Privacy Policy

Last Updated: 17 September 2025

Overview

At Fuzsion Capital Pte Ltd (“Fuzsion Capital”, “we”, “us”, or “our”), we are committed to protecting your personal data and respecting your privacy. This Privacy Policy explains in detail how we collect, use, disclose, and safeguard personal data in compliance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and other applicable data protection laws. It applies to all personal data in our possession or under our control, including personal data managed on our behalf by third parties.

Section 1 - Introduction & Commitment to Privacy

Your trust is important to us. This Policy sets out the principles governing how Fuzsion Capital manages personal data. We believe in transparency and accountability, ensuring that individuals know what data we collect, how it is used, and how they can exercise their rights. This Policy covers customers, investors, employees, contractors, business partners, service providers, and visitors to our website or platform.

Section 2 - Who This Policy Covers

This Policy applies to any individual who interacts with Fuzsion Capital, including:
- Clients and prospective investors.
- Website visitors and mobile app users.
- Vendors, consultants, and business partners.
- Employees, contractors, and job applicants.
- Any other party providing personal data in the course of dealings with us.

Section 3 - Definition of Personal Data

Under the PDPA, “personal data” refers to any data, whether true or not, about an individual who can be identified from that data alone, or from that data combined with other information accessible to an organisation. Examples include names, identification numbers, contact information, and financial records. For the purposes of this Policy, personal data also includes technical and usage information collected automatically through our website and platform.

Section 4 - Types of Data We Collect

We may collect and process various types of personal data depending on your relationship with us:

- Identity and Contact Data: Name, NRIC/passport, nationality, gender, date of birth, address, phone number, email, photographs.
- Financial and Employment Data: Bank account details, income, assets, tax residency, occupation, employer details.
- Transaction Data: Investments, payments, redemptions, subscriptions, loan arrangements.
- Technical and Usage Data: Login details, device identifiers, cookies, IP addresses, browsing patterns.
- Compliance Data: KYC/AML verification, sanctions screening, politically exposed person (PEP) checks.
- Communications Data: Correspondence by email, phone calls, or chat messages.
- Audio-Visual Data: CCTV, video recordings, voice recordings for compliance or security purposes.

Section 5 - How We Collect Data

Personal data may be collected in several ways:
- Directly from you: through forms, applications, account opening, communications, and documents submitted.
- Automatically: via cookies, log files, and analytics tools when you use our website or platform.
- From third parties: including financial institutions, verification service providers, regulators, or partners.
- Public sources: such as government registries, professional directories, or publicly available platforms.

We generally do not collect personal data unless it is provided voluntarily, or where such collection is required or authorised by law.

Section 6 - Purposes of Data Use

Fuzsion Capital may use personal data for purposes including:
- Providing services requested by you.
- Verifying your identity and conducting due diligence.
- Complying with MAS, IRAS, AML/CTF, and other regulatory obligations.
- Processing transactions, payments, and investment instructions.
- Managing and maintaining relationships with clients and partners.
- Communicating updates, promotions, and relevant marketing (subject to consent).
- Detecting, investigating, and preventing fraud or unlawful activities.
- Conducting internal audits, risk assessments, and business planning.
- Ensuring platform security and monitoring usage.
- Any other purpose related to your relationship with us.

Section 7 - Disclosure of Data

We may disclose personal data to trusted third parties where necessary:
- Employees, officers, and authorised representatives of Fuzsion Capital.
- Affiliates, subsidiaries, and related corporations.
- Professional advisers such as auditors, lawyers, and consultants.
- Service providers including IT vendors, cloud hosting, and KYC agents.
- Banks, custodians, and payment intermediaries.
- Regulators, law enforcement, and government authorities where required.
- Business successors in connection with mergers, acquisitions, or restructurings.

All recipients are required to maintain confidentiality and protect data in compliance with applicable laws.

Section 8 - Consent & Withdrawal

By providing personal data, you consent to its collection, use, and disclosure for the purposes set out in this Policy. Consent may be expressed (e.g., signing a form) or implied (e.g., providing data voluntarily). You may withdraw consent at any time by contacting our Data Protection Officer. Withdrawal may affect our ability to provide services, but does not affect processing required by law.

Section 9 - Your Rights

You have rights under the PDPA, including:
- Access: Request copies of your personal data held by us.
- Correction: Request corrections of inaccurate or incomplete data.
- Withdrawal: Withdraw consent for non-essential uses.
- Portability: Request transfer of data where technically feasible.

Requests must be submitted in writing to our DPO. We aim to respond within 30 days and may charge a nominal fee for access requests.

Section 10 - Retention of Data

We retain data only as long as necessary to fulfil the purposes for which it was collected, or as required by law. Typically, personal data is retained for 5–7 years after the end of the relationship. Once no longer required, data is securely deleted or anonymised.

Section 11 - Accuracy of Data

We rely on you to provide complete and accurate information. Please notify us promptly of any updates to your personal data.

Section 12 - Data Protection Measures

We take appropriate measures to safeguard personal data against loss, misuse, unauthorised access, disclosure, or modification. Our security practices include:
- Encryption and secure servers.
- Access restrictions and employee confidentiality agreements.
- Regular IT security reviews, audits, and penetration testing.
- Physical security at our offices and data centres.

While no system is completely secure, we continually update safeguards to reduce risks.

Section 13 - International Transfers

Where personal data is transferred outside Singapore, we ensure it is protected by contractual safeguards or equivalent legal standards. We will not transfer personal data overseas without ensuring compliance with the PDPA.

Section 14 - Cookies & Tracking

We use cookies and similar technologies to improve website functionality and enhance user experience. Cookies help us remember preferences, analyse site traffic, and deliver tailored content.

Types of cookies include:
- Essential cookies: Enable login and secure functions.
- Functional cookies: Store preferences and settings.
- Analytics cookies: Collect usage statistics.
- Marketing cookies: Deliver targeted advertising.

Third-party cookies, such as Google Analytics, may also be used. You may manage or disable cookies in your browser, but this may affect functionality.

Section 15 - Children’s Privacy

Our services are not directed to individuals under 18. We do not knowingly collect personal data from minors. If we become aware of such data, we will delete it promptly.

Section 16 - Legitimate Interests Exception

We may rely on legitimate interests to collect, use, or disclose data without consent, where permitted by the PDPA. Examples include:
- Fraud detection and prevention.
- Network security monitoring.
- Credit analysis and risk management.
- Protecting business operations and enforcing rights.

We will always balance legitimate interests against potential adverse impacts on individuals.

Section 17 - Withdrawing Consent

You may withdraw consent by writing to our DPO. Processing may take up to 10 business days. Withdrawal does not affect data processing required by law.

Section 18 - Access & Correction Requests

To request access or corrections, please contact our DPO. A reasonable fee may apply for access requests. If we cannot fulfil a request, we will provide reasons unless prohibited by law.

Section 19 - Updates to This Policy

This Policy may be updated periodically to reflect changes in law, regulation, or business practices. The latest version will be posted on our website. Continued use of our services after updates constitutes acceptance

Section 20 - Governing Law

This Policy is governed by and construed in accordance with the laws of Singapore. Disputes arising from this Policy shall be resolved in Singapore.