Introduction
Vertex FinCapital is committed to safeguarding and processing personal information ("PI"), including sensitive personal information ("SPI"), in compliance with applicable privacy and data protection laws, including the Personal Data Protection Act 2012 (PDPA) of Singapore.
"Vertex FinCapital," "we," "us," or "our" refers to Vertex FinCapital, a sub-fund of XEQ Global Alternatives VCC, managed by XEQ Capital and promoted by YB Advisors Ltd. Where applicable, "we" includes affiliates, service providers, and regulated entities operating under the Vertex FinCapital framework. The fund is operated by Vertex FinCapital and legally represented by its management entity.
- Registered Address: 76 Playfair Road, #06-01, Singapore 367996
- Registration Number: T24VC0027F-SF002
This Privacy Policy applies to individuals whose PI is collected and processed in connection with:
- visiting or using our website and services;
- making inquiries regarding investment opportunities;
- participating in the fund as an investor, representative, or partner;
- providing services to Vertex FinCapital; or
- interacting with us during events, communications, or onboarding.
This document outlines the purposes for which we collect, use, and disclose PI, the categories of PI we may process, and how we protect your data. It also outlines your rights under relevant privacy legislation.
What Personal Information We Collect
We may collect and process the following categories of PI, depending on your interaction with us:
- Identification Data: Full name, date of birth, nationality, passport number, identification documents, signature.
- Contact Data: Personal or business address, email address, phone number.
- Professional Data: Company name, title/position, work history, business contact details, LinkedIn or similar professional identifiers.
- Financial Data: Bank details, payment history, account numbers, investment transactions, KYC and AML documents.
- Electronic Monitoring Data: Email records, contact forms, website inquiries, communications with representatives.
- Technical Data: IP address, device data, browser type, session metadata, cookies (see Cookie Policy).
- Interaction Data: User preferences, history of communications, submitted forms or applications.
- Service and Contract Data: Legal agreements, onboarding forms, compliance documents, subscription or redemption data.
- Sensitive Personal Information (SPI): Only when legally required or voluntarily disclosed, such as disability accommodations, politically exposed person (PEP) status, or dietary/religious information in the context of events.
How We Collect Personal Information
We collect PI through the following means:
- Directly from you (e.g., via web forms, onboarding documents, or communication);
- From your employer, organization, or authorized representative;
- From service providers or regulatory partners (e.g., legal, compliance, banking);
- From publicly available sources (e.g., company websites, LinkedIn);
- Automatically through our website using cookies, analytics tools, and session logs;
- During participation in events, meetings, or fund-related transactions.
Specific personal data may be required to comply with legal or contractual obligations. Failure to provide such data may result in an inability to establish or maintain a relationship with Vertex FinCapital.
International Transfers and Service Providers
As part of delivering cross-border financial services, Vertex FinCapital may transfer personal information outside of the jurisdiction in which it was collected. This includes transfers to affiliated entities, service providers, or partners in jurisdictions such as the European Union, the United States, Singapore, and other countries where XEQ Capital, YB Advisors Ltd, or engaged third-party providers operate.
Where PI is transferred internationally, we apply equivalent levels of protection through:
- contractual safeguards with third-party processors;
- adherence to the Personal Data Protection Act (PDPA) of Singapore;
- and, where applicable, the use of EU Standard Contractual Clauses (SCCs) for transfers outside of the EEA.
Marketing Communications and Personalization
Where permitted under applicable law, we may send you updates and marketing communications related to Vertex FinCapital or its affiliated partners. In jurisdictions requiring explicit consent, we will only contact you after obtaining such consent.
You may opt out of receiving such communications at any time by:
- clicking the unsubscribe link included in our emails,
- notifying your usual contact person,
- or contacting us directly via the details provided in the Contact Us section.
If you are logged into our platforms, we may also tailor your experience based on previous interactions and preferences, in accordance with your consent and applicable cookies policy.
No Sale of Personal Information
Vertex FinCapital does not sell your personal information. Without your explicit consent, we do not share your PI with third parties for direct marketing or advertising purposes. Furthermore, we do not knowingly collect or share PI from individuals under 16.
Data Retention
Your PI is retained only for as long as necessary to fulfil the purposes for which it was collected, including:
- legal or regulatory compliance,
- internal policy requirements,
- audit and accounting obligations,
- and in some cases, for the establishment, exercise, or defense of legal claims.
Retention periods are determined based on the nature of the data, its relevance to business activities, and applicable statutory requirements.
Data Security
We implement technical, administrative, and physical safeguards to protect your PI from unauthorized access, alteration, disclosure, or destruction. These measures include:
- staff training in cybersecurity awareness and privacy compliance,
- restricted access protocols,
- secure IT infrastructure with firewalls and encryption (e.g., SSL/TLS),
- role-based data access and endpoint protection,
- periodic external audits and vendor risk assessments,
- disaster recovery and data backup mechanisms,
- and layered threat detection and response capabilities.
While we apply industry-standard security protections, no data transmission over the internet can be guaranteed to be entirely secure. We advise against sending sensitive personal information via unencrypted email or unsecured channels.
Your Rights
Subject to applicable data protection laws, including the Personal Data Protection Act 2012 (PDPA) of Singapore and other relevant international frameworks, you may have the following rights regarding your personal information (PI):
- Access: Request a copy of the PI we hold about you and information about how it is processed.
- Objection: Object to the processing of your PI where it is based on our legitimate interests or used for direct marketing.
- Withdrawal of Consent: Withdraw any consent you have previously provided, without affecting the lawfulness of processing prior to withdrawal.
- Correction: Request correction or completion of inaccurate or incomplete PI.
- Erasure: Request deletion of your PI, subject to our legal and regulatory obligations.
- Restriction: Request that we limit the processing of your PI in certain circumstances (e.g. pending correction or objection).
- Data Portability: Request a copy of your PI in a structured, commonly used and machine-readable format.
- Automated Decision-Making: Request human intervention or explanation where decisions affecting you are made solely based on automated processing.
You may exercise your rights anytime by contacting us using the details below. We may need to verify your identity before acting on your request to ensure confidentiality and data integrity. Where allowed under law, we reserve the right to charge a reasonable fee for excessive or unfounded requests.
If you act through an authorized representative, appropriate documentation, such as a valid power of attorney or written mandate, may be required to validate their authority.
Exercising your rights will not affect the service or treatment you receive from Vertex FinCapital. We will respond to all valid requests within the timeframe applicable data protection law requires.
Contacting Us
If you wish to exercise your rights or have any questions about this Privacy Policy or our data protection practices, please contact Vertex FinCapital at:
- Email: info@vertexfcapital.com
- Website: vertexfcapital.com
