Privacy Policy

Last Modified: June 01, 2018

1. Scope of This Privacy Policy

This Privacy Policy outlines what types of information are collected from our account holders, users, and visitors (“you”, “your” or “User”), to whom it may be disclosed, and how that information may be used by ALT Capital Pte Ltd. (“ALT Capital”, “we”, “our” or “us”), as each of the foregoing relates to your use of ALT Capital’s Web Sites, software, applications, online services and products (collectively, the “Sites or Services”).

By using the Sites or Services, you agree that you have read, understood, and consented to this Privacy Policy, our Terms of Use, all amendments, addenda, and licenses to each of the Privacy Policy and the Terms of Use (collectively, the “Agreement”). By using our Sites or Services, you consent to ALT Capital’s use of your information and data as described in the Agreement. If you do not agree to the terms of this Privacy Policy, do not use the Sites or Services.

Please check back periodically as ALT Capital reserves the right to change, modify, add, or remove portions of this Privacy Policy after providing notice to you. The form of such notice is determined at our discretion. For more information, please see Section 16 below.

The official language used by ALT Capital is English; in the event of a conflict between the English language version of this document and any version translated into any other language, the English language version shall prevail.

2. Definitions

“Account” means a User Account.

“Agreement” means this Privacy Policy, our Terms of Use, all amendments, addenda, and licenses to each of the Privacy Policy and the Terms of Use.

“ALT Capital” (“we”, “our” or “us”) means ALT Capital PTE LTD, a Singapore limited liability company.

“Authorization” means the set of rights and privileges on the Web Site assigned to a User by ALT Capital.

“Content” means all information and other materials present on the Sites, including ALT Capital’s products and services, text, images, photos, trading ideas, opinions rumors, advice, charts, financial information, ratings, reviews, or similar information.

“Controller” means a person or entity who, either alone or jointly, determines the purposes and means of the processing of Personal Data, controls the data, and is responsible for it, and does so with respect to persons (Data Subjects) who are physically located in the European Union.

“Cookies” means small files that are placed on your hard drive for identification purposes. These files are used for site registration and customization the next time you visit us.

“Credit Card Information” means that information required to process a credit card payment, including name of the debit card holder, credit card number, CVV number, expiration date, billing address, phone number, and email address.

“Data” means User Data.

“Data Subject” means an identified or identifiable natural person.

“Debit Card Information” means that information required to process a debit card payment, including name of the debit card holder, debit card number, CVV number, expiration date, billing address, phone number, and email address.

“Designated Agent” means the ALT Capital representative identified in Section 2 of the Terms of Use.

“EU” means the European Union.

“EU User” means a User who resides in the European Union.

“Feedback” means your comments, feedback, information, or other materials regarding the Sites and Services.

“GDPR” means the General Data Protection Regulation, adopted as Regulation (EU) 2016/679 of the European Parliament on April 14, 2016. The GDPR is effective on May 25, 2018.

“Log Data” means information that your browser sends whenever you visit a website; this information is automatically recorded by our servers.

“Personal Data” means any information relating to an identified or identifiable natural person.

“Privacy Officer” means the individual at ALT Capital who is responsible for implementation of this Privacy Policy.

“Sensitive Data” means data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data that concerns health, or data that concerns a natural person’s sex life or sexual orientation.

“Terms” means ALT Capital’s Terms of Use.

“User” means a natural or legal person over the age of 18 who has accepted ALT Capital’s Terms of Use and has been authorized to use the Account on behalf of himself/herself.

“User Account” means an account of a User that is registered with ALT Capital that has access to specified Services of ALT Capital.

“User Data” means trading information generated by you and other Users (whether aggregated or otherwise).

“User Submission” means any comment, or personal information, including ideas, suggestions, opinions, comments, observations, or other material, posted to any public form on our Sites or Services, including any publication, article, social network page, blog, chat room, or other such forum.

“Visitor” means a legal or natural person who visits our Site without having an Account.

“You” or “Your” means User or User’s.

3. ALT Capital as Data Controller / Privacy Officer

For users in the EU, ALT Capital is a Controller, as defined in the GDPR, of your Personal Data. Should you have questions or requests regarding your Personal Data, you may contact ALT Capital’s Privacy Officer at any time at info@altcapitalfund.com. or write to us at:

Privacy Officer

ALT Capital, PTE LTD,

The Great Room, One George Street,

#10-01 Singapore 049145

4. Designated Agent

ALT Capital’s Designated Agent for purposes of the Digital Millennium Copyright Act may be contacted at info@altcapitalfund.com. Please refer to “Designated Agent” in the subject line of your email or write to us at:

Designated Agent: ALT Capital Pte Ltd, The Great Room, One George Street, #10-01 Singapore 049145

5. Collection of Personal Data

You may choose to register an account with our Sites or Services and we may collect certain personal information from you in order to provide services and to complete transactions.

When you register with us through our Sites or Services, we will ask you for Personal Data. Personal Data may include your name, phone number, email address, postal address, username, password, zip code, and age (optional).

Our Sites or Services may provide links to third-party applications, products, services, or web sites for your convenience and information. If you access those links, you will leave our Sites or Services. We do not control those third party sites and services or their privacy practices, which may differ from our practices. We do not endorse or make any representations about third-party sites. Any information you choose to provide to, or that is collected by those third parties is not covered by the Agreement. We cannot control the activities of third parties, and we have no responsibility for any use of the information provided by such third parties. Any information you choose to provide to third party web sites or products will be governed by the policies of those third party web sites and products.

If you post a User Submission to any public forum on our Sites or Services, including any publication, article, social network page, blog, chat room, or other such forum, please be aware that any Personal Data disclosed in your User Submission can be read, viewed, collected, or used by other users of these forums, and could be used to contact you, send you unsolicited messages, or for purposes that neither you nor we control. We may also aggregate all or any part of User Submissions into a resource that we may use, share, or distribute provided that any Personal Data has been anonymized. ALT Capital is not responsible for the Personal Data contained in your User Submission.

6. Legal Basis for Collecting Your Personal Data

Your consent to our Terms of Use and this Privacy Policy constitutes the legal basis upon which we may collect your Personal Data.

7. Purposes for Which We Collect Personal Data / How We Use and Share Your Personal Data / Location of Processing

Purposes for Which We Collect Personal Data

We do not sell your Personal Data to third parties to use for their own marketing purposes. ALT Capital uses the information we collect for the following purposes:

Provide our Services. To provide the services we offer on our Sites and Services, to communicate with you about your use of our Sites or Services, to respond to your inquiries, to provide troubleshooting, and for other customer services designed to make your experience better.
Personalization. To tailor the content and information that we may send or display to you, to suggest personalized help and instructions, and to otherwise personalize your experience while visiting or using our Sites or Services.
Advertising. To display interest-based advertising to you, to improve our advertising and measurement systems so that we can show you more relevant ads, and to measure the effectiveness and reach of ads and services.
Marketing and Promotions. For marketing and promotional purposes, such as to send you news and updates, special offers, and promotions, or other otherwise contact you about products, services, or information we think may interest you, including information about third party products and services.
Analytics. To gather metrics to better understand how users access and use the Sites and Services; to evaluate and improve the Sites and Services; and to develop new products and services.
Comply with the Law. To comply with legal obligations, as part of our general business operations, and for other business administration purposes.
Prevent Misuse. Where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Privacy Policy.

How We Use Your Personal Data

We use the information you provide to offer, manage, and/or improve our Sites or Services, including but not limited to:

improving content
adapting or adding in new features and functionality
providing and improving service and support
delivering relevant advertising
assisting with social sharing functionality
developing new products and services
selecting content to be communicated to you
aggregating certain types of information to better understand or provide better engagement with our Users
contacting you regarding our products or services; and preventing and detecting security threats, fraud or other malicious activity

ALT Capital may share your Personal Data with our affiliates or with third parties, which provide services to us and which agree to keep such Personal Data confidential.

We may employ third party companies and individuals for any of the following:

to facilitate the Sites or Services
to provide the Sites or Services on our behalf
to perform related services, including maintenance, database management, web analytics, and improvement of the features or functionality
to assist us in data analysis

We employ a third party company to process debit, credit, and other payments and to perform related services.

We may collect and compile general information about you and your preferences and interests and use that information as described in this Section. We may share with or sell such information to third parties for these same purposes, but would never do so without your consent. When you sign up for an Account, you will be asked if you consent to us sharing or selling your information. If you do not provide your consent, we will not share with or sell any of your information to third parties.

We retain the right to disclose Personal Data as allowed or required by law. We may also disclose Personal Data under the following circumstances:

to respond to duly authorized information requests of police and governmental authorities
to comply with any law, regulation, subpoena, or court order
to investigate and help prevent security threats, fraud or other malicious activity
to investigate and help prevent a violation of any contractual or other relationship with ALT Capital or the perpetration of any illegal or harmful activity
to enforce and protect the rights and properties of ALT Capital, its affiliates and its business partners
to protect the personal safety of our employees, agents, affiliates, business partners, customers or site users

In the event of a merger, consolidation, or sale or transfer of all or substantially all of the assets of ALT Capital or the ALTQOIN Parties, Personal Data stored in our database will be transferred to the purchasing or new entity. However, the use of this information by any purchasing or surviving entity would be governed by the terms of this Privacy Policy, as amended from time to time, including any amendment after such transaction.

Your information may be transferred to and maintained on computers and servers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, ALT Capital transfers Personal Data to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Personal Data from our Users who reside in the European Union is processed in the United States. ALT Capital shall process such Personal Data in accordance with the requirements of the GDPR.

European Union General Data Protection Regulation 2016/679

European Union General Data Protection Regulation EU 2016/679 (“GDPR”), approved by the European Parliament on April 14, 2016, and effective May 25, 2018, addresses the protection of natural persons located in the EU with respect to the processing of their Personal Data.

GDPR recognizes that Personal Data shall be:

processed lawfully, fairly and in a transparent manner;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which it is processed;
accurate and, where necessary, kept up to date;
kept in a form which permits identification of Data Subjects for no longer than is necessary for the purposes for which the personal data are processed;
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures

As a Controller, ALT Capital shall be responsible for, and shall be able to demonstrate compliance with, the foregoing principles.

Therefore, you have the right:

to request the correction or update of any Personal Data that is incorrect or incomplete; and
to request the erasure of your Personal Data (the right to be forgotten)
to portability of your Personal Data
to object to the processing of your Personal Data
not to be subject to a decision based on automated decision-making, including profiling
to withdraw consent to the processing of your Personal Data
to register a complaint with a supervisory authority (if you are located in the EU)

Unless otherwise prohibited by law, ALT Capital will effect any such request without delay. Where ALT Capital is able to comply with a request for erasure by anonymizing the Personal Data, we will do so.

Under the GDPR, you have the right to be forgotten. If you reside in an EU territory, you may request the deletion of your personal data that we collect, store, or process. When you make your request, we will balance the privacy rights of the individual concerned with the interest of the general public in having access to the information, as well as the right of others to distribute the information. For instance, we may refuse to delete information regarding financial scams or other unlawful activities. In the event ALT Capital receives a request for erasure, or a request to be forgotten, ALT Capital has the obligation to erase the Personal Data without undue delay (and no longer than 30 days after the request is received), where one of the following grounds applies:

The Personal Data is no longer necessary for the purpose for which it was originally collected or processed.
You withdraw your consent to the collection processing of your Personal Data.
You object to the processing and there is no overriding legitimate interest for continued collection or processing of your personal data.
You believe that your Personal Data was unlawfully processed or collected (i.e., in breach of the GDPR).
Your Personal Data must be erased in order to comply with an EU or an EU Member State law to which we are subject.
Such Personal Data was processed in relation to the offer of information society services to a child.

Where Processing of Personal Data Takes Place

Personal Data is processed in the United States of America.

8. Keeping Your Personal Data Secure

To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of the information, ALT Capital utilizes generally accepted industry standards to protect your Personal Data submitted to ALT Capital or relies on the services of third parties to provide the same. However, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your Personal Data.

9. Children’s Privacy

ALT Capital Sites or Services are not intended for use by minors under the age of 18 and are not targeted to children. ALT Capital does not knowingly collect information from children under the age of 16, solicit information from such children, or market products to such children.

10. Sensitive Data

We do not intentionally collect, process, transfer, or store Sensitive Data.

11. Log Data and Cookies

We use cookies and other similar technologies, including log data, on our Sites and Services to distinguish you from other users of our websites and apps (including when you browse third party websites). This helps us to provide you with a good experience when you use our services. We also use cookies and similar technologies to show you more personalized advertising. You may adjust the settings on your browser to refuse cookies but some of our services may not work if you do so.

Our servers also automatically record Log Data which includes information such as your internet service provider, your computer’s internet protocol address, browser type and operating system, referring/exit pages, clickstream data, pages of our Sites and Services that you visit (and the time spent on these pages), information you search for on our Sites or Services, and other statistics. We use this information to monitor and analyze your use of our Sites or Services and to better tailor them to your needs in order to provide you with a better experience.

12. Access to and Accuracy of Your Personal Data

ALT Capital strives to keep your Personal Data accurately recorded. You have the right to access and request the correction, amendment, or deletion of all of your recorded personal information that has been collected by us. If you wish to review your recorded Personal Data, please contact us at:

ALT Capital, PTE LTD
Email: info@altcapitalfund.com
The Great Room, One George Street,

#10-01 Singapore 049145
Attn: Privacy Officer

If you write to us, please include your name, email address, and telephone number and let us know what kind of information you want to see. You may see and copy your information in person, or if you prefer, we will copy and send you your information. If you see any mistakes, let us know and we will review it. If we agree, we will correct our files. If we disagree, you may file a short statement of dispute with us. Your statement will be included with any data we disclose in the future. We will also send the statement to anyone you ask us to who received your information from us in the past two years.

13. Data Retention

ALT Capital retains Personal Data for as long as we reasonably require it for legal or business purposes. In determining data retention periods, ALT Capital takes into consideration local laws, contractual obligations, and the expectations and requirements of our Users. We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. When we no longer need personal information, we securely delete or destroy it.

14. Acceptance of and Modifications to This Privacy Policy

You must affirm that you have read, understand, and accept the terms of this Privacy Policy. If you do not accept the terms of this Privacy Policy, you must discontinue your use of the Sites and Services.

The terms of the Privacy Policy may change from time to time. If we modify our Privacy Policy, we will notify you and post the revised statement here, with an updated revision date. You must affirm that you have read, understand, and accept the revised terms of this Privacy Policy. If you do not accept the revised terms of this Privacy Policy, you must discontinue your use of the Sites and Services.

15. Contact Us

We value your opinion. If you have comments or questions about our Privacy Policy, please send them to our Privacy Officer at info@altcapitalfund.com. You can also write to us at:

ALT Capital, PTE LTD
Email: info@altcapitalfund.com
The Great Room, One George Street,

#10-01 Singapore 049145

Attn: Privacy Officer