01 Who We Are
XEQ Capital Private Limited (UEN 201905093E) is a capital markets services licensee (CMS Licence No. CMS101602) regulated by the Monetary Authority of Singapore (MAS). Our registered address is 76 Playfair Road #06-01 LHK2, Singapore 367996.
We are the data controller for personal data collected through this website and, where applicable, through our investor onboarding process.
02 Scope
This policy applies to personal data collected via xeqcap.com and any direct communications initiated through it. It does not apply to third-party websites linked from this site. Those sites operate under their own privacy terms.
03 Data We Collect
Web contact data - collected when you submit an enquiry or subscribe to communications:
- Name, email address, organisation, and message content
- IP address, browser type, and page interaction data (via server logs and cookies)
Investor onboarding data - collected after initial contact, where required by MAS regulations and the Securities and Futures Act 2001 (SFA):
- Government-issued identification (NRIC, passport)
- Source of wealth and source of funds documentation
- Tax residency and related declarations
- Accredited Investor assessment information
Investor onboarding data is collected under a separate legal obligation and is not governed by consent. Collection is mandatory for regulatory compliance.
04 Legal Basis for Processing
- Web contact data: Consent (PDPA s.13) - you provide this voluntarily when contacting us
- Investor onboarding data: Legal obligation - required under MAS Notice SFA 04-N02, the Monetary Authority of Singapore Act, and the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (CDSA)
- Service delivery: Contractual necessity - to fulfil obligations under any investment management agreement
05 How We Use Your Data
- To respond to your enquiry or request
- To send communications you have consented to receive
- To conduct investor due diligence and onboarding as required by law
- To fulfil obligations under any investment management agreement
- To comply with applicable laws, regulations, and regulatory directions
We do not sell, rent, or trade your personal data to third parties for marketing purposes.
06 Disclosure of Personal Data
We may disclose your personal data to:
- Regulators and law enforcement - including MAS, the Suspicious Transaction Reporting Office (STRO), the Singapore Police Force, and IRAS, where required by law or regulatory direction. Such disclosures do not require your consent.
- Service providers - including fund administrators, custodians, legal counsel, compliance consultants, and IT service providers engaged to support our operations. These parties are bound by confidentiality obligations.
- Professional advisers - on a need-to-know basis in connection with a specific transaction or legal matter.
07 Overseas Transfers
Where personal data is transferred outside Singapore - for example, to a fund administrator or custodian operating in another jurisdiction - we take steps to ensure the recipient provides a standard of protection comparable to PDPA requirements, consistent with Section 26 of the PDPA. We will not transfer your data overseas without a lawful basis for doing so.
08 Retention
- Web contact data: Retained for up to 2 years from last contact, or until you withdraw consent, whichever is earlier
- Investor onboarding and transaction data: Retained for a minimum of 5 years from the end of the business relationship, as required under MAS Notice SFA 04-N02 and the CDSA
Erasure requests in respect of legally mandated retention periods cannot be fulfilled until the applicable retention period has expired.
09 Cookies
This website uses functional and analytical cookies to support site performance and understand aggregate usage patterns. We do not use behavioural advertising or cross-site tracking cookies. You may disable cookies in your browser settings; doing so will not affect your ability to access the site.
10 Your Rights
Under the PDPA, you have the right to:
- Access - request a copy of personal data we hold about you
- Correction - request correction of inaccurate or incomplete data
- Withdrawal of consent - withdraw consent for non-mandatory processing at any time, without affecting the lawfulness of prior processing
- Data portability - request that data you provided to us be transmitted to another organisation in a machine-readable format, where technically feasible (PDPA s.26F)
These rights are subject to applicable legal exceptions, including data we are required to retain under MAS regulations or other legislation.
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
11 Security
We implement reasonable administrative, technical, and physical safeguards to protect personal data against unauthorised access, disclosure, alteration, or loss. In the event of a data breach that is notifiable under the PDPA, we will notify the Personal Data Protection Commission (PDPC) and affected individuals within 3 business days of assessment, as required under the PDPA mandatory breach notification obligation.
12 Changes to This Policy
We may update this policy from time to time. The effective date at the top of this page reflects the most recent revision. For material changes affecting how we process investor data, we will notify affected individuals directly.
13 Contact
For privacy-related enquiries, access or correction requests, or complaints:
If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission (PDPC) at pdpc.gov.sg/complaints.