Octagon Capital Management Pte Ltd

Data Protection Policy

We, Octagon Capital Management Pte Ltd (“Octagon”), take our responsibilities under Singapore’s Personal Data Protection Act 2012 (“PDPA”) seriously. We recognize the importance of the personal data you have entrusted to us and our responsibility to properly manage, protect and process your personal data.

This Data Protection Policy is designed to assist you in understanding how we generally collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, or have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, please do not hesitate to contact our Data Protection Officer at:

Data Protection Officer
Octagon Capital Management Pte Ltd
Email: info@octagoncapital.com.sg
Main Number: +65 6325 2870


A. Introduction to PDPA

“Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, bank account numbers and other financial information.

We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.


B. Purposes for Collection, Use, Disclosure and Processing of Personal Data

We may collect, use, disclose and/or process your personal data for various purposes, depending on the circumstances for which we may need to use including but not limited to:

  1. responding to your enquiries and/or carrying out instructions issued by you or on your behalf;
  2. administering and/or managing your relationship with us (including outsourcing of any related functions to authorised service providers)
  3. carrying out due diligence or other screening activities (including background checks) in accordance with legal and regulatory obligations or risk management procedures (including but not limited to those designed to combat financial crime, anti-money laundering, counter-terrorist financing or anti-bribery) that may be required by law or that may have been put in place by us;
  4. sending you information and materials relating to fund(s) managed by us via email;
  5. storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
  6. complying with or as required by any request or direction or regulatory requirement of any governmental authority; and
  7. any other purposes which we may notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

In order to conduct our business operations smoothly, we may also disclose the personal data you have provided to us to our third party service providers, agents, delegates and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.


C. Specific Issues for the Disclosure of Personal Data to Third Parties

We respect the confidentiality of the personal data you have provided to us. In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.


D. Request for Access and/or Correction of Personal Data

You may request to access and/or correct the personal data currently in our possession by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. If we deny your access or correction request, we will provide you with reasons for doing so.

We reserve the right to charge you a fee for handling and processing your requests to access and/or processing your personal data. Such fee will depend on the nature and complexity of your request.


E. Request to Withdraw Consent

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control. Your withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of your withdrawal of consent, we may not be able to continue with your existing relationship with us.


F. Administration and Management of Personal Data

We will make reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be disclosed to another organisation. This also implies that you must update us of any changes in your personal data form time to time. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any material changes in your personal data in a timely manner.

We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:

Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or other applicable law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations (which may or may not be set out in a contract between the parties) to provide to the transferred personal data a standard of protection that is comparable to the protection under the PDPA.


G. Cookies

Please note that we use cookies on our website. Cookies are text files that we put on your computer and they store/record information about your visit to and use of the website. Cookies can compile information about your browsing habits and can also enhance your browsing experience.

Your use of our website constitutes consent by you to our use of cookies and to the matters set out herein.


H. Updates on Data Protection Policy

As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

We reserve the right to amend the terms of this Data Protection Policy at any time at our absolute discretion. Any amended Data Protection Policy will be posted on our website.