TERMS OF USE

This website (“Website”) is directed at Accredited Investors and Institutional Investors (“Permitted Investors”) as defined under the Securities and Futures Act (Chapter 289) of Singapore (the “Act”).

These Terms of Use set out the terms on which users may use this Website, whether as a guest or a registered user, and apply to every page on this Website, whether or not such pages are individually disclaimed. Please read these Terms of Use carefully before using this Website. By using this Website, users agree to accept these Terms of Use and to abide by them. Where users do not accept these Terms of Use, and do not intend to be bound by them, they are requested to cease using this Website, and should exit it immediately.

AR Capital Pte Ltd ("AR Capital") reserves the right to amend these Terms of Use from time to time, and any continued use of the Website after such amendment(s) will represent an agreement by the user to be bound by the Terms of Use as amended.

Intended Audience
The contents of this Website are intended as a source of general information for Permitted Investors only. It is not intended for use by retail investors. Where a user is not a Permitted Investor, they are requested to cease using this Website, and should exit it immediately.

The contents of, and information from, this Website is not to be used in any jurisdiction where such use is prohibited by law and must not be used in any way that would be contrary to any local or other applicable law or regulation.

None of the funds are to be promoted in any jurisdiction where to do so would not be permitted.

Intellectual Property Rights
The copyright in and to the contents of this Website is owned or licensed for use by AR Capital. No part or parts of this Website or its contents may be reproduced, distributed, published, modified, displayed, broadcast, hyperlinked or transmitted in any manner or by any means stored in an information retrieval system without the prior written consent of AR Capital.

Any trade and/or service marks displayed on this Website are the sole and exclusive property of AR Capital and/or other relevant third parties. No right or licence is given for any reproduction or use of any such trade and/or service marks.

Disabling Programmes
Users hereby undertake that they shall not use any computer code that would damage or corrupt the data or integrity of data, storage media, other computer programs or computer systems or network or disrupt, disable, harm, interfere or otherwise impede in any manner the operation of or communications between computer hardware, software, firmware, computers, computer systems or networks (hereinafter referred to as “Computer Virus”), device, software or routine to interfere or attempt to interfere with the proper working of this Website, nor shall a user take any action that imposes an unreasonable or disproportionately large load on this Website or its associated infrastructure (including any computers hosting or connected to the Website).

Users hereby undertake to ensure that the computer, mobile, wireless and other equipment used to access this Website are well-maintained and are free from any Computer Virus, device, software or routine which may cause harm or damage, including but not limited to the installation of anti-virus programmes to prevent such equipment from acquiring and/or transmitting any such Computer Virus, device, software or routine.

Users agree that AR Capital shall not be liable for any defect or default in any equipment or computer or system interferences, Computer Virus or defects that may interfere with this Website, the telecommunication or computer system of the user, or that of AR Capital’s, any certification authority, Internet service provider, telecommunication service provider or other service provider.

User Identification Code
Users may be provided with a user identification code and password to access certain pages of this Website. Users are to treat this information as confidential and must not disclose it to any third party or allow any third party to access this Website using such user identification code or password. Users agree to notify us immediately if they suspect any unauthorised use of this Website or of their user identification code or password.

Termination of Access
AR Capital reserves the right, in its sole discretion, to deny any user access to the Website, or immediately suspend or terminate their access to the Website, or to disable any user identification code or password (whether chosen by the user or allocated by AR Capital) at any time if their use of the Website breaches these Terms of Use in any manner.

Governing Law
These Terms of Use shall be governed by and construed in accordance with the law of the Republic of Singapore.

AR CAPITAL DATA PROTECTION POLICY

The Personal Data Protection Act 2012 of Singapore (“PDPA”) came into force on 2 July 2014. AR Capital takes its obligations under the PDPA seriously and is committed to safeguard any personal information that has been, and will in future be, provided to it in its role as Investment Manager to its managed portfolios.

This Policy sets out the purposes for which AR Capital will collect, use, disclose and process personal data.

Collection of Personal Data
“Personal data” is data that can be used to identify a natural person. Examples of personal data that AR Capital may collect are:
(a) personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
(b) specimen signatures;
(c) financial details;
(d) employment details;
(e) tax information;
(f) information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets; and
(g) banking information.

Generally, AR Capital obtains personal data by virtue of its role as Investment Manager to its managed portfolios, where the relevant Fund Administrators share subscription and other account information with AR Capital to facilitate the management of the various portfolios, and compliance with AR Capital’s obligations under applicable anti-money laundering and countering the financing of terrorism laws, regulations or directives.

Use of Personal Data
AR Capital may use personal data reasonably in relation to its core business, which use includes for:

(a) the provision of investment management services to its managed portfolios;
(b) assessing and processing subscriptions, and other instructions or requests from investors in its managed portfolios;
(c) communicating with investors in its managed portfolios, including the provision of monthly fact sheets and other investor notifications;
(d) managing its business operations, and complying with internal policies and procedures;
(e) responding to queries or feedback from investors in its managed portfolios, and addressing or investigating any complaints, claims or disputes;
(f) verification of identity for the purposes of meeting compliance obligations under applicable anti-money laundering and countering the financing of terrorism laws, regulations or directives;
(g) complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities, or other agencies of competent authority;
(h) enforcing any obligations that may be owed to AR Capital;
(i) financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes; and
(j) seeking any professional advice, including legal advice.

AR Capital may also use personal data for the purposes set out in the various terms and conditions of the respective subscription forms of any fund in its managed portfolios.

Use of Personal Data for Marketing Purposes
AR Capital may use personal data to inform on the launch of new funds that may be of interest to the existing investors in its managed portfolios, for which such existing investors may be eligible.

In doing so, AR Capital will comply with the PDPA and any other applicable data protection laws and regulations. Upon request by any person, AR Capital will cease to use that person’s personal data for marketing purposes.

Disclosure of Personal Data
AR Capital may from time to time, and in compliance with all applicable laws, disclose personal data to any of the managed portfolios, the relevant Fund Administrators, or to other third parties, whether located in Singapore or elsewhere, in order to carry out the purposes set out above. Where personal data is disclosed to such parties, AR Capital shall take reasonable steps ensure that any such data is kept confidential and secure.

AR Capital may on occasion transfer, store, process and/or deal with personal data outside Singapore, and in doing so, will comply with the PDPA and other applicable data protection and privacy laws, including taking reasonable steps to prevent the unauthorised access, collection, use and disclosure of personal data.

Websites
AR Capital’s website may contain links to other websites which are not maintained by AR Capital. For the avoidance of doubt, this Policy shall only apply to AR Capital’s website, and shall not extend to the use of any third party website.

Access and correction
Where permitted under applicable law, AR Capital will allow access and/or corrections to personal data in its possession or under its control.

Retention of Personal Data
AR Capital will retain personal data as long as the purpose for which such data was collected remains, and until it is no longer necessary for any other legal or business purpose.

Data Protection Officer
AR Capital will make this Policy available upon request, and has appointed a Data Protection Officer to address all queries and feedback on AR Capital’s data protection obligations.

Contact details for AR Capital’s Data Protection Officer are: Ms Jasmine Lee Tel: (+65) 6323 0521 Email: LeeJ@arcapital.com.sg

Amendments and Updates
AR Capital may amend this Policy from time to time to ensure that consistency with any developments in the way AR Capital uses personal data, or to comply with any changes to the laws and regulations applicable to AR Capital. Updates to this Policy will be made available upon request. All communications and dealings with AR Capital shall be subject to the latest version of this Policy in force at the relevant time.