INTRODUCTION

These Terms and Conditions or Notice (“Notice”), covers the use and terms of the following: 1. Website Disclaimer; 2. Privacy Policy & Personal Data Protection Act; and 3. Email Confidentiality, Professional Privilege and Privacy Policy Notice, it describes how, Crosspoint Capital Asia Pte. Ltd. (“CCA”) and its related corporations, representatives and/or agents (collectively, “Crosspoint Capital Asia”, “CCA”, “we”, “us”, or “our”) are covered under these Terms and Conditions in accordance with regulatory requirements in Singapore.

These Terms and Conditions supplements and does not supersede any other consent or privacy terms you may have provided to us. It is in addition to our rights at law to collect, use or disclose personal data.

By interacting with us, submitting your own or another individual’s personal data to us, using our website, or viewing or signing up for our products/services, you confirm that you (and such other individual, where applicable) agree and consent to Crosspoint Capital Asia Pte Ltd’s collection, use, disclose, process and safeguard personal data pursuant to the Singapore Personal Data Protection Act 2012 (“PDPA”). Please do not send us personal data if you do not want it used as described here.

1. WEBSITE DISCLAIMER

Crosspoint Capital Asia Pte. Ltd. (“Crosspoint Capital Asia”) (Company Registration No. 201010341G) holds a Capital Markets Services Licence issued by the Monetary Authority of Singapore for the conduct of fund management activities under the Securities and Futures Act 2001 (“SFA”).

The information on this website is intended for accredited investors (“Accredited Investors”) as defined in Section 4A(1)(a)(i) of the SFA, and Institutional Investors as defined in Section 4A(1)(c) of the SFA, which can be found here. None of the contents of this website have been reviewed or endorsed by the Monetary Authority of Singapore.

The contents of this website or E-mail are for general information purposes only and have been prepared without consideration of the specific investment objectives, financial situation, or particular needs of any person. No representations or warranties, express or implied, are made as to the reliability, accuracy, or completeness of the information, and any liability for errors or omissions is expressly disclaimed.

Crosspoint Capital Asia reserves the right to make changes, deletions and corrections at any time without notice. Any opinions or estimates are subject to change without notice. Crosspoint Capital Asia, its directors, officers, employees, or affiliates accept no liability for any loss or damage (direct or consequential) arising from any use of or reliance on this website or its contents.

This website may contain forward-looking statements or information derived from third parties. Actual results may differ materially from those expressed or implied. Crosspoint Capital is not responsible for, and does not endorse, any third-party websites or materials linked to this site.

Nothing contained in this website constitutes an offer to sell, a solicitation to buy, or investment advice or a recommendation in respect of any fund or investment product. Crosspoint Capital Asia funds are offered only through the offering document(s) with respect to each fund. The value of units/shares and income from them may fall as well as rise, and investors may not get back the amount originally invested. Past performance is not indicative of future performance.

Investments are subject to risks, including the possible loss of the principal amount invested. Units/shares in the fund are not obligations of, deposits in, or guaranteed by Crosspoint Capital Asia or any of its affiliates. Distributions (if any) are not guaranteed by Crosspoint Capital Asia or any of its affiliates. Where distributions (if any) are made out of capital, in accordance with the prospectus, the net asset value per unit may be immediately reduced. Some funds may exhibit higher volatility due to their investment policies or techniques, including the use of in financial derivative instruments. You should seek independent legal or tax advice before making any investment decisions.

The information on this website is not intended for persons located or resident in jurisdictions where such distribution is restricted or unauthorized. No action has been taken to authorize, register or qualify any Crosspoint Capital Asia funds or to permit a public offering in any jurisdiction.

This website and its contents are protected by copyright and other intellectual property laws. No part of this website may be copied, distributed, or reproduced without prior written consent from Crosspoint Capital Asia.

Terms of Access

By accessing this website, you undertake, warrant, and confirm that:

  • You are an Accredited Investor or Institutional Investor, and are accessing information published on this website for your information purposes only. You understand that nothing herein constitutes an offer, solicitation, or investment advice by Crosspoint Capital Asia.
  • You are accessing this website on your own initiative and in compliance with the laws and regulations of your jurisdiction.
  • You, or any other person or entity you represent initiated the communications with Crosspoint Capital Asia or its representatives, and none of Crosspoint Capital Asia or its representatives at any time directly or indirectly contacted you with respect to the provision of investment advisory services or investment in a Crosspoint Capital Asia fund prior to such unsolicited initiation of discussions, correspondence or other communications.

This website uses cookies to improve user experience. By using this website, you consent to our use of cookies.

Acceptance

By clicking “Accept”, you have acknowledged that you have read, understood, and agreed to the Terms and Conditions under the Website Disclaimer.

*This website has not been reviewed by the Monetary Authority of Singapore. These terms are governed by the laws of Singapore.

2. PRIVACY POLICY & PDPA

Personal Data

“Personal data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which Crosspoint Capital Asia Pte Ltd has or is likely to have access.

Personal Data We Collect

In the course of our provision of services, you may provide personal data to us. Your personal data may also be provided by someone on your behalf, in which case, we will assume until notified otherwise, that you have authorised the disclosure of your personal data to us.

If you provide us with any personal data relating to a third party (e.g. information on your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their personal data, and for the collection, use and disclosure of their personal data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include, but not limited to:

  • Identification and KYC data: full name, nationality, date/place of birth, government-issued identifiers (e.g., NRIC/FIN, passport, tax ID), specimen signatures.
  • Contact details: address, email, telephone number(s).
  • Employment/education/income details; client onboarding and transaction records; instructions/confirmations.
  • Financial/billing data: bank account, payment details.
  • Recordings: call logs/recordings, CCTV/entry logs, photographs, video/voice recordings (incl. at our events or premises).
  • Opinions and responses to surveys or feedback requests.
  • Technical/usage data: IP address, device identifiers, connection logs, browsing history/patterns, cookies and similar technologies.
  • Any other information you (or a third party on your behalf) provide to us in forms, agreements, correspondence or otherwise.

If you provide personal data relating to another individual (e.g., spouse, dependants, employees), you represent that you have authority and have obtained the individual’s consent for our collection, use and disclosure for the purposes set out in this Notice.

How We Collect Personal Data

Generally, we may collect your personal data through, among others:

  • Account opening/onboarding, transaction and other forms; agreements you enter with us.
  • Your instructions, confirmations and other dealings with us.
  • Interactions with our staff/representatives (phone – may be recorded, email, meetings, online/virtual rooms, social platforms).
  • Use of our websites, portals, apps and other technology platforms (including account creation).
  • Submissions in response to our job postings or contractor engagements (CVs, references, interviews, background checks).
  • Events, seminars, functions, surveys and market research conducted by us or our service providers.
  • Third-party sources (e.g., distributors, referrers, business partners, public agencies, previous employers), where permitted by law and/or with your consent.
  • Due diligence and screening (e.g., AML/CFT, sanctions, adverse media).
  • Where you voluntarily submit personal data to us for any purpose.

Why We Collect/Use/Disclose Personal Data (Purposes)

Generally, We collect, use and/or disclose personal data for the following purposes (“Purposes”):

Client & Investor Servicing

  • Processing registrations, onboarding (including KYC/AML/CFT), account set-up, and transactions in our products/services.
  • Administering holdings, sending statements/notices, servicing enquiries/requests, providing updates and service notifications.
  • Carrying out your instructions; managing our relationship; maintaining records and documentation.

Risk, Compliance & Operations

  • Preventing, detecting and investigating crime (including fraud, money-laundering, terrorist financing), sanctions screening; analysing and managing commercial risks.
  • Internal management reviews, audits, surveillance, investigations; compliance with laws, regulations, codes, guidelines and law-enforcement requests (in Singapore and relevant jurisdictions).
  • Business continuity, IT and network security; monitoring use of tools/facilities to ensure operations function in a secure, efficient and effective manner.
  • Preparing internal/external reports; responding to claims, actions or proceedings; obtaining legal advice; enforcing contractual/legal rights.

Business Management & Transactions

  • Facilitating business asset transactions (including mergers, acquisitions, restructurings or asset/debt sales).
  • Matching/combining data for accuracy and for the Purposes herein; market research, profiling and statistical analysis to review, develop and improve our products/services and customer experience.

Communications & Marketing (where permitted)

  • Contacting you on account matters, policy/terms changes and administrative information.
  • Requesting feedback/surveys; organising promotional events.
  • Providing/marketing products, services and benefits (including via joint marketing and cross-promotions with partners), personalising content/experiences, and recommending relevant offerings.
  • Do Not Call (DNC): If you have provided Singapore telephone number(s) and consented to marketing via such number(s), we may contact you (voice, text, fax or other means) with information about our products/services and offers.

Employment/Contracting

  • For candidates/contractors: interviews, pre-hire checks, reference checks, suitability assessments.
  • For directors/employees/temps/interns/trainees: HR administration (benefits, payroll/expense claims, leave, training and development), investigations of defaults/compliance issues, providing work tools/facilities and monitoring their use, internal directories/emergency contacts, travel and logistics, risk management and policy compliance.

Third-Party Personal Data You Provide

  • Reviewing onboarding/transaction forms; due diligence; fraud detection and prevention; facilitating your requests or for other authorised purposes.

Additional Purposes (where permitted by law)

  • Matching personal data with other data (including third-party sources) to customise offerings/experiences.
  • Administering contests/competitions and personalising touchpoints.
  • Data analytics/monetisation with business partners only where permitted by law and subject to appropriate safeguards.

The above Purposes may continue to apply for a reasonable period even after your relationship with us ends (e.g., to enforce our rights or meet legal obligations).

Legal Bases, Legitimate Interests & Deemed Consent

In addition to consent:

  • We may handle personal data without consent where permitted by law, including for legitimate interests (not for direct marketing unless separately consented), such as:
    (a) evaluative purposes; (b) investigations/proceedings; (c) obtaining legal services; (d) fraud detection/prevention;
    (e) entering into/managing/terminating an employment relationship; (f) detecting misuse of services;
    (g) IT/network security and safety; (h) enhancing AML/financial crime risk management.
  • Deemed consent may apply: (i) where you voluntarily provide personal data for identified purposes; and/or (ii) where collection/use/disclosure is reasonably necessary for concluding or performing a contract with you (or with another organisation at your request).

Cookies, Connection & Usage Data

When you visit our website, our servers may record connection data (e.g., IP address, browser/user-agent) for security, diagnostics and statistical analysis. We use cookies and similar technologies to improve services, understand site usage, and remember your investor-type confirmation for subsequent visits. You may adjust browser settings to block cookies; however, some site functions may not work properly.

Sharing Personal Data with Third Parties

We do not disclose your personal information to third parties, except as described in this Notice. We will not sell your personal information.

Third party disclosures may include sharing such information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to us. These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that we dictate.

We may also disclose your personal information to fulfil your instructions or pursuant to your express consent.

Finally, under limited circumstances, your personal data may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to proceedings of a court of law or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

Cross-Border Transfers

Your personal data may be transferred to, stored or processed in jurisdictions outside Singapore. We will ensure such transfers comply with the PDPA’s requirements (including comparable protection standards or appropriate safeguards).

Security

We will take reasonable measures to ensure the security of your personal information. In particular we take steps to protect against unauthorised access to, alteration of or disclosure of your personal information. The steps we take to protect the security of your personal information include the putting in place of industry standard firewalls and password protection systems.

However, no method of transmission or 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.

We cannot guarantee that no harmful code (e.g., viruses, malware) will enter our website. Please take precautions (e.g., strong passwords, secure browsers) and be aware of internet risks.

Accuracy

We generally rely on personal data provided by you (or your authorised representative). Please keep your data current, complete and accurate by notifying us of any changes (see Contact/DPO).

Retention

We retain personal data only as long as necessary for the Purposes or as required/permitted by law. When retention is no longer needed, we will delete or anonymise the data within a reasonable period.

Your rights: Access & Correction

Subject to PDPA exceptions, you may:

  • Request access to personal data we hold about you and information on how it has been used/disclosed in the past year (a reasonable fee may apply; we will inform you of the fee before processing); and
  • Request correction/update of inaccurate or incomplete personal data.
  • We generally aim to respond within 30 days. If we need more time, we will inform you in writing of the expected timeframe. If we cannot provide/access or make a requested correction, we will generally tell you why (unless we are not required to do so under PDPA)

Withdrawal of Consent

Your consent remains valid until withdrawn in writing. Upon receiving your request, we will inform you of the likely consequences and process it within a reasonable time (generally within 10 business days, depending on complexity).
Please note that withdrawing consent may affect our ability to provide products/services or continue our relationship and may result in termination of agreements; our legal rights and remedies are reserved. Withdrawal does not affect our rights to continue handling personal data without consent where permitted or required by law.

Third-Party Websites

Our websites may contain links to third-party sites. We are not responsible for the privacy practices of such sites. Please review their privacy policies to understand how they handle your data.

Effect of Notice & Changes

This Notice applies together with any other applicable notices, contractual and consent clauses. It supplements (and does not replace) prior consents you have provided; consents are cumulative with our rights at law.
We may update this Notice from time to time. You can determine if changes have been made by referring to the “Last updated” date. Where required by law, we will notify you via appropriate means (e.g., posting on our website, email).

Consent to this Privacy Notice

By using our website, submitting forms, engaging with us, or purchasing/using our products or services, you consent to our collection, use and disclosure of personal data as described in this Notice.

Governing Law

This Notice and your use of our website are governed by the laws of Singapore.

Contact / Data Protection Officer (DPO)

Acceptance

By clicking “Accept”, you have acknowledged that you have read, understood, and agreed to the Terms and Conditions under the Privacy Policy & PDPA.

*This website has not been reviewed by the Monetary Authority of Singapore. These terms are governed by the laws of Singapore.

If you have any request (access, correction, withdrawal), question or feedback regarding your personal data or this Notice, please contact our Data Protection Officer:

Data Protection Officer
Crosspoint Capital Asia Pte. Ltd.
Level 37 Ocean Financial Centre
10 Collyer Quay
Singapore 049315
Tel: +65 6808 6668

3. EMAIL DISCLAIMER CONFIDENTIALITY AND PROFESSIONAL PRIVILEGE NOTICE

    This email may contain privileged and/or confidential information. If you are not the intended recipient (or responsible for delivery of the message to such person) or if you have inadvertently received this email, please immediately notify the sender by replying to this e-mail and delete this message from your system as well as destroy any paper copies made. No waiver of confidentiality or privilege is made by mis-transmission.

    If the reader of this message is not the intended recipient, you are hereby notified that any unauthorized dissemination, distribution, reading, printing, copying and/or use of this communication is strictly prohibited.

    If you or your employer do not consent to using Internet email for messages of this kind, please advise immediately by sending an email to the sender of this message. All opinions, conclusions and other information in this message that do not relate to the official business of the legal entity identified in the signature line of this message (“we” or “Crosspoint Capital Asia Pte Ltd” or “CCA”) shall be understood as neither given nor endorsed by CCA.

    We accept no liability for the content of this email, or for the consequences of any actions taken on the basis of the information provided, unless that information is subsequently confirmed in writing.

    WARNING: Computer viruses can be transmitted via email, and you should check this email and any attachments for the presence of viruses. We accept no liability for any damage caused by any virus transmitted by this email. We expressly prohibit all our partners and employees from making defamatory statements infringing copyright and/or infringing any other legal right via any communications. Any such communication will be contrary to our policies, and outside the scope of the employment of the said individual. We will not be liable for any such communications.

    Acceptance

    By clicking “Accept”, you have acknowledged that you have read, understood, and agreed to the Terms and Conditions under the Email Disclaimer, Confidentiality and Professional Privilege Notice.

    *This website has not been reviewed by the Monetary Authority of Singapore. These terms are governed by the laws of Singapore.