Singularity Dynamics Investment Management Co., Ltd. · Effective: 1 January 2026
Singularity Dynamics Investment Management Co., Ltd. (“Singularity Dynamics,” “we,” “us,” or “our”) is committed to protecting the privacy of individuals who visit our website, submit enquiries, or otherwise interact with us. This Privacy Policy explains how we collect, use, store, and disclose personal information in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and, where applicable, the General Data Protection Regulation (“GDPR”) of the European Union.
1. Information We Collect
We may collect the following categories of personal information when you interact with our website, submit a contact form, or communicate with us directly:
Identity and Contact Data: First name, last name, email address, telephone number, job title, and company or organisational affiliation.
Investor Profile Data: Investor type classification (e.g., family office, institutional investor, sovereign wealth fund), investment interests, and any information voluntarily provided in free-text message fields.
Uploaded Documents: Any files you choose to upload through our contact form, which may include pitch decks, investment summaries, or other materials.
Technical Data: IP address, browser type and version, device identifiers, time zone, operating system, and browsing behaviour on our website, collected via cookies and similar technologies (see our Cookie Policy).
2. How We Use Your Information
We process personal information for the following purposes:
• To respond to your enquiries and provide information about our fund, investment strategy, and opportunities.
• To assess your suitability as a prospective investor in accordance with applicable securities regulations and anti-money laundering (“AML”) and know-your-customer (“KYC”) requirements.
• To send you fund updates, research publications, and market commentary, where you have consented to receive such communications.
• To comply with legal and regulatory obligations, including those imposed by the Securities and Futures Commission (“SFC”) of Hong Kong, the Cayman Islands Monetary Authority (“CIMA”), and applicable anti-money laundering legislation.
• To improve our website, analyse usage patterns, and enhance user experience.
3. Legal Basis for Processing
Where the GDPR applies, we rely on the following legal bases: (a) your consent, where you have provided it; (b) the performance of a contract or pre-contractual steps at your request; (c) our legitimate interests in operating and marketing our fund management business, provided these do not override your rights; and (d) compliance with legal obligations.
4. Data Sharing and Transfers
We do not sell, rent, or trade your personal information to third parties for marketing purposes. We may share your information with:
• Service providers: Including fund administrators, legal counsel, compliance consultants, IT service providers, and cloud hosting providers who assist in our operations, subject to contractual data protection obligations.
• Regulatory authorities: Where required by law or regulation, including the SFC, CIMA, and relevant tax authorities under the Common Reporting Standard (“CRS”) and Automatic Exchange of Information (“AEOI”) frameworks.
• Joint GPs and fund vehicles: Information relevant to investor onboarding may be shared with our joint general partners and fund entities within the Singularity Dynamics group structure.
Where personal data is transferred outside Hong Kong, we ensure appropriate safeguards are in place, including standard contractual clauses or reliance on adequacy determinations.
5. Data Retention
We retain personal information for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Enquiry data is typically retained for 24 months following your last interaction. Investor data is retained for the life of the fund plus seven years in accordance with regulatory record-keeping requirements.
6. Your Rights
Under the PDPO and, where applicable, the GDPR, you have the right to: access the personal data we hold about you; request correction of inaccurate data; request deletion of your data (subject to legal retention obligations); object to or restrict processing; withdraw consent at any time; and lodge a complaint with the Privacy Commissioner for Personal Data (Hong Kong) or your local data protection authority.
7. Security
We implement appropriate technical and organisational measures to protect personal information against unauthorised access, alteration, disclosure, or destruction. These include encrypted data transmission (TLS/SSL), access controls, and regular security assessments. However, no method of internet transmission is completely secure, and we cannot guarantee absolute security.
8. Contact
For questions about this Privacy Policy or to exercise your data rights, contact our Data Protection Officer at: privacy@singularitydynamics.com, or write to: Singularity Dynamics Investment Management Co., Ltd., Unit 804, 8F, Far East Consortium Building, 121 Des Voeux Rd, Central, Hong Kong.