1. Overview and Scope 

Company Identity and Licensed Status

1.1.   In this Privacy Policy, “we,” “us,” “our” or “the Company” means NH Absolute Return Partners Pte. Ltd. (Company Registration Number: 200805707G), a company incorporated in Singapore and licensed by the Monetary Authority of Singapore (“MAS“) to conduct fund management activities under a Capital Markets Services licence issued pursuant to the Securities and Futures Act 2001 of Singapore.

Definitions

1.2.   In this Privacy Policy:

1. (a)   “NH ARP Group” means the Company together with its affiliated entities, related corporations or any of their respective subsidiaries;

1. (b)   “Personal Data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information we have or are likely to have access to, as defined under the Personal Data Protection Act 2012 of Singapore (“PDPA“);

1. (c)   “Website” includes but is not limited to the information, materials, data, reports, text, images, links, sounds, graphics and video sequences displayed herein.

Basis of Processing and Consent

1.3.   This Privacy Policy sets out the basis on which we may collect, use, disclose, and process your Personal Data in accordance with the PDPA and all subsidiary legislation, regulations, and advisory guidelines issued thereunder. By visiting and using this Website, you consent to the collection, use and disclosure of your Personal Data as described in this Privacy Policy. If you are acting as an intermediary or otherwise on behalf of a third party or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, use, storage and disclosure of their Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this Privacy Policy by referring them to our Website.

Other Legal Grounds and Cumulative Consents

1.4.   This Privacy Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us, either directly or via a third-party data collector, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use, disclose and/or process your Personal Data. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your Personal Data.

Scope of Application

1.5.   This Privacy Policy applies to Personal Data collected through this Website and through any other interactions you may have with us in connection with your access to or interest in the Company’s services. It does not apply to information collected by third parties, including third-party websites that may be linked from this Website.

Processing Required by Law and Regulatory Obligations

1.6.   Please note that certain data processing activities described in this Privacy Policy are required by law or by MAS regulations and may be carried out without or regardless of your consent, as further described in Section 3 below. In such cases, the Company relies on the applicable legal basis under the PDPA (including the First and Second Schedules thereto) rather than on your consent.

2. Collection of Personal Data

Sources of Personal Data Collection

2.1.   Generally, we collect Personal Data when you or your authorised representatives provide it directly or indirectly to us or to our subsidiaries, affiliates, partners, vendors or service providers, including through the following:

1. (a)   whenever you furnish Personal Data by completing online or hardcopy forms during the application process for or enquiry about the Company’s services, making inquiries, submitting requests, or engaging in various forms of communication;

1. (b)   upon any interaction with the Company (such as telephone conversations, social media interactions, faxes, or emails), we may retain records of such correspondence;

1. (c)   for evaluating job applications and determining suitability for roles within the Company;

1. (d)   upon entering into a contractual agreement with the Company or enrolling in any of the Company’s services;

1. (e)   upon your response to any communication materials issued by the Company;

1. (f)   if you participate in surveys or initiatives managed by the Company;

1. (g)    when attending events, seminars, or workshops organised or sponsored by the Company;

1. (h)   when you link any of your account(s) with us with third-party services and applications (examples include, without limitation, Google and LinkedIn);

1. (i)    when we receive your Personal Data from third parties, for example, when you submit your email address to us to show interest, we receive information from a third party that provides automated fraud detection services to us, or from parties that legally provide it to us, such as credit reference agencies or law enforcement agencies; and

1. (j)   through the use of analytics code and other tools like cookies (please refer to Section 8 below for further details).

Categories of Personal Data Collected

2.2.   Depending on your interaction with us, we may collect the following kinds of Personal Data through the different channels mentioned above:

1. (a)   full name;
   

1. (b)   contact details (including address, telephone/ mobile numbers, e-mail address);

1. (c)   date of birth;

1. (d)   Singapore National Registration Identification Card (“NRIC”)/Passport numbers, and other government-issued identity document details;

1. (e)   work pass numbers (e.g. FIN) and details, where applicable;

1. (f)   gender and nationality;

1. (g)   legal and financial history;

1. (h)   bank account details and payment information;

1. (i)   IP address and other technical data collected through cookies and analytics tools (see Section 8 below);

1. (j)   photographs, videos and other audio-visual information;

1. (k)   educational, employment history and professional qualifications, including testimonials and references;

1. (l)   curricular vitae; and

1. (m)   any other information that on its own, or when combined with other information, can uniquely identify individuals.

Collection of Anonymous and Aggregated Data

2.3.   Apart from Personal Data, we may also collect other types of information which may not be related to a specific individual. Such information is anonymous and will be used in an aggregated form. Examples would include but are not limited to information such as the traffic and usage patterns of our Website visitors ascertainable through the use of “cookies”. For avoidance of doubt, the NRIC number will only be collected, used and/or disclosed if necessary and only in accordance with the guidelines set out by the Personal Data Protection Commission of Singapore.

3. Purposes of Collection, Use and Disclosure of Personal Data

Operational, Contractual and Regulatory Purposes

3.1.   We may collect, use and/or disclose your Personal Data for any or all of the following purposes:

1. (a)   for administering and operating this Website(s);
   

1. (b)   to perform or carry out our obligations arising from any contracts entered into between you and us;
   

1. (c)   for conducting due diligence, Anti-Money Laundering (AML), Know Your Customer (KYC) and other background checks as required under the SFA, the MAS Notice on Prevention of Money Laundering and Countering the Financing of Terrorism (SFA 04-N02), and other applicable MAS notices and guidelines;
   

1. (d)   for client administration, account management, and servicing of queries and requests;

1. (e)   for payment administration purposes;

1. (f)   managing the administrative and business operations of the NH ARP Group and complying with internal policies and procedures;

1. (g)   to respond to, handle and process your enquiries, requests, applications, complaints, and feedback pursuant to your emails, telephone calls, submission of form(s) and/or any other form of communication;
   

1. (h)   to comply with the SFA, and any other applicable laws, regulations, MAS notices, guidelines, circulars, or directions issued by MAS or any other relevant regulatory or law enforcement authority, which any member of the NH ARP Group may be subject, from time to time, whether local or overseas (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
   

1. (i)   for recruitment and evaluation purposes if you apply for a job with us;

1. (j)   to follow up with event attendees and for security clearance purposes at the Company’s events and premises;

1. (k)   for internal reporting, accounting, audit, compliance, and risk management purposes;

1. (l)   for compiling statistics, whether for our own use or for industry exercises and studies, including for the purposes of improving our products and services for you;
   

1. (m)   to enhance security, monitor and verify identity or service access, and combat spam, malware, fraud, or other security risks;
   

1. (n)   to send information including confirmations, technical notices, updates, regulatory disclosures, security alerts, and support and administrative messages;

1. (o)   for market research and to understand investor behaviour, preferences, and demographics, where you have provided consent for such purposes;

1. (p)   disclosure to other members of the NH ARP Group, business partners, or third party service providers;

1. (q)   legal and accounting purposes (including but not limited to obtaining legal advice and dispute resolution);

1. (r)   all other purposes which are reasonably related to the aforesaid; and
   

1. (s)   any other purposes for which you have provided consent, or which are permitted under applicable laws and regulations, including the First and Second Schedules to the PDPA.

Continuing Application After Termination

3.2.   The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

4. Disclosure of Personal Data to Third Parties

Categories of Third-Party Recipients

4.1.   We may disclose your Personal Data for any of the purposes listed in Section 3 to the following persons, whether located overseas or in Singapore:

1. (a)   entities belonging to the NH ARP Group;
   

1. (b)   agents, third party service providers and contractors, including third party vendors that provide services to the NH ARP Group, including, without limitation, courier services, information technology, telecommunications, payment, payroll, processing, training, survey, market research, storage, archival, data processing or management services and for compliance with applicable laws and regulations;
   

1. (c)   vendors and other third party service providers in connection with promotions, online campaigns, products and services offered by the NH ARP Group;
   

1. (d)   our auditors, legal advisers, tax advisers, compliance consultants, and other professional advisers;
   

1. (e)   credit bureaus and credit reporting agencies;

1. (f)   any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale);

1. (g)   relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any court orders, requirements of legal authorities, laws, rules, guidelines and regulations or schemes to which the NH ARP Group may be subject;
   

1. (h)   brokerage houses, fund houses, registrars, custodians, external banks and investment vehicles in relation to any custodial services and settlement processing; 
   

1. (i)   counterparties, billing organisations, banks, credit agencies and other financial and/or payment service providers; and

1. (j)   any other party to whom you authorise us to disclose your Personal Data to.

Aggregated and Anonymised Disclosures

4.2.   We may share information about you in aggregate or anonymised form with the abovementioned entities or parties, provided that such information cannot be used to identify you individually.

Data Intermediaries and Safeguards

4.3.   Where we engage third parties as data intermediaries to process Personal Data on our behalf, we will take reasonable steps to ensure that such third parties are contractually bound to protect your Personal Data to standards comparable to those required under the PDPA.

5. Withdrawal of Consent

Right to Withdraw Consent

5.1.   The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided in Section 13 below.

Processing Timeline and Consequences

5.2.   Upon receipt of your written withdrawal request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed. We will notify you of the consequences of acceding to your withdrawal, including any legal consequences which may affect your rights and liabilities. In general, we shall endeavour to process your request within thirty (30) business days of receiving and verifying your identity and request.

Impact on Services

5.3.   Whilst 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 we shall, in such circumstances, notify you before completing the processing of your request. 

Processing Without Consent Where Permitted by Law

5.4.   Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is required or permitted under the PDPA (including under the First and Second Schedules thereto) or any other applicable written laws, including for AML/CFT compliance and other regulatory obligations.

6. Transfer of Personal Data Outside Singapore

Comparable Protection for Overseas Transfers

6.1.   Where there is a necessity to transfer Personal Data outside of Singapore, whether to our affiliates, related companies, business partners, authorized agents, third party service providers or to data storage facilities, we endeavor to do so in accordance with the requirements of the PDPA and/or the privacy laws of any other applicable jurisdiction, to ensure that the standard of protection applied to Personal Data so transferred is comparable to the protection under the Act and/or the applicable privacy laws of the applicable governing jurisdiction.

7. Retention of Personal Data

Retention Period

7.1.   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 laws and regulations.

Cessation of Retention

7.2.   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 the purpose for which the Personal Data was collected is no longer being served by retention, and retention is no longer necessary for legal, regulatory, or business purposes, and all applicable minimum retention periods have been satisfied.

8. Cookies and IP Addresses

Collection of Technical Information

8.1.   When you use our Website, we may collect and store information about your computer or other electronic devices (including your IP address, operating system, and browser type) for system administration purposes. This is statistical data about the browsing actions and patterns of users of our Website. This data may potentially lead to your identification, but we, and our data intermediaries, do not use it to identify you except where required or permitted by law.

Use of Cookies

8.2.   Cookies are small files which are stored on your computer or other electronic devices when you access a website. They help the website to navigate efficiently between pages and enable the website operator to track usage of the site. Cookies cannot contain viruses or anything else that might harm your computer or other electronic devices.

Purpose of Cookie Usage

8.3.   Our Website uses cookies to distinguish you from other users of our website by storing information on your computer or other electronic devices, including session information such as the number of times you visit our Website and the location from which you are accessing the Website. While some limited information is personally identifiable for the purposes of managing your experience on the Website, any other information is anonymised and aggregated to produce statistical reports that enable us to evaluate the use of our website, and to make improvements to, and increase efficiency when you browse our Website.

Managing Cookie Preferences

8.4.   If you wish to disable cookies on your computer or other electronic devices, you may do so by changing your browser settings. Please note that changing these settings may limit the functionality of some web pages or prevent them from loading properly. By continuing to use this Website without changing your cookie settings, you are deemed to consent to our use of cookies as described in this Section 8.

9. Protection of Personal Data

Security Measures and Limitations

9.1.   Although every reasonable effort has been made to ensure that all Personal Data will be protected, we cannot be responsible for any unauthorised use or misuse of such information and damage arising from risks which are inherent in all internet communications.

Mandatory Data Breach Notification

9.2.   In the event of a data breach that is likely to result in significant harm to affected individuals or is of a significant scale, the Company will comply with its mandatory data breach notification obligations under the PDPA, including notifying the Personal Data Protection Commission within three (3) calendar days of assessing that the data breach is notifiable, and notifying affected individuals as required.

10. Links to Third-Party Websites

External Links Disclaimer

10.1.   Our Website may contain links to other external websites. The Company is not responsible for the privacy policies, data protection practices, or content of such external websites which are under the care of third parties. We strongly encourage you to check the privacy policy of each website that you visit. The inclusion of any link on this Website does not constitute an endorsement or recommendation of the linked website or its content.

11. Accuracy of Personal Data

User Obligation to Update Information

11.1.   We generally rely on Personal Data provided by you (or your authorised representative). 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 email at the contact details provided in Section 13 below.

12. Access and Correction of Personal Data

Right of Access and Correction

12.1.   If you wish to make (a) an access 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, or (b) a correction request to correct or update any of your Personal Data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided in Section 13 below.

Administrative Fees

12.2.   Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

Response Timeline

12.3.   We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Scope of Access

12.4.   Please note that depending on the request that is being made, we will only need to provide you with access to the Personal Data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the Personal Data that our organisation has on record, if the record of your Personal Data forms a negligible part of the document.

13. Data Protection Officer

Contact Information

13.1.   You may contact our Data Protection Officer via email (fion.lek@nharp.com) if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request relating to the handling of your Personal Data.

14. Effect of Privacy Policy and Updates

Relationship with Other Policies

14.1.   This Privacy Policy applies in conjunction with any other policies, procedures, standards, notices, contractual obligations, and consents that apply in relation to the collection, use, and disclosure of your Personal Data by us.

Amendments and Effective Date

14.2.   We may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable laws and regulations (including any updates to MAS notices and guidelines), or for other operational, legal, or regulatory reasons. The revised version will be posted on our Website and will be effective once posted. Where required by applicable law, we will notify you of material changes to this Privacy Policy through other appropriate means. Please review this page regularly for updated information on our policies and practices regarding the handling of your Personal Data.

Last updated: 3 March 2026