Your privacy is important to us. The purpose of this privacy statement (the "Data Protection Policy") is to inform you of how the Fund and the Investment Manager (collectively, the “Fund Parties”) manages the confidential information we hold. Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your confidential information.

By executing the Subscription Agreement, interacting with us, submitting information to us, or entering into an agreement with each of the Fund Parties to provide you any products or services, you agree and consent to each of the Fund Parties collecting, using, disclosing and sharing amongst themselves your Confidential Information, and disclosing such Confidential Information to each of the Fund Parties’ authorized service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consent you may have previously provided to the Fund Parties nor does it affect any rights we may have at law in connection with the collection, use or disclosure of your Confidential Information.

Each of the Fund Parties may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time.

1.Definitions

In this Data Protection Policy, unless the context otherwise requires, the following terms shall have the meanings assigned to them below:

"Confidential Information" refers to all information relating to: (i) you or your related parties (including without limitation, your connected persons, authorised persons and beneficial owners); (ii) your investments in the Fund (including any subscription, redemption, holding or dealing in/with the Fund); (iii) your dealings with the Fund, the Investment Manager and/or the Administrator (including any of their principals, members, managers, officers, directors, shareholders, employees and agents); (iv) any other information of a confidential nature; and (v) any personal data as defined in the PDPA belonging to you or any related parties (including without limitation, your connected persons, authorised persons and beneficial owners) (“Personal Data”).

“PDPA” means the Personal Data Protection Act 2012 of Singapore.

2.Collection of Confidential Information

Generally, we collect and process Confidential Information about you through a variety of channels, including in your subscription documentation, as well as through ongoing communications by mail, email or telephone:

a）Information that you provide to us or one of our affiliates. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise (which may be monitored or recorded). This information may include (but is not limited to) your name, address, social security number or company registration number, birth date or incorporation date, assets, financials, income and investment experience of you and/or your representatives.
b）Information we collect or generate about you. This may include (but is not limited to) information that we collect about you and/or your representatives in the course of performing services for you, such as information about client or investor transactions (e.g., account activity and balances).
c）Information we obtain from other sources. This may include (but is not limited to) information from our affiliates and our service providers, where you have provided (or your delegate or agent has provided on your behalf) such information to them, and information from other sources such as credit reporting agencies.

3.Purposes for the Collection, Use and Disclosure of Your Confidential Information

a）Generally, each of the Fund Parties collects, uses and discloses your Confidential Information for complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
b）You should ensure that all Confidential Information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in delays in the processing of your application, or our inability to process your application.
c）In addition, to the extent applicable, each of the Fund Parties also collects, uses and discloses your Confidential Information for the following purposes:
1. i）evaluating and assessing your application or redemption requests;
2. ii）processing your subscription and investment in the Fund or redemption;
3. iii）verifying the identity(ies) of you or your related parties (including without limitation your connected persons, authorised persons and beneficial owners) for the purpose of anti-money laundering checks, anti-tax evasion and/or anti-terrorism checks and conducting screening against applicable sanctions, politically exposed persons and other relevant database;
4. iv）completing information on the Register of Members of the Fund or any other records or books;
5. v）carrying out your instructions or responding to any enquiry purporting to be given by you or on your behalf, or other client servicing purposes;
6. vi）dealing in any other matters relating to your holding of Shares (including the mailing of reports or notices) or any other interest in the Fund;
7. vii）implementing, operating, managing and/or administering the Fund and any related investments on an ongoing basis;
8. viii）providing services to the Fund;
9. ix）forming part of the records of the business carried on by you;
10. x）providing a marketing database for product and market research or to provide information for the dispatch of information on other products or services to us from the Investment Manager or any connected persons of the Investment Manager; and
11. xi）observing any other legal, governmental or regulatory requirements of any relevant jurisdiction (including any disclosure or notification requirements to which any recipient of the data is subject).
d）Your Confidential Information will generally be disclosed to the following persons:
1. i）each of the Fund, the Investment Manager and the Administrator;
2. ii）each of the respective employees, officers, directors and agents of the persons listed in sub-paragraph (i);
3. iii）each of the respective subsidiaries, holding companies and other affiliates of the persons listed in sub-paragraph (i);
4. iv）each of the respective delegates, service provider or third parties of the persons listed in sub-paragraph (i) engaged to provide services, directly or indirectly, to the persons listed in sub-paragraph (i) or to the Fund (including but not limited to any auditors, prime brokers, brokers, banks, custodians, sub-custodians or other institutions);
5. v）each of the respective auditors and/or professional advisers of the persons listed in sub-paragraph (i);
6. vi）any person to whom the Fund, the Investment Manager and /or the Administrator assigns, transfers or delegates its rights or obligations to; and
7. vii）any other persons (including any tax or regulatory authorities).

4.Security Measures

Each of the Fund Parties protects your Confidential Information by making reasonable arrangements (including, where appropriate, physical, administrative, procedural and information & communications technology measures) to prevent: (a) unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of Confidential Information, or other similar risks; and (b) the loss of any storage medium or device on which personal data is stored.

Each of the Fund Parties only permits authorized personnel to access your Confidential Information on a need to know basis.

5.Retention of Confidential Information

Each of the Fund Parties does not retain Confidential Information for a period of time longer than is necessary. Upon a written request, Confidential Information will be returned, and all physical, electronic copies deleted, and, after returning or deleting all data provide confirmation that it no longer possess any Confidential Information, save to the extent that we are required to retain any such information by an applicable law, rule or regulation. Where applicable, each of the Fund Parties will also instruct third parties to whom it has disclosed Confidential Information to return or delete such Confidential Information.

6.Notification of Breach

Each of the Fund Parties will immediately notify you when it becomes aware of a breach of any of its obligations, except where such disclosure is made to any governmental, banking, taxation or other regulatory authority or similar body.

Getting In Touch

Should you have any queries or wish to discuss your data protection rights with us, please contact us at aams@amicorp.com.