DATA PRIVACY NOTICE

This Data Privacy Notice was last updated on 1 October 2019.

1. Introduction
   About Affirma Capital
   1. This Data Privacy Notice is provided by Affirma Capital Limited and its affiliates (collectively, “Affirma Capital” or the “Group”). Affirma Capital comprises different legal entities. More information can be found here: (http://www.affirmacapital.com/about.html). This Data Privacy Notice is issued on behalf of Affirma Capital so, references to "Affirma Capital", "we", "our" or "us" in this Data Privacy Notice refer to the relevant entity in Affirma Capital responsible for processing your Personal Data (as defined below).
   Data Privacy Notice
   2. The purpose of this Data Privacy Notice is to provide you with information on how Affirma Capital as well as persons engaged by Affirma Capital manage Personal Data in accordance with the Personal Data Protection Act 2012 of Singapore as amended from time to time and any other applicable data protection laws (collectively, “Data Protection Legislation”). Depending on the jurisdiction in which Personal Data is being collected, used, disclosed or processed by Affirma Capital, jurisdiction-specific provisions set out in this notice may apply.
   3. This Data Privacy Notice applies to:

      (a)individuals associated with investors of funds managed by Affirma Capital and potential investors of funds managed by Affirma Capital with whom Affirma Capital has had contact;

      (b)individuals with whom Affirma Capital has had contact for business purposes, either on its own account or on behalf of third parties or organisations;

      (c)individuals who are employees or prospective employees of Affirma Capital;

      (d)individuals associated with Affirma Capital's suppliers, vendors or professional advisors;

      (e)individuals involved in transactions or potential transactions, that are conducted or evaluated by Affirma Capital or Affirma Capital's advisors; and

      (f)individuals who have opted to receive communications from Affirma Capital.
   4. Personal Data collected through Affirma Capital's websites, intranet or portals, as well as information that is collected through other means, about people who contact us, including vendors, investors and employees, will be processed by Affirma Capital and persons engaged by Affirma Capital. We do not knowingly collect data relating to minors and our websites, intranet and portals are not intended for minors.
   5. Subject to the applicable laws, by interacting with Affirma Capital, including via electronic communication or telecommunications, accessing and using Affirma Capital's websites, intranet or portals or submitting information to Affirma Capital, you agree and consent to the collection, use, disclosure and processing of Personal Data by Affirma Capital and persons engaged by Affirma Capital in accordance with the terms set forth in this Data Privacy Notice, as updated from time to time on this website link: http://www.affirmacapital.com/privacy.html.
   If you do not agree to this Data Privacy Notice, please do not access or use Affirma Capital's websites, intranet or portals or provide Personal Data to Affirma Capital.
2. About Affirma Capital & Data Protection Principles
   Data Protection Principles
   1. We will use Personal Data in accordance with the following principles and in compliance with applicable data protection laws:

      (a)lawfully, fairly and in a transparent manner;

      (b)collecting Personal Data only for purposes that are valid, compatible and relevant to the reason for which you have a relationship with Affirma Capital;

      (c)in an accurate manner and based on the latest up to date Personal Data made available to us; and

      (d)kept securely and only as long as necessary for our purposes.
3. Collection of Personal Data
   Definition of Personal Data
   1. In this Data Privacy Notice, “Personal Data” shall mean the following:

      (a)any information that identifies or could be used to identify an individual (“Personal Information”); and

      (b)information other than Personal Information submitted by you to Affirma Capital via Affirma Capital's websites, intranet, portals or infrastructure which in itself cannot identify an individual, but can be combined with other information to identify an individual.
   2. Personal Data does not include data where identifiers have been removed i.e. anonymous or aggregated data.
   3. For the purposes of Personal Data being collected, used, disclosed or processed by Affirma Capital in India, references to "Personal Data" in this Data Privacy Notice shall be read to mean Sensitive Personal Data or Information (“SPDI”) .
   Collection of Personal Data
   4. Generally, Affirma Capital collects Personal Data in the following ways:

      (a) when you browse Affirma Capital's websites, intranet or portals;

      (b) when you visit our offices or premises for various business purposes, including for meetings and events organised by Affirma Capital;

      (c) when you have contact with Affirma Capital for business purposes, including through emailing or meeting a representative of Affirma Capital;

      (d) when you or your representative submits forms or applications to Affirma Capital, including resumes and/or CVs;

      (e) when you are a supplier or vendor to Affirma Capital; or if you are a professional adviser engaged by Affirma Capital;

      (f) when you are an individual involved in transactions or potential transactions relating to Affirma Capital's business, including any investor or potential investor in our investment products;

      (g) when we need your Personal Data in order to perform our obligations under a contract that we are about to enter into, or have entered into, with you;

      (h) when you are employed or engaged by Affirma Capital;

      (i) when you contact us, submit queries or feedback to Affirma Capital, request to be included in Affirma Capital's mailing list or submit Personal Data to Affirma Capital for any other reason; and/or

      (j) when it is necessary for our legitimate interests or where we need to comply with a legal or regulatory obligation.
   5. You represent and warrant that all Personal Data submitted to Affirma Capital by you is true, complete and accurate. If you provide Affirma Capital with Personal Data relating to a third party (e.g. personal information of your immediate family members), by submitting such information to Affirma Capital, you represent and warrant to Affirma Capital that:

      (a) such third parties have read and understood this Data Privacy Notice; and

      (b) you have obtained the requisite consent of such third party and/or are authorised to provide Affirma Capital with such Personal Data by such third party.
   6. For the purposes of Personal Data being collected, used, disclosed or processed by Affirma Capital in South Korea, at the time of the collection or processing of your Personal Data, Affirma Capital will indicate which types of Personal Data are mandatory and which types are optional, as well as the potential effects on you if you do not wish to provide us with Personal Data.
   7. Affirma Capital may combine information that we collect from you and about you with information that we obtain about you from our affiliates, vendors and other third parties, and use such combined information in accordance with our Data Privacy Notice.
   8. Affirma Capital may aggregate and/or anonymise information that Affirma Capital collects; and use such aggregated and/or de-identified information for any purpose, including for research and marketing purposes; and may share such anonymised data with third parties.
   9. If you fail to provide certain information when requested by Affirma Capital, Affirma Capital may not be able to deal with you or fulfil our contractual obligations with you.
   Special Categories: Sensitive Personal Data
   10. Affirma Capital recognises that certain categories of Personal Data are more sensitive (“Sensitive Personal Data”), including (i) sensitive information (such as health information, race, religious beliefs, political opinions, sexual orientation and ideology); and (ii) unique identification information (such as resident registration numbers, passport numbers and foreign registration numbers).
   11. Generally, to the extent possible, Affirma Capital does not usually collect Sensitive Personal Data unless:

       (a)

       there are clear reasons for doing so, such as any dietary requirements when attending a dinner, or to ensure that appropriate facilities are available for you to attend an event;

       (b)

       specifically permitted under law; or

       (c)

       explicitly required to protect the life, physical safety or proprietary interest of an individual.
   Additional Consent
   12. In certain instances, Affirma Capital may rely on obtaining your consent to our use of your Personal Data. Affirma Capital collects, uses and processes Personal Data for the purposes stated in the Data Privacy Notice. If the purposes are modified, Affirma Capital will take the necessary measures to obtain separate consents.
4. Purpose of Collecting, Using, Disclosing and Processing Personal Data
   Lawful Basis for collecting Personal Data
   1. The laws in certain jurisdictions require Affirma Capital to tell you about the legal grounds that they rely on to collect, use, share or disclose Personal Data. To the extent such laws apply, Affirma Capital's legitimate grounds are broadly as follows:

      (a)responding to your queries, requests or feedback to Affirma Capital and providing you with access and/or use of Affirma Capital's infrastructure, including its websites, intranet, portals and systems;

      (b)interacting with investors or potential investors to facilitate investments into Affirma Capital;

      (c)facilitating investments, business transactions and business agreements by Affirma Capital with counterparties;

      (d)conducting data analytics, audits, reviews and analysis for the purpose of managing risk and fraud; improving systems and processes; managing regulatory and compliance risks; enhancing human resources processes; investment insights; and managing the internal processes of Affirma Capital;

      (e)fulfilling, protecting and enforcing Affirma Capital’s legal, contractual or regulatory obligations, including complying with any applicable laws, regulations, rules, codes, directives or guidelines, to assist in law enforcement and investigations by the relevant authorities, dispute resolution or fulfilling contractual obligations pursuant to which Affirma Capital is a contractual party;

      (f)internal corporate governance policies including fraud and crimes, managing commercial risks and operational risks arising from Affirma Capital’s activities;

      (g)conducting anti-money laundering and counter-terrorism due diligence and such other due diligence checks that are required to comply with our internal compliance framework and risk management framework; and

      (h)where such collection, use, processing and/or disclosure of Personal Data is necessary for our legitimate interests in operating our business.
   Purpose of collecting Personal Data
   2. Affirma Capital may also collect, use, disclose and/or process Personal Data for the following purposes, depending on the nature of our relationship with you:

      Relationship	Purpose(s)
      Investors or Potential Investors	• maintain a directory of contacts • send updates, information and notices or otherwise corresponding with you in connection with your investment(s) in Affirma Capital • provide you with, and inform you about, investment products and services; manage our risk and operations • organise meeting with investors and potential investors • assess and process requests you make • perform conflict checks, including investor due diligence • perform contracts, including administering or managing of Affirma Capital, processing the subscription and investment into funds managed by Affirma Capital • facilitate the continuation or termination of the contractual relationship between investors and Affirma Capital • facilitate business asset transactions involving Affirma Capital or related entities • facilitate the transfer of funds, and administering and facilitating any other transaction, between investors and Affirma Capital • maintain statutory registers • enter information in the register of partnership interests; send each investor statements relating to such investor’s investment(s) • facilitate the payment of dividends and/or other distributions • protect the security and integrity of our IT systems • billing and invoicing purposes • facilitate advice from our professional advisors, including accountants, lawyers and other consultants • send to third party service providers or professional advisors to process information on Affirma Capital's behalf • general business purposes, including statistical analysis and market research • inform parties of changes to Affirma Capital’s policies, terms and conditions and other administrative information • investigate any complaints, or pursue or defend any claims, proceedings or disputes • prevent and detect fraud • comply with audit requirements; ensure internal compliance with our policies and procedures • protect Affirma Capital against fraud, breach of confidence or theft of proprietary materials • anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners) • sanctions screening and complying with applicable sanctions and embargo legislation • comply with requests from regulatory, governmental, tax and law enforcement authorities; surveillance and investigation activities • comply with legal, tax, accounting or regulatory obligations to which we or the third party are subject • monitor communications to/from us (where permitted by law)
      Investment and Transaction Counterparties	• maintain profiles of counterparties in Affirma Capital's system database • send periodic updates about Affirma Capital's business, events, presentations and opportunities • market our investment products • organise meetings with transaction counterparties • perform conflict checks, undertaking due diligence and performing background checks • verify and process personal particulars to maintain accurate records • inform parties of changes to Affirma Capital’s policies, terms and conditions and other administrative information • evaluate potential transactions and maintain records of investments • perform contractual obligations with such counterparties • administer transactions which are entered into • trades and transaction reporting • business development and promotion • facilitate advice from our professional advisors, including accountants, lawyers and other consultants • send to third party service providers or professional advisors to process information on Affirma Capital's behalf • general business purposes, including statistical analysis and market research • send to applicable or other governmental agencies for compliance purposes • billing and invoicing purposes • safeguard legal rights and interests • anti-money laundering and counter-terrorism financing checks in compliance with our internal risk management framework • monitor communications to/from us (where permitted by law)
      Employees or Job Applicants	• verify and process personal particulars, evaluate the qualification and suitability for employment with Affirma Capital and assess the job applicant's financial status • communicate and inform the employee or job applicant of changes to Affirma Capital’s policies, terms and conditions and other information • send updates to the employee or job applicant • conduct market research for statistical analysis and profiling for the improvement of services • monitor communications to/from us (where permitted by law)
      External Service Providers or Vendors	• verify and process personal particulars and assess suitability as an external service provider or vendor for Affirma Capital as well as assess its financial status • inform the external service provider or vendor of changes to Affirma Capital’s policies, terms and conditions and other information • maintain profiles of our investment counterparties in Affirma Capital's system database • conduct anti-money laundering and counter-terrorism due diligence and run checks in compliance with our internal risk management framework • administer and maintain records of goods, services or advice that we have received • commission further services or procure further goods • monitor communications to/from us (where permitted by law)
      Visitor of our website or offices; or attendees of events organised by Affirma Capital	• maintain a directory of contacts • contact information for security reasons or emergency purposes • health information for first aid accident book • collect information for names and dietary preferences for the purposes of catering • collect, use, disclose and transfer photos and videos featuring such attendee for publicity purposes by Affirma Capital • respond to queries from visitors and event attendees • maintain profiles of our visitors and event attendees in Affirma Capital's system database • monitor communications to/from us (where permitted by law)

5. Sharing, Disclosure and/or Transfer of Personal Data
   Sharing of Personal Data
   1. Affirma Capital may share Personal Data with affiliates and delegates of Affirma Capital where we believe it is necessary or consistent with our legitimate interests.
   2. Affirma Capital’s affiliates and delegates may process Personal Data on Affirma Capital's behalf, including with Affirma Capital's banks, accountants, auditors and lawyers which may be data controllers in their own right. Affirma Capital's services providers, such as administrators, are generally processors acting on the instructions of Affirma Capital.
   3. Additionally, a service provider may use Personal Data where it is necessary for compliance with a legal obligation to which it is directly subject (for example, to comply with applicable law in the area of anti-money laundering and counter terrorist financing or where mandated by a court order or regulatory sanction). The service provider, in respect of this specific use of personal data, acts as a data controller.
   4. In certain circumstances, Affirma Capital may be legally obliged to share Personal Data with respect to your interest in Affirma Capital with relevant regulatory authorities, government agencies or departments, which, in turn, may exchange this information with foreign authorities, including tax authorities and other applicable regulatory authorities.
   Disclosure of Personal Data
   5. Subject to the applicable laws, Personal Data may be disclosed to any member of Affirma Capital or to third parties such as service providers and professional advisors, including the following parties for the purposes listed above:

      (a) other entities within Affirma Capital;

      (b) professional advisers of Affirma Capital such as lawyers, accountants, consultants and auditors appointed by Affirma Capital;

      (c) administrative agents, custodians, registrars, agents, contractors, insurance companies, insurance brokers or third party service providers who provide services to Affirma Capital, such as courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support, investigation services, recruiting, insurance services, corporate secretarial or other services to Affirma Capital;

      (d) any actual or potential business partner, investor, assignee or transferee to facilitate transactions;

      (e) local and foreign government agencies, regulatory bodies, statutory boards, tax authorities, recognised stock exchanges, listing authorities, or other authorities and/or law enforcement agencies to comply with any laws, regulations, rules, directions, codes of practice or guidelines, or schemes issued or administered by any of them;

      (f) in order to comply with a judicial proceeding, court order or other legal obligation, or a regulatory or government enquiry;

      (g) other organisations, banks and financial institutions which may reasonably request that Affirma Capital provide them with Personal Data;

      (h) in order to enforce or apply terms of engagement and other agreement or otherwise protect and defend Affirma Capital’s rights, property or safety;

      (i) partners in relation to events planning, including charity events organised or co-organised by Affirma Capital;

      (j) in connection with a reorganisation or combination of Affirma Capital with another organisation; and/or

      (k) any other party to whom you authorise Affirma Capital to disclose Personal Data
   6. In certain jurisdictions, Affirma Capital has a legal obligation to report suspicious transactions or other activity to relevant authorities under anti-money laundering regulations, counter-terrorist financing, insider dealing or related legislation. Under these circumstances, Affirma Capital is not always permitted by the relevant laws to inform you in advance of such disclosure, or at all.
   Transfer of Personal Data Internationally
   7. Due to the international nature of Affirma Capital's business, Personal Data may be transferred to jurisdictions that may not offer equivalent protection of personal data as under the Data Protection Legislation.
   8. In such cases, Affirma Capital will process Personal Data or procure that Personal Data be processed in accordance with the requirements of the Data Protection Legislation. This may include having appropriate contractual undertakings in legal agreements with service providers who process personal data on our behalf.
   9. Our servers are currently based in Singapore and Hong Kong. Personal Data will be stored and used by Affirma Capital on servers located in Singapore and Hong Kong and systems of relevant Affirma Capital members in other jurisdictions around the world.
   10. Personal Data may also be processed by staff or service providers of Affirma Capital who process Personal Data on our behalf and who may be located around the world.

       Jurisdiction	Transfer of Personal Data Internationally
       India	Affirma Capital may transfer your SPDI to any person or entity whether in India or located in any other country that ensures a similar level of data protection as provided in the RSP Rules when the same is necessary for the performance of a lawful contract with you or where you have consented to such transfer. The SPDI transferred would include such information provided to Affirma Capital either directly by you (the information provider) or by any legal entity with whom you (the information provider) are associated in any capacity. You acknowledge that some countries to which we may transfer your SPDI may not have data protection laws which are as stringent as the data protection laws of India. You acknowledge and agree that it is adequate that when we transfer your Personal Data to any other entity overseas, we will put in place contractual obligations on the transferee which will oblige the transferee to adhere to the same levels of data protection as those adopted by us.
       EU	Affirma Capital may transfer your Personal Data into and outside the European Economic Area and when we do, you can expect a similar degree of protection in respect of your Personal Data as set out in this Data Privacy Notice.

   11. By submitting Personal Data, you agree to the foregoing transfer, disclosure, sharing, storage or processing of such Personal Data. Affirma Capital shall take all steps reasonably necessary to ensure that Personal Data is treated securely and shall procure that the Personal Data transferred is afforded the level of protection that is required under the Data Protection Legislation. Please contact the data protection officer, where applicable, if you require further information about the adequacy measures and mechanisms implemented.
   Data Controller
   12. For the purposes of the Data Protection Legislation, the Affirma Capital company with which you have dealings is the controller of your Personal Data (Data Controller). The Data Controller is responsible for deciding how we hold and use your Personal Data. If you have any questions regarding our use of your Personal Data or this Data Privacy Notice, please submit your queries to our data protection officer at [email protected].
   13. Affirma Capital continues to be a data controller even though it may have engaged an administrator and other third parties to perform certain activities on Affirma Capital's behalf.
   Retention of Personal Data
   14. Affirma Capital retains Personal Data for as long as reasonably necessary for the satisfaction of the purposes for which it was collected; or to which you have given consent except otherwise provided by law.
   15. Affirma Capital will destroy Personal Data without delay when it becomes apparent that it is no longer necessary to retain such Personal Data due to the expiration of the period of retention or achievement of the purposes for collecting, using, disclosing and processing Personal Data.
   16. Notwithstanding the above, in certain circumstances, Personal Data will be retained if this is required by any laws and regulations. For example, in respect of investors, Affirma Capital will generally retain Personal Data throughout the lifecycle of the investment in which you are involved. Information may also persist in copies made for backup and business continuity purposes for an additional period of time.
6. Privacy Rights: Feedback, Withdrawal of Consent or Correction of Personal Data
   Privacy Rights
   1. You have certain privacy rights, including the right to:

      (a) be informed about the purposes for which your personal data are processed;

      (b) be informed of a personal data breach (unless such breach is unlikely to be prejudicial to you);

      (c) access your personal data;

      (d) restrict the processing of your personal data;

      (e) ask us to stop processing your personal data;

      (f) stop direct marketing;

      (g) have incomplete or inaccurate personal data corrected;

      (h) issue a complaint to the data protection officers or the respective supervisory authority;

      (i) require us to delete your personal data in some limited circumstances; and

      (j) upon written request, request copies of the personal data that Affirma Capital has collected in relation to you.

      You have the right to make a complaint at any time to the relevant data protection authority. We would, however, appreciate the chance to deal with your concerns before you approach the data protection authority
   Contact Information
   2. In the event that you wish to exercise any of the foregoing rights, please contact our data protection officer at:

      Email: [email protected]

      Contact number: +65 6500 7920
   3. Other than the general contact information set out above, please find set out below jurisdiction specific contact officers:

      Jurisdiction	Transfer of Personal Data Internationally
      India	In addition to the rights granted to you in this Data Privacy Notice, if you would like to obtain access to review your Personal Data, please contact the Grievance Officer at the contact details set out below. We have appointed a Grievance Officer to address any concerns or grievances that you may have regarding any use of your Personal Data. If you have any such grievances, please write to our Grievance Officer at: [email protected].
      EU	The designated contact entity in relation to Affirma Capital matters in the European Union and the European Economic Area is [email protected].
      South Korea	Affirma Capital has appointed an individual as the Personal Information Protection Manager to oversee responsibility for matters relating to the handling of personal information as well as the handling of complaints from providers of personal information. For matters relating to Affirma Capital in Korea, Korean residents or activities taking place within the territory of Korea, please contact: [email protected].

   4. If you elect to withdraw your consent to the collection, usage, sharing and/or disclosure of any or all of your Personal Data, please note that depending on the nature of your request, this may affect certain contractual arrangements between you and Affirma Capital. Affirma Capital’s legal rights and remedies in such event are expressly reserved.
   5. Affirma Capital may refuse the request for suspension of processing of Personal Data made by an individual if:

      (a) there is a special provision in law or if denying the request is necessary to comply with legal obligations;

      (b) such an act is likely to inflict damages or harm upon another person's life or body or unfairly infringe upon another person's property and other rights; or

      (c) performing the contract becomes impracticable unless the Personal Data is processed and the individuals have not expressed a clear intention to terminate such contract.;
7. Data Security, Breach Notification and Report
   Data Security
   1. Affirma Capital has implemented administrative, technical and physical security measures and safeguards to protect against the loss, misuse and/or alteration of Personal Data – which vary based on the sensitivity of the information that we collect and store. Third parties only process Personal Data where they are obliged to treat the information confidentially and to keep it secure.
   2. Notwithstanding the above, Affirma Capital cannot guarantee that these measures will prevent every unauthorised attempt to collect, access, use, share or disclose Personal Data as no electronic transmission or infrastructure can be absolutely secure.
   Breach Notification and Report
   3. All employees, contractors, partners and providers involved in the processing of Personal Data work together to report any signs of possible data breach or security incident.
   4. In the event that such signs are discovered, the facts and circumstances are to be reported to the data protection officer within 24 hours from its discovery, for verification as to whether a breach had occurred. The data protection officer will also determine if this requires notification under the Data Protection Legislation as well as a determination of the relevant circumstances surrounding the reported breach and/or security incident.
   5. For a breach requiring notification, the data protection officer will, within 72 hours upon receipt of facts or circumstances (or such earlier timing as may be required under the applicable laws), notify the relevant data protection commission and affected data subjects following the procedures prescribed by the applicable laws.
   6. All security incidents and personal data breaches will be documented through written reports, including those not covered by the notification requirements and a summary of the reports shall be submitted by the data protection officers including the facts surrounding the incident and the remedial actions taken to address the data breach.
   7. To monitor compliance with data protection and to identify areas for improvement in response to inquiries and/or complaints regarding Personal Data, the following will be observed:

      (a)regularly test and verify management of Personal Data;

      (b)monitor corrections or improvements to deficiencies in control or policies to verify that compliance findings are addressed in a timely manner;

      (c)handle privacy concerns, issues or complaints reported by data subjects in a timely manner; and

      (d)train all employees to recognise and report potential privacy events and provide awareness on the importance of reporting any possible privacy event in a timely manner.
8. General
   1. To the extent that you have provided any other consents to Affirma Capital in respect of the Personal Data, this Data Privacy Notice supplements but does not supersede nor replace such consents. Consents provided herein are in addition to any rights which any member of Affirma Capital may have at law or contract or in equity to collect, use, disclose or process Personal Data.
   2. Affirma Capital will continue to evaluate the Data Privacy Notice and may, from time to time, update or amend this Data Privacy Notice. All changes will be posted on the following website link: http://www.affirmacapital.com/privacy.html.