCM by any of the following methods; please mark your communication “Privacy Policy Enquiry” to ensure its prompt handling.

By Post

Falcon House Capital Management Pte. Ltd.
Attn: Data Protection Officer
541 Orchard Road
#18-01 Liat Towers
Singapore 238881

 
By Facsimile

+65 6735 4135

 
By Email

PrivacyPolicy@FalconHousePartners.com

 
By Using The Contact Us Page On Our Site.

14. Access & Revisions to this Privacy Policy

You may obtain the current version of this Privacy Policy by visiting our Site. We will indicate in this section of this Privacy Policy when it was last updated. We reserve the right to update or modify this Privacy Policy at any time and without prior notice to you.

For this reason, each time you use this Site you should review this Privacy Policy for any changes that may apply to your use of the Site at such time.

This Privacy Policy was last updated on 14 January 2022.

Privacy Policy