Privacy Policy
1. Introduction
Hundred Autumns Pte Ltd (“The Company”, “Hundred Autumns Capital”, "we", "us" or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose and protect personal data when you visit our website at [website address], contact us, or otherwise deal with us. It is written in accordance with the Personal Data Protection Act 2012 of Singapore (the "PDPA").
By using our website or providing personal data to us, you agree to the collection, use and disclosure of your personal data as described in this Privacy Policy.
2. Personal data we collect
"Personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information we have or are likely to have access to.
We may collect the following personal data:
Contact information: your name, job title, organisation, email address, telephone number and correspondence address, when you contact us through the website, by email or in person.
Information you choose to share: any details you include in messages, enquiries, business plans, pitch materials or other documents you send to us.
Professional information: information about your professional background, where you are an investor, prospective investor, portfolio company, adviser or business contact.
Technical information: your IP address, browser type, device information, pages visited and time spent on the website, collected automatically through cookies and similar technologies.
We do not intentionally collect personal data from individuals under the age of 18.
3. How we collect personal data
We collect personal data when you submit information through our website, contact us by email, phone or other means, meet us or exchange business cards, or engage with us as an investor, business partner or service provider. We may also receive personal data from third parties such as introducers, professional advisers, or publicly available sources, where permitted by law.
4. Purposes for which we use personal data
We may collect, use and disclose your personal data for the following purposes:
responding to your enquiries and communicating with you;
evaluating potential investment opportunities, partnerships or business relationships;
managing our relationships with investors, portfolio companies, advisers and service providers;
carrying out due diligence, including know-your-customer (KYC), anti-money laundering and counter-terrorist financing checks, where applicable;
sending you information about [Company Name], where you have agreed to receive it;
operating, maintaining and improving our website;
complying with applicable laws, regulations, and requests from regulatory or government authorities; and
any other purpose that we notify you of at the time of collection, or that is otherwise permitted under the PDPA.
5. Consent and withdrawal of consent
Where required by law, we will obtain your consent before collecting, using or disclosing your personal data. You may withdraw your consent at any time by contacting our Data Protection Officer (see Section 12).
We will process your request within a reasonable time. Please note that, depending on the nature of your request, withdrawal of consent may mean we are unable to continue our relationship or respond to your enquiries. Withdrawing consent does not affect our right to continue using your personal data where this is permitted or required by law.
6. Disclosure of personal data
We do not sell your personal data. We may disclose your personal data to:
our affiliates, partners and personnel, on a need-to-know basis;
professional advisers such as lawyers, auditors and accountants;
service providers who support our operations, such as IT, hosting, fund administration and communications providers, who are bound to protect your data;
regulators, government bodies, courts or law enforcement agencies, where required or permitted by law; and
other parties with your consent.
7. Transfers outside Singapore
Our service providers, including our website hosting provider, may store or process personal data outside Singapore. Where we transfer personal data overseas, we will take appropriate steps to ensure that the recipient provides a standard of protection comparable to that required under the PDPA.
8. Protection of personal data
We take reasonable security measures to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification or disposal. These include access controls, secure systems and confidentiality obligations on our personnel and service providers. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
In the event of a data breach that is likely to result in significant harm to affected individuals, we will notify the Personal Data Protection Commission and affected individuals as required under the PDPA.
9. Retention of personal data
We retain personal data only for as long as it is needed for the purposes for which it was collected, or as required for legal, regulatory, accounting or business purposes. When personal data is no longer required, we will securely delete or anonymise it.
10. Accessing and correcting your personal data
You may request access to the personal data we hold about you and information about how it has been used or disclosed within the past year. You may also ask us to correct any error or omission in your personal data.
Please send requests to our Data Protection Officer (see Section 12). We will respond as soon as reasonably possible. If we are unable to respond within 30 days, we will tell you when we expect to be able to. A reasonable fee may be charged for access requests, and we will inform you of any fee in advance.
11. Cookies
Our website uses cookies and similar technologies to help it function properly and to understand how visitors use it. You can set your browser to refuse or delete cookies, although some parts of the website may not work as intended if you do.
Our website is hosted on Squarespace, which may use cookies for essential site functions and analytics. For more information, please see Squarespace's own privacy and cookie policies.
12. Contact us
If you have any questions about this Privacy Policy, or wish to make a request regarding your personal data, please contact our Data Protection Officer:
Data Protection Officer
[Company Name]
[Address], Singapore [postal code]
Email: [privacy@yourdomain.com]
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this page periodically