Privacy
Policy

Our Commitment to Your Privacy

Analog 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 safeguard personal information in compliance with Singapore’s Personal Data Protection Act (PDPA) and other applicable laws and regulations, including requirements under the Monetary Authority of Singapore (MAS) as a Licensed Fund Management Company (LFMC).

By accessing our website or engaging with our services, you agree to the practices described in this policy.

Information We Collect

We collect personal information necessary to operate our business, provide fund management and client services, comply with legal obligations, and communicate with you. This may include:

    • Identity information: name, date of birth, nationality, identification documents (e.g. NRIC, passport)

    • Contact details: email, phone number, postal address

    • Financial and investment information: account details, transaction history, investment preferences

    • Employment information: occupation, employer details, professional qualifications

    • Compliance and due diligence data: source of funds and wealth, politically exposed person (PEP) status, tax identification numbers

    • Transaction and communication records: subscription agreements, mandates, legal documentation, emails, and correspondence related to investments and client services

    • Payment and banking details

    • Marketing and event participation data: communication preferences, event registration, feedback

    • Technical information: IP address, browser type, device identifiers, cookies, and website usage data

We may collect this information directly from you, your representatives, service providers, public sources, and other parties involved in your investment or professional relationship with us.

Sensitive Information

Generally, we do not collect sensitive information unless required or permitted by law or with your consent. Sensitive information may include data about:

    • Race

    • Political or religious beliefs

    • Sexual orientation and sexual life

    • Criminal convictions

    • Membership of professional or trade associations or unions

    • Biometric and health information

We will not collect sensitive information where this is expressly prohibited by local law.

How We Use Your Information

We collect and process personal data based on your consent, to perform contractual obligations, comply with legal and regulatory requirements, or pursue legitimate interests where appropriate. We use your data to:

    • Manage and administer your investments and related services

    • Perform due diligence, compliance, risk management, and regulatory reporting

    • Communicate with you regarding your account, transactions, or other relevant matters

    • Conduct marketing and business development activities, where permitted by law and with your consent

    • Manage investor relations and client services

    • Improve our services, systems, and website functionality

    • Protect against fraud, financial crime, and unauthorised access

Sharing Your Information

We may disclose your personal information to:

    • Our affiliates, service providers, and professional advisors who assist us in providing services

    • Reputable third-party cloud service providers (e.g. AWS, Azure), acting as data processors and meeting strict security standards

    • Regulators, law enforcement, or other government authorities as required by law

    • Third parties involved in transactions, audits, or corporate reorganisations

    • Your nominated financial advisers, custodians, and brokers (with your permission)

    • Other financial institutions and organisations for fraud prevention, anti-money laundering, and payment processing

    • Other parties with your consent or as otherwise permitted by law

Where your data is stored on cloud services, we ensure compliance with applicable data protection standards. Currently, all data storage is maintained within approved jurisdictions, and no personal data is stored offshore outside these environments

Data Security, Retention, and Breach Notification

We implement appropriate technical and organisational measures to protect your personal information from unauthorised access, loss, or misuse. Personal data is retained only as long as necessary to fulfil the purposes described in this policy or to meet legal and regulatory obligations, after which it is securely deleted or anonymised.

We have processes in place to investigate data breaches involving personal information and will notify you and relevant authorities as required by law and in accordance with applicable timeframes.

Keeping Your Information Accurate and Secure

We take reasonable steps to ensure the information we hold is accurate and up to date. You may contact us at any time to request correction of your data if it is inaccurate or incomplete.

We require all third-party service providers to implement appropriate technical and organisational measures to protect your information. Access within Analog Capital is limited to staff who need it to perform their duties, and is governed by internal policies, audits, and regular training.

Your Rights

You have the right to:

    • Access and request correction of your personal information

    • Withdraw consent where applicable, subject to legal or contractual restrictions

    • Object to certain uses of your data

    • Lodge complaints about our handling of your personal information

To exercise these rights or for any privacy-related enquiries, please contact our Data Protection Officer at DataPrivacy@analog-cap.com.

Use of Cookies and Web Tracking

Our website uses cookies and similar technologies to enhance your experience, analyse website usage, and support marketing activities. Cookies may collect device information, browsing activity, and location data.

The types of cookies we use include:

    • Strictly necessary cookies: Enable core site functionality and cannot be switched off.

    • Analytics and performance cookies: Help us understand website usage and improve performance.

    • Functional cookies: Enhance functionality and personalisation.

You can configure your browser to block or delete cookies; however, some website features may not function properly if cookies are disabled.

Links to Other Websites

Our website may contain links to external sites not operated by us. We strongly advise you to review the privacy policies of these third-party sites. We do not control and are not responsible for the content or privacy practices of any other websites.

Changes to This Privacy Policy

We may update this policy from time to time to reflect changes in our practices or legal requirements. Material changes will be communicated via our website and/or direct communication where appropriate. The updated policy will be posted on our website with the revision date.

Contact Us

If you have any questions or concerns about this Privacy Policy or how we manage your personal data, please contact:

Data Protection Officer
Analog Capital Pte Ltd
Email: DataPrivacy@analog-cap.com

 

Last Updated: July 2025