Your privacy is important to us. This privacy statement (the “Privacy Statement”) describes how A2D Ventures Pte. Ltd. and its affiliates (collectively, “us,” “we” or “A2D“) collect, use and disclose Personal Data that you submit via the email and other A2D web properties that link to this Privacy Statement (collectively, the “Site”).

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This Privacy Statement is incorporated within the A2D Terms of Use on the Site (the “Terms”), and capitalized terms used and not otherwise defined in this Privacy Statement shall have the corresponding meanings set forth in the Terms.

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This notice explains our online information practices, including how we collect and use the Personal Data you submit via the Site. If you disagree with the processing of your Personal Data as described in this Privacy Statement, stop using the Site and avoid submitting any Personal Data.

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If you subscribe to any A2D services, your agreement(s) with A2D for these services will include provisions regarding the submission of Personal Data and A2D's rights and obligations.

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Please note that providing personal details to A2D is voluntary, not required by law. You can avoid sharing information by not completing specific forms or disabling cookies. Irreversibly anonymized or aggregated information will not contain Personal Data.

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"Personal Data" or "Personal Information" refers to any information that can uniquely identify a living individual, either alone or combined with other data, and any information considered Personally Identifiable Information by privacy laws. This is a master privacy policy, and some provisions apply only to individuals in certain jurisdictions. For example, the legal basis in the table below is relevant only to GDPR-protected individuals.

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1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

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A. Information we collect from you when you browse or visit our Site

a) What data is collected:

• Cookies, analytic tools and log files

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b) For What Purposes is the Data Collected

• ​To improve, modify and update A2D services and content offered on the Site.

• To monitor and ensure the orderly and proper operation and development of the Site and
  associated services.

• To analyze and derive statistical information with the goal of improving and customizing your
  experience and the content that is presented to you on the Site.
   

c) Legal basis (GDPR only)

• Consent

• Legitimate interest (e.g. essential cookies)

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B. When you contact us (e.g. submit a request)

a) What data is collected:

• Full name

• Contact information (e.g., email and phone number)

• Job title

• Company name

• Country

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b) For What Purposes is the Data Collected

• To process and answer questions

• To customize your experience

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c) Legal basis (GDPR only)

• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

• Legitimate interest (e.g. respond to a query sent by you)

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C. When you contact us (e.g. submit a request) – for the purposes of consent

a) What data is collected:

• Full name

• Contact information (e.g., email and phone number)

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b) For What Purposes is the Data Collected

• To contact you occasionally regarding A2D’s services. (Note: Even if you authorize A2Dto contact
  you, you may revoke/withdraw such authorization any time. In addition, you may opt-out of
  A2D’s mailing lists by following the unsubscribe instructions in each of the emails you receive or
  by contacting us as described in this Privacy Statement).

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c) Legal basis (GDPR only)

• Consent

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D. When you create an account and when you log in

a) What data is collected:

• Email address

• First Name

• Last Name

• Country of Residence

• Phone number

• Your eligibility as an Accredited Investor in SGD (or equivalent currency) including but not limited to (i) financial statement form financial institution, (ii) appraised asset valuation by a qualified appraiser, (iii) pay slip.

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Please find the full definition of accredited investor in accordance to Section 4 A. of the Singapore Securities and Future Act 2001.

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b) For What Purposes is the Data Collected

• To be able to create an account

• To be able to log in

• To be able to enjoy features available to registered users only

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c) Legal basis (GDPR only)​

• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

• Legitimate interest (e.g. respond to a query sent by you)

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E. When you subscribe to our distribution list(s)/newsletter(s)​

a) What data is collected:

• Full name

• Contact information (e.g., email, address and phone number)

• Job title

• Company name

• Country

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b) For What Purposes is the Data Collected

• To send you newsletters for which you have subscribed (together with an unsubscribe option in
  each communication that is sent you).

 

c) Legal basis (GDPR only)

• Consent

• Legitimate interest (e.g. send you more information about A2D)

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F. When we process your job application

a) What data is collected:

• Full name

• Email address

• Phone number

• Resume/CV

• Any other Personal Data you decide to provide us with

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b) For What Purposes is the Data Collected

• To process your job application

• To assess you as a candidate

• To communicate with you for job application-related matters

 

c) Legal basis (GDPR only)

• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

• Legitimate interest (e.g. process your job application)

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G. When you register to our webinars – for the purposes of processing

a) What data is collected:

• Full name

• Contact information (e.g., email and phone number)

• Job title

• Company name

• Country

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b) For What Purposes is the Data Collected

• To send you more information about us and marketing communications

 

c) Legal basis (GDPR only)

• Consent

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H. When you register to our webinars – for the purposes of consent

a) What data is collected:

• Full name

• Contact information (e.g., email and phone number)

• Job title

• Company name

• Country

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b) For What Purposes is the Data Collected

• To process your registration and participation in webinars, conferences and/or other A2Devents
  in which you have registered.

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c) Legal basis (GDPR only)

• To allow you to register to a webinar

• To send you webinar-related communications

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a) What data is collected:

• Full name

• Email address

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b) For What Purposes is the Data Collected

• To send you more information about us and marketing communications

 

c) Legal basis (GDPR only)

• Consent

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I. When you make use of, or interact with, our Site platform

a) What data is collected:

• Full name

• Contact information (e.g., email and phone number)

• Job title

• Company name

• Country

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b) For What Purposes is the Data Collected

• To establish an account for return customers and to provide customer service activities.

 

c) Legal basis (GDPR only)

• Consent

• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

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J. When you engage in investment opportunities on the A2D platform

a) What data is collected:

• Financial and personal information (e.g., forms of identification, tax documentation, banking details, etc.)

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b) For What Purposes is the Data Collected

• For use in connection with A2D’s KYC and accredited investor evaluation processes.

 

c) Legal basis (GDPR only)

• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

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We may use non-personally identifying information collected in aggregate to provide statistical data about Site users (anonymously), improve the Site's quality, design, and content, analyze Site usage, and cooperate with law enforcement. This information is used to enhance website usability and for aggregated statistical reporting.

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We regularly review retention periods for Personal Data. We will store your Personal Data as long as necessary for the purposes outlined in this Privacy Statement, as specified in any relevant contract with us, or as required or permitted by law.

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When providing Personal Data to A2D, you warrant and represent that the information is complete, accurate, and correct. Failure to do so may prevent A2D from contacting you about your inquiries. It is your responsibility to update us if any information is no longer accurate and inform A2D of required updates. Additionally, if you provide Personal Data on behalf of another person or entity, you represent that you have the authorization to give us consent to use the submitted information.

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2. SHARING OF INFORMATION WITH THIRD PARTIES

We do not currently sell any of your Personal Data to third parties, and we have no plans to do so. If we decide to sell your Personal Data, we will first obtain your consent. A2D will not share your personal details or any information related to your activities on the Site (provided it identifies you personally) with third parties, except in specific cases or as outlined in this Privacy Statement.

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We may disclose your Personal Data under the following circumstances:

• A2D shares Personal Data with its affiliates, for the purpose of assisting in the processing activities detailed herein or if such affiliate is the best suited to handle your inquiry.

• A2D may share Personal Data with its consultants, vendors and service providers for the purpose of helping A2D executes certain tasks outsourced to them, or providing capabilities which A2D requires. The service providers to which A2D provides Personal Data collected through the Site include without limitation: (1) email service providers for email campaigns management and to send you emails on our behalf, with the express provision that their use of such information must comply with our instructions; (2) registration management of users to events through the website; (3) billing, processing payments, marketing automation, A2D advertisements on social media, CRM platform, analytics tools providers, web page building tools, cloud services, support and maintenance operation tools. Our service providers do not have any right to use your Personal Data collected from the Site beyond what is necessary for the purpose of facilitating their services for us, and are subject to data protection agreements to the extent required under applicable law. Our vendors with whom we may share Personal Data include entities such as AWS, Hubspot, Auptimate, Osome, Notion and more. If you want to receive a full and updated list of our vendors, please send a request to info@a2dventures.com .

• As permitted or required by, or in response to lawful requests (e.g., subpoenas, court orders and other legal processes) by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security;

• In any case of dispute, or legal proceeding of any kind between you and A2D, or between you and other users or third parties;

• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; and in connection with our Terms and other agreements, including where we believe you may have breached the Terms or other agreements with A2D;

• Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and/or

• Other than as set out above, you will be notified when Personal Data about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

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3. DATA TRANSFERS AND GLOBAL PROCESSING

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The Site may be operated in countries other than your own location, and your Personal Data may be accessed and/or processed from and/or transferred to countries other than your own location. We may do this where data is accessed/processed for any of the basis identified above.

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By consenting to the collection and use of your Personal Data, you agree to your Personal Data being transferred and stored in this manner and for the specified purposes.

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The safeguards we deploy for performing such transfers across boundaries:

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• Adequacy. Any transfers to A2D affiliates may be made on the basis of an adequacy decision;

• Model Clauses. With some of our processors, we use standard contractual clauses that are binding standards of processing of Personal Data committed to contractually by third parties processing information for us and on our behalf;

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4. LINKS

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The Site contains links to other sites. A2D is not responsible for and has no liability for privacy policies and/or practices on other sites. We advise you to read the privacy policy stated on other sites you link to through the Site. Our Privacy Statement only governs information that we collect on the Site.

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5. SECURITY

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We take appropriate precautions to protect your Personal Data by using physical as well as technological security devices. Additionally, we have implemented physical, electronic and procedural safeguards that are designed to protect the security of your information in compliance with applicable laws and regulations. Although we have invested in leading-edge security software, systems and procedures to offer you a safe and secure investing platform and to protect your personal, financial and investment data, no security system is impenetrable. Thus, we are continually monitoring the effectiveness of our security system while constantly refining and upgrading our security technology and procedures to ensure maximum protection.

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6. RETENTION OF YOUR PERSONAL DATA

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Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

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7. SOCIAL MEDIA FEATURES

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The Site includes social media plugins, including links to Facebook, LinkedIn and Twitter. These features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the plugin to function properly. Social media features are governed by the privacy policy of the company providing it.

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8. CHILDREN’S PRIVACY

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You must be at least 18 years old to register for or use the Site. If your state, country, or jurisdiction requires a higher minimum age for Site use or participation in its activities, you must comply with the applicable law. A2D does not knowingly collect Personal Data from minors under the age of 18 through the Site. If a parent or guardian becomes aware that their child has provided us with personally identifiable information without consent, they should contact A2D using the information provided below. If we learn that a child under 18 has provided us with personally identifiable information, we will delete it from our files.

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9. DATA SUBJECT RIGHTS

9.1. The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):

• You have a right to access Personal Data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;

• You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading;

• You have the right to request the erasure/deletion of your Personal Data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims;

• You have the right to object, to or to request restriction, of the processing;

• You have the right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;

• You have the right to object to profiling;

• You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;

• You also have a right to request certain details of the basis on which your Personal Data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;

• You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

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9.2. You may exercise the rights set forth in this Privacy Statement to the extent these rights apply to
you by contacting A2D via the contact information listed herein. We will undertake to respond to your
request within the applicable time frame prescribed by applicable law, and in any event we will make
efforts to respond within 30 days of receipt of your request. Although A2D will make reasonable efforts
to accommodate your requests, in some circumstances we may deem your request unfounded or not
eligible under applicable law. If that should happen, A2D expressly reserves the right to refuse your
request. Before A2D is able to accommodate any request, provide you with any information or correct
any inaccuracies – we may verify your identity by requesting certain information or identification.

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9.4. You can also request that we close your A2D account, or request that we no longer use your information to provide you Services, by emailing Customer Service at info@a2dventures.com . After we close your account, we may retain some information if we believe it may be necessary to prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, if required by law, enforce our Terms of Use and take actions otherwise permitted by law. Notwithstanding the foregoing, if you are an active investor on the A2D platform, it would not be possible to close your A2D account while any investment(s) is/are actively managed by A2D.

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10. LOG FILES

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• Google Analytics. The Website uses a tool called “Google Analytics” to collect information
  about use of the Website. Google Analytics collects information such as how often users visit
  this Website, what pages they visit when they do so, and what other websites they used prior to
  coming to this Website. We use the information we get from Google Analytics to maintain and
  improve the Website and our products.

 

Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

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• Advertising Partners. Through our services, we may allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile/website identifiers, page(s) visited, location, time of day). We also may combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will potentially use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

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We reserve the right to remove or add new analytic tools.

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12. NOTIFICATION OF CHANGES

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This Privacy Statement may change from time to time and we will post the amended terms on the A2D Site and/or notify you by email of major changes. Amended terms will take effect immediately for new users, and 30 days after they are posted for existing users. You should review the Privacy Statement periodically to remain informed of any changes. You agree to accept posting of a revised Privacy Policy as actual notice to you.

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Your continued use of the Site after any changes to this Privacy Statement have been posted (or, if
applicable, notified) signifies your acceptance of those changes. If you do not agree to the revised
Privacy Statement, please refrain from using our products or services and contact us by sending an email
to info@a2dventures.com .

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13. QUESTIONS AND FEEDBACK

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If you have questions or feedback regarding this Privacy Statement, you may direct them to info@a2dventures.com , and we will make every effort to answer your questions promptly.

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