EDBI PRIVACY POLICY Privacy

EDBI Privacy Policy

This Privacy Policy informs you of how EDB Investments Pte Ltd and its fund manager, SG Growth Capital Pte. Ltd., and its managed funds (collectively, “SGGC”), as well as the respective representatives and/or agents (collectively referred to herein as “us”, “we” or “our”) handle your Personal Data (defined below). Please take a moment to read this Privacy Policy and understand our views and practices regarding your Personal Data and the purposes for which we collect, use, disclose and process your Personal Data.

By interacting with us including through email or phone conversations, accessing and using the SGGC website, or submitting information to us, you agree and consent to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to SGGC’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access or use the SGGC website, or provide Personal Data to us.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to SGGC in respect of your Personal Data. Your consents provided to SGGC are cumulative and additional to any rights which SGGC may have at law to collect, use, disclose or process your Personal Data.

We reserve the right to update or change this Privacy Policy from time to time to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. All changes will be published on this page.

To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on this website. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from such data; or (b) from such data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, gender, NRIC, passport or other identification number, date of birth, nationality, telephone number(s), mailing address, email address, employment and training history, salary information and bank account details, details of your next-of-kin, spouse and other family members, work-related health issues and disabilities, photographs and other audio-visual information, performance assessments and disciplinary records, information provided by you as a job applicant, and any other information relating to either yourself or any other individuals which you have provided to us in any forms you may have submitted to us, or via other forms of interaction with you, or information about your use of the SGGC website and services, including cookies and IP address (but only to the extent that SGGC may identify you from such information).

We may also collect your Personal Data from third party sources, for example, from social media sites where we are present and active such as LinkedIn.

2. Collection of Personal Data

2.1

Generally, we collect Personal Data in the following ways

2.1.1

when you submit forms or applications to us;

2.1.2

when you provide your resumes and/or CVs to us;

2.1.3

when you submit queries, requests, complaints or feedback to us;

2.1.4

when you interact with our representatives and agents, whether in person, via telephone calls, virtual meetings, or email or other electronic means;

2.1.5

when we receive references from business partners and third parties (e.g., where you have been referred by them);

2.1.6

when you respond to our requests for additional Personal Data;

2.1.7

when you ask to be included in an email or other mailing list;

2.1.8

when a recruitment agency refers your resume to us;

2.1.9

when you respond to our initiatives or contact us;

2.1.10

when you access and/or browse our website;

2.1.11

when you take part in events organised solely or jointly by SGGC and/or any third parties;

2.1.12

when you are employed or engaged by SGGC; and/or

2.1.13

when you provide your Personal Data to us for any other reasons.

2.2

If you provide us with any Personal Data relating to a third party (e.g., information of your family), by submitting such information to us, you represent and warrant to us that they have read and understood this Privacy Policy and that you have obtained the requisite consent of such third party and/or are authorised to provide us with such Personal Data for the relevant purposes contained in this Privacy Policy.

2.3

You are to ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to fulfil, or delays in processing, your requests and/or applications. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided in paragraph 8 below

2.4

When you access and/or browse the SGGC website, you generally do so anonymously but please see paragraph 6 below for information on cookies and other technologies which we have implemented therein.

3. Purposes for the Collection, Use, Disclosure and Processing of Your Personal Data

3.1

SGGC generally collects, uses, discloses and processes your Personal Data for the following purposes:

3.1.1

responding to, processing and handling your queries, requests, complaints and feedback;

3.1.2

managing the business operations of SGGC and complying with internal policies and procedures;

3.1.3

facilitating investments, collaboration, deal origination activities; partnerships, business asset transactions (which may include but are not limited to any merger, acquisition or asset sale) and business agreements with counterparties;

3.1.4

matching any Personal Data we hold which relates to you for any of the purposes listed herein;

3.1.5

verifying your identity and conducting background checks, to the extent permissible by law, and due diligence;

3.1.6

conducting data analytics for the purpose of (a) system and process improvements, (b) risk/fraud management, (c) regulatory and compliance risk management, (d) investment insights and enhancements to human resources processes;

3.1.7

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 SGGC’s operations and investment activities;

3.1.8

conducting audits, reviews and analyses of our internal processes, strategy and risk management process;

3.1.9

protecting, fulfilling and enforcing SGGC’s legal, contractual or regulatory rights and obligations, including complying with any applicable laws, regulations, rules, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

3.1.10

any purposes exempted from data privacy requirements, or otherwise required or authorised under the applicable laws; and/or

3.1.11

purposes reasonably related to any of the above.

3.2

In addition, SGGC may collect, use, disclose and / or process your Personal Data for the following purposes, depending on the nature of our relationship with you:

3.2.1

if you are an employee, officer or owner of our investment counterparties (including our joint venture partners, brokers, investee companies etc.), potential investment counterparties or partners:

(a)

verifying and processing your personal particulars to maintain accurate records;

(b)

communicating with you to update you of changes and developments to SGGC’s business and investments, policies, terms and conditions and other administrative information;

(c)

creating and maintaining profiles of our investment counterparties, potential investment counterparties or partners in our system database, and sharing these with our affiliates for collaboration and deal origination purposes; and/or

(d)

purposes reasonably related to any of the above;

3.2.2

if you subscribe to our newsletter:

(a)

verifying and processing your personal particulars to maintain accurate records;

(b)

sending you information and updates related to SGGC’s business and investments;

(c)

creating and maintaining profiles of our newsletter subscribers in our system database; and/or

(d)

purposes reasonably related to any of the above;

3.2.3

if you are a job applicant (including employees, contractors, interns and unpaid volunteers):

(a)

verifying and processing your personal particulars, processing your application, evaluating your suitability, eligibility or qualification for employment / engagement by SGGC or our portfolio companies;

(b)

communicating with you to update you of changes and developments to SGGC’s policies, terms and conditions and other administrative information or as required by SGGC to comply with its policies and processes;

(c)

sending you updates and alerts, or contacting you on matters related to job applications which you may have requested for;

(d)

conducting market research for profiling and statistical analysis in relation to your application; and/or

(e)

purposes reasonably related to any of the above;

3.2.4

if you are an employee, officer or owner of an external service provider or vendor:

(a)

verifying and processing your personal particulars and assessing your organisation’s and/or your suitability, eligibility or qualification as an external service provider or vendor for SGGC as well as your organisation’s and your financial status;

(b)

communicating with you to inform you of changes and developments to SGGC’s policies, terms and conditions and other administrative information;

(c)

managing project tenders and quotations, processing orders or managing the supply of goods and services;

(d)

creating and maintaining profiles of our service providers and vendors in our system database;

(e)

processing and payment of vendor invoices and bills; and/or

(f)

purposes reasonably related to any of the above;

3.2.5

if you submit a request through the contact form on the SGGC website:

(a)

verifying and processing your personal particulars to maintain accurate records;

(b)

responding to and sending you information and updates related to SGGC’s business and investments;

(c)

creating and maintaining profiles of you and your request in our system database; and/or

(d)

purposes reasonably related to any of the above.

The purposes listed in the above paragraphs may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

3.3

Furthermore, where permitted under applicable law, if you attend events organised by SGGC or jointly by SGGC and third parties, SGGC may also collect, use, disclose, process and transfer photographs and audio and video recordings in SGGC publications, both print and digital forms, including the SGGC website, newsletters, emails, social media posts and videos, for the purpose of promoting and highlighting SGGC events, exhibiting the capabilities of SGGC and/or you and your company and/or your company’s partnership with SGGC. If you do not wish for any photograph or audio or video recording where you appear to be used by SGGC for its publicity materials, please notify SGGC at the time of registration for the event.

4. Disclosure and/or Transfer of Personal Data

4.1

SGGC will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed to the following parties (whether located in Singapore or overseas), for one or more of the purposes listed above (as may be applicable):

4.1.1

affiliates of SGGC, including the Economic Development Board of Singapore;

4.1.2

recruitment agencies;

4.1.3

portfolio companies, where your job application relates to a job with our portfolio company;

4.1.4

agents, contractors or third party service providers who provide operational services to SGGC, such as cloud service providers and data processors, courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support, investigation services or other services to SGGC;

4.1.5

insurance companies and brokers in connection with staff insurance and indemnity;

4.1.6

any business partner, investor, investment counterparty, partner, assignee or transferee (actual or prospective) to facilitate investments and business asset transactions (which may extend to any mergers, acquisitions and asset sale);

4.1.7

local and overseas financial institutions and their respective service providers;

4.1.8

our professional advisers such as our consultants, auditors and lawyers;

4.1.9

business partners in relation to events planning;

4.1.10

the government of Singapore and/or any ministry, department, agency, judicial or administrative body, statutory body or corporation under the control thereof, including the Enterprise Singapore Board, in compliance with SGGC’s internal reporting and approval requirements;

4.1.11

relevant government regulators, government ministries, statutory boards, embassies, or authorities and/or law enforcement agencies, whether local or overseas, to comply with any directions, laws, regulations, rules, codes of practice or guidelines, or schemes issued or administered by any of them;

4.1.12

other organisations which may request that we provide them with your Personal Data for evaluative purposes; and/or

4.1.13

any other party to whom you authorise us to disclose your Personal Data.

4.2

You consent to us transferring your Personal Data to the parties specified in this Privacy Policy for the purposes specified in this Privacy Policy where such parties are located in a country or territory outside of Singapore, so long as we take appropriate steps to ensure that your Personal Data is handled in accordance with this Privacy Policy, to the standards required by applicable laws.

To the extent that European or other data protection laws apply, you should be aware that Singapore and the other countries or territories in which your Personal Data are located may not have data protection laws which have been acknowledged to ensure adequate protection for Personal Data for the purposes of those laws.

4.3

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

5. Deemed Consent

5.1

In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to SGGC collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to SGGC’s authorised service providers and relevant third parties:

5.1.1

where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to SGGC for such purpose(s);

5.1.2

where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy; and/or

5.1.3

where we have brought to your attention our intention to collect, use or disclose your Personal Data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the SGGC website, or via other forms of communication (e.g. short-form messaging or email) based on the contact particulars that we may have of you in our records from time to time.

6. Use of Cookies, Web Beacons, and Similar Technologies on the Website

6.1

When you visit, access or interact with the SGGC website, we or our authorised service providers may use cookies, web beacons, and other similar technologies for collecting and storing information to help provide you with a better, faster, and safer web experience.

6.2

The information collected by us or our authorised service providers may recognise a visitor as a unique user and may collect information such as how a visitor arrives at our websites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

6.3

The use of cookies, web beacons and similar technologies by us on our website perform different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities.

6.3.1

Cookies – Small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognise a particular device or browser. There are several types of cookies:

(a)

Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.

(b)

Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.

(c)

First-party cookies are set by the site you are visiting.

(d)

Third-party cookies are set by a third party site separate from the site you are visiting.

Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be selected separately and different browsers offer different functionalities and options.

You can find out more about cookies at www.allaboutcookies.org.

6.3.2

Web beacons – Small graphic images (also known as “pixel tags” or “clear GIFs”) may be included on our websites and services. Web beacons typically work in conjunction with cookies to profile each unique user and user behaviour.

6.3.3

Similar technologies – Technologies that store information in your browser or device utilising local shared objects or local storage, such as flash cookies, HTML 5 cookies, and other web application software methods. These technologies can operate across all of your browsers.

6.4

We offer certain website features and services that are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits.

6.5

However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain website features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.

6.6

The SGGC 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 is personally identifiable for the purposes of:

6.6.1

managing and customising your experience on the website;

6.6.2

analysing trends and improving our site for our users; and

6.6.3

delivering content tailored to your interests and the manner in which you browse our website and platforms,

and will be treated accordingly as Personal Data by SGGC acting in compliance with this Privacy Policy and applicable law.

7. Third-Party Sites and Cookies

7.1

Our website may contain links to, or may be linked from, other websites operated by third parties and which are not controlled by us and to which we have not provided permission, including but not limited to our portfolio companies and business partners. We are not responsible for nor make any representations about any other websites, including their products and services, contents, communications and privacy practices. We encourage you to learn about the privacy policies of such third party websites before you submit any Personal Data to these websites. We expressly disclaim any responsibility for your access to or use of such other websites.

7.2

Third party websites (including but not limited to advertising networks and providers of external services like Google Analytics) may use cookies which are downloaded when you visit our website. These cookies are likely to be analytical, performance or targeting cookies. To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

8. Withdrawal of Consent, Access and Correction of your Personal Data

8.1

If you:

8.1.1

have any questions or feedback relating to your Personal Data or our Privacy Policy;

8.1.2

would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or

8.1.3

would like to obtain access or make corrections to your Personal Data,

please contact the SGGC Data Protection Officer at legal@sggc.sg.

8.2

If your Personal Data has been provided to us by a third party, you should contact such third party directly to make any queries, feedback, and access and/or correction requests to EDBI on your behalf.

8.3

The consent that you provide for the collection, use, disclosure and processing of your Personal Data will remain valid until such time it is being withdrawn by you in writing. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the likely consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.

8.4

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, SGGC may no longer be in a position to administer or comply with the relevant contractual agreement or arrangement in place. This may also adversely impact and affect your relationship or other agreements or arrangements with SGGC. SGGC’s legal rights and remedies in such event are expressly reserved.

8.5

Please note that withdrawing consent does not affect our right to continue to collect, use, disclose and process Personal Data where such collection, use, disclosure and processing without consent is permitted or required under applicable laws.

8.6

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your access request. We will respond to your access request as soon as reasonably possible. If we are unable to provide you with any information pursuant to your access request or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required or permitted to do so under applicable law).

9. Retention of Personal Data

9.1

We may retain your Personal Data and you have no right to demand your Personal Data be destroyed for as long as it is necessary to fulfil the purposes for which they were collected, and as required or permitted by applicable laws.

9.2

To this end, we will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

10. Governing Law

10.1

This Privacy Policy shall be governed in all respects by the laws of Singapore.

EDBI Privacy Policy

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