WHY?
Financial companies choose how they share your personal information. Applicable laws give consumers the right to limit some but not all sharing. Applicable law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
WHAT DATA DO WE COLLECT?
The types of personal information we collect and share depend on the product or service you have with us. Generally, this information can include:
- Location Address and Telephone Numbers
- Identification Numbers – Date of Birth, Social Security / Tax Identification, Passport Number, Driver’s License Number
- Online Identification – Email Addresses
- Financial Data – Income, Assets, Net worth, Account balances
- Banking Data – Account (Wire) transfer instructions
HOW?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information (subject to applicable law); the reasons Proterra Asia chooses to share; and whether you can limit this sharing.
REASONS WE CAN SHARE YOUR PERSONAL INFORMATION
For our everyday business purposes – such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations.
DOES PROTERRA SHARE?
Yes
CAN YOU LIMIT THIS SHARING?
No
For our marketing purposes – to offer our products and services to you
No
We don’t share
For joint marketing with other financial companies
No
We don’t share
For our affiliates’ everyday business purposes – information about your transactions and experiences
Yes
No
For our affiliates’ everyday business purposes – information about your creditworthiness
No
We don’t share
For nonaffiliates to market to you
No
We don’t share
Questions?
Contact the Compliance Officer at + 65 6709 8750
WHO WE ARE
Who is providing this notice?
This notice is provided by Proterra Asia, the affiliated general partners to the private investment funds managed by Proterra Asia, and the private investment funds managed by Proterra Asia.
How does Proterra Asia protect my personal information?
To protect your personal information from unauthorized access and use, we use security measures that comply with applicable law. These measures include computer safeguards and secured files and secured buildings. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and will review and enhance our information security measures as necessary from time to time.
How does Proterra Asia collect my personal information?
We collect your personal information, for example, when you
- Open an account or seek investment advice
- Complete an investor questionnaire or subscription document
- Give us your contact information, or other personal data
- Make capital calls or receive distributions from your account
- Give us your employment history
We also collect your personal information from affiliates.
Why can’t I limit all sharing?
Applicable law gives you the right to limit only
- sharing for affiliates’ everyday business purposes—information about your creditworthiness
- affiliates from using your information to market to you
- sharing for non-affiliates to market to you
State laws and individual companies may give you additional rights to limit sharing.
GENERAL DATA PROTECTION REGULATION (“GDPR”), DATA PROTECTION LAW, 2017 OF THE CAYMAN ISLANDS (“DPL”) AND SINGAPORE PERSONAL DATA PROTECTION ACT 2012 (“PDPA”)
GDPR
The GDPR applies to individuals who are citizens of or resident in the EU, including the UK, at any time their data is processed. The EU GDPR includes rules on giving privacy information to data subjects in Articles 12, 13 and 14.
DPL
The DPL applies to investors in our Cayman Islands investment funds.
If you are a corporate investor (including, for these purposes, legal arrangements such as trusts or exempted limited partnerships) that provides us with personal information on individuals connected to you for any reason in relation to your investment with us, this will be relevant for those individuals and you should transmit this document to such individuals or otherwise advise them of its content.
PDPA
The PDPA applies to Proterra Asia in connection with its collection, use and disclosure of personal data of current, former and prospective investors of funds managed by Proterra Asia or its affiliates.
Data Controller and Who We Are
Proterra Asia is the Data Controller and is committed to protecting the rights of individuals in line with the PDPA.
Proterra Asia’s contact details are:
Telephone: + 65 6709 8750
Address:
138 Market Street
#16-02 CapitaGreen
Singapore 048946
Proterra Asia acts as Investment Adviser and Distributor of the Fund.
What Data Do We Share?
We will only share personal data provided where:
- We have a legitimate business interest to do so, in order to facilitate the execution of a contract /service
- We have regulatory or legal obligations to share personal data
- You have requested us to do so
We may disclose your personal data to relevant regulatory authorities and tax authorities, and to our service providers, which may include our administrators, accountants, auditors, bankers, insurers, lawyers, AML service providers and other back-office service providers.
Any transfer of personal data by us or our duly authorized affiliates and/or delegates outside of the Cayman Islands shall be in accordance with the requirements of the DPL.
For the purposes of the PDPA, we may transfer your personal data to countries outside of Singapore in connection with the reasons set forth above and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
Your Rights Under the GDPR and the DPL
Under the GDPR you have a number of rights with regard to your personal data. You have the right to:
- Request from us access to and obtain a copy of your personal data held
- Rectification of incorrect or incomplete data
- Erasure of your personal data where there is no legitimate basis for it to be held restrict processing
- Object to processing as well as in certain circumstances the right to data portability
If you have provided consent for the processing of your data you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn. Investors in our Cayman Islands investment funds have broadly analogous rights under the DPL.
You have the right to lodge a complaint to the Information Commissioners’ Office if you believe that we have not complied with the requirements of the GDPR or United Kingdom Data Protection Act 2018 with regard to your personal data. Investors in our Cayman Islands investment funds have the right to lodge a complaint with the Cayman Islands Ombudsman pursuant to the DPL.
Your Rights Under the PDPA
Under the PDPA you have a number of rights with regard to your personal data. You have the right to:
- Withdraw your consent for the collection, use and disclosure of your personal data, and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via e‑mail to our Data Protection Officer at the contact details provided below. While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and, in such circumstances, we will notify you before completing the processing of your request.
- Make a request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data. A reasonable fee may be charged for an access request. You may submit your request in writing or via e‑mail to our Data Protection Officer at the contact details provided below.
- Make a request to correct or update any of your personal data that we hold about you. You may submit your request in writing or via e‑mail to our Data Protection Officer at the contact details provided below.
We generally rely on personal data provided by you. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via e‑mail at the contact details provided below.
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected or as required or permitted by applicable law. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.
Data Protection Officer
Proterra Asia is the controller and processor of data for the purposes of the GDPR.
For the purposes of the GDPR, Proterra Asia has opted not to appoint a Data Protection Officer, which is within the GDPR. Any matters relating to Data Protection can be raised to any of the following persons within the firm:
- The Managing Partner; and
- The Compliance Officer.
For the purposes of the PDPA, Proterra Asia has designated a Data Protection Officer. You may contact the Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures or if you wish to make any request using the following contact details:
Telephone: + 65 6709 8750
E‑mail Address: marketing@proterrapartners.com
How To Make A Complaint
If you are unhappy with the way in which your personal data has been processed you may in the first instance contact the Compliance Officer using the following contact details:
Telephone: + 65 6709 8750
Address: 138 Market Street, #16-02 CapitaGreen, Singapore 048946
If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at: Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
United Kingdom
SK9 5AF
www.ico.org.uk
Effective Date of and Changes to Privacy Policy
This Privacy Policy applies in conjunction with any other contractual clauses, consent clauses and notices that may apply in relation to the collection, use and disclosure of your personal data by Proterra Asia.
We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Last Updated: March 17, 2020
DEFINITIONS
Affiliates
Companies related by common ownership or control. They can be financial and nonfinancial companies.
- Our affiliates include the Proterra Asia private investment funds that we manage and the general partners of the Proterra Asia private investment funds.
Nonaffiliates
Companies not related by common ownership or control. They can be financial and nonfinancial companies.
- Proterra Asia does not share with nonaffiliates so they can market to you.
Joint Marketing
A formal agreement between nonaffiliated financial companies that together market financial products or services to you.
- Proterra Asia does not jointly market.
- Personal data will not be used for marketing unless consent is provided.
Personal Data
For the purposes of the PDPA, data, whether true or not, about a customer who can be identified (a) from that data or (b) from that data and other information to which we have or are likely to have access.