Privacy Policy

1. Why are you seeing this notice?

The Privacy Policy provides specific details of how Altive Limited and its employees (“Altive”, “we”, “us” or “our”) treat any Personal Data you provide us when you visit the Altive website (“Site”) and use the services provided to you at the Site. Altive is committed to protecting your privacy information in accordance with applicable laws and regulation, including without limitation to the Hong Kong Personal Data (Privacy) Ordinance (Cap 486), Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore and Privacy Act 1988 of Australia, as amended from time to time.

“Personal Data” has  its respective meaning given in the Hong Kong SAR, Singapore, Australia or other relevant jurisdiction data protection legislation, as the context may require, and includes any information relating to an identifiable individual (such as name, address, date of birth or economic information).

2. Who is providing this notice?

This Privacy Policy is made on behalf of Altive. We do not request from you more information than necessary for us to process your application or participation through the Site. We will take all practical steps to ensure that your personal data will be protected against unauthorised or accidental access.

By submitting your personal data to us, you agree to the processing as set out in this Privacy Policy. You also agree to the purposes for collection of information and data set forth by the Altive.

We will not release any personal information and data collected from you to anyone without the prior consent of the relevant user(s) of the Site except to the authorized persons listed under Section 6 below.

We will take all practical steps to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure while the data is under our control. We would also set out certain measures at the discretion of the company on how to use and protect your Personal Data - but only to the extent that we have informed you about the use or are otherwise permitted by applicable law to do so.

3. What Personal Data do we collect about you?

In the course of using the Site, you may be asked to provide personal information and/or data. In order to have the benefit of enjoying various services offered by us, it may be necessary for you to provide Altive with your personal information. The types of Personal Data we process, hold and share depends on the product or service you have with us and the nature of your investment. This can include or be related to:

• Name
• Contact information
• Income and asset
• Biometric data
• Assets and investment experience
• Risk tolerance and transaction history
• Investment activity
• Activity on the Site
• Accounts at other institutions

Certain non Personal Data, which does not identify you, may also be collected when you use the Site, including the type of Internet browser and operating system you use, other navigational clickstream data, etc.

The Personal Data collected about you will help us provide you with a better service and facilitate our business relationship. The personal data collected may be collected in an online or offline content, and may be combined together or updated in accordance to our Private Policy.

4. Where do we obtain your Personal Data?

We will collected, or have collected, Personal Data about you from a number of sources, both directly and indirectly:

You provided your Personal Data to us:

• from the forms and any associated documentation that you complete when subscribing for an interest in Altive. This can include information about your name, address, date of birth, passport details or other national identifier, your income, employment information and details about your investment or retirement portfolio(s)
• when you undergo certain verification checks and submit identity information to us
• when you provide it to us in correspondence and conversations
• when you make transactions with respect to Altive
• when you purchase securities from us and/or instruct us to undergo transactions on your behalf

Other methods we obtain your Personal Data includes:

• publicly available and accessible directories and sources
• professional partners such as private banks or family offices of whom you may be a client
• bankruptcy registers
• tax authorities, including those that are based outside Hong Kong SAR/Singapore/Australia if you are subject to tax in another jurisdiction
• governmental and competent regulatory authorities to whom we have regulatory obligations
• credit agencies
• fraud prevention and detection and anti-money laundering agencies, organisations and service providers

5. Why do we process your Personal Data?

The Purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:

(I) For Contracts and Agreements

It is necessary to perform our contractual obligations with you to:

• administer, manage and set up your investor account(s) to allow you to purchase your holding (of interest) in our Fund
• meet the resulting contractual obligations we have to you
• facilitate the continuation or termination of the contractual relationship between you and Altive
• facilitate the transfer of funds, and administering and facilitating any other transaction, between you and Altive

(II) In Compliance with Applicable Laws and Regulations

For making disclosures when required by law, regulation, or court order of any jurisdiction and/or requested by any government, regulatory or law enforcement authority or administrative organisation, which may be within or outside Hong Kong SAR/Singapore/Australia. It is necessary for compliance with an applicable legal or regulatory obligation to which we are subjected to:

• undertake our client and investor due diligence, and on-boarding checks
• carry out verification, know your client (KYC), terrorist financing and anti-money laundering checks
• verify the identity and addresses of our investors (and, if applicable their beneficial owners)
• comply with requests from regulatory, governmental, tax and law enforcement authorities
• surveillance and investigation
• carry out audit checks
• maintain statutory registers
• prevent and detect fraud

(III) For our legitimate interest

For our legitimate interests or those of a third party to:

• manage and administer your holding in any funds in which you are invested, and any related accounts on an ongoing basis
• assess and process any applications or requests made by you
• open, maintain or close accounts in connection with your investment in, or withdrawal from, Altive
• send updates, information and notices or otherwise correspond with you in connection with your investment in Altive
• address or investigate any complaints, claims, proceedings or disputes
• provide you with, and inform you about, our investment products and services
• monitor and improve our relationships with investors
• comply with applicable regulatory obligations
• manage our risk and operations
• comply with our accounting and tax reporting requirements
• comply with our audit requirements
• assist with internal compliance with our policies and process
• ensure appropriate group management and governance
• keep our internal records
• prepare reports on incidents / accidents
• protect our business against fraud, breach of confidence, theft of proprietary materials, and other financial or business crimes (to the extent that this is not required of us by law)
• analyse and manage commercial risks
• seek professional advice, including legal advice
• enable any actual or proposed assignee or transferee, participant or sub-participant of the partnership’s or Fund vehicles’ rights or obligations to evaluate proposed transactions
• facilitate business asset transactions involving Altive partnership or Fund-related vehicles
• monitor communications to/from us using our systems
• protect the security and integrity of our IT systems

(IV) From Your consent

We rely on explicit consent to enhance your user experience on the platform to:

• Track & analyse platform activity and engagement with Altive media and publications
• Send you marketing and promotional messages related to the alternative investments industry and related Altive products
• Share news and updates in response to your enquiries
• Notify you of any changes to this Site or an Event

We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes (or purposes as specified in a personal information collection statement when we collect your Personal Data) without your prior consent.

We will monitor communications where the law requires us to do so. We will also monitor where we are required to do so to comply with our regulatory rules and practices and, where we are permitted to do so, to protect our business and the security of our systems.

6. Disclosure and Transfer of Personal Data

To facilitate the purposes mentioned under “5. Why do we process your Personal Data”, we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Hong Kong/Singapore/Australia, and your Personal Data may be transferred within or outside Hong Kong/Singapore/Australia. These third parties may include the following:

(I) Tax authorities

• to comply with applicable laws and regulations
• where required by Hong Kong SAR/Singapore/Australia tax authorities (who, in turn, may share your Personal Data with foreign tax authorities)
• where required by foreign tax authorities, including outside of the Hong Kong SAR/Singapore/Australia

(II) Service providers or professional advisers

• delivering and facilitating the services needed to support our business relationship with you
• supporting and administering investment-related activities

In exceptional circumstances, we will share some or all of your Personal Data with:

• competent regulatory, prosecuting and other governmental agencies or litigation counterparties, in any country or territory
• organisations and agencies – where we are required to do so by law
• third parties – who provides administrative, marketing, research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to support Altive’s business, where we have obtained your specific consent to do so in relation to certain promotional offers or other limited time programs that may be available on the Altive platform from time to time

7. Do you have to provide us with this Personal Data?

Where we collect Personal Data from you, we will indicate if:

• provision of the Personal Data is necessary for our compliance with a legal obligation; or
• it is purely voluntary and there are no implications for you if you do not wish to provide your data with us.

Unless otherwise indicated, you should assume that we require the Personal Data for business and/or compliance purposes.

Certain Personal Data we request, or have requested, is necessary for us to perform our contract with you as part of our services as stated in the Terms and Conditions. If you do not wish to provide us with this Personal Data, it may affect our ability to provide our services to you.

8. Use of Personal Data in Direct Marketing

If we intend to use your Personal data for direct marketing purposes, we will first obtain your consent (or an indication of no objection) before doing so. In this respect, please note that:

(i) your name, contact details, product information, financial background, and demographic data held by us may be used by us in direct marketing from time to time;

(ii) financial, investment, and related services and products may be marketed;

(iii) the above services, products, and subjects may be provided by or solicited by Altive and/or third party financial institutions with whom Altive contracts such as banks, securities contractors, and investment contractors;

(iv) in addition to marketing the above services, products and subjects itself, we also intend to provide the data described in (i) above to all or any of the persons described in paragraph (iii) above for use by them in marketing those services, products and subjects, and we require your written consent (which includes an indication of no objection) for that purpose;

(v) in connection with (iv) above, we may receive money or other property in return for providing the data to the persons described in (iii) above for use by them in direct marketing (including revenue / benefit sharing arrangements between us and such persons).

If you agree to receive marketing communications but do not wish to receive them in the future, you may opt out of receiving them at any time, free of charge, by notifying us through the contact information provided in “15. Contact Us”.

9. Sending your Personal Data internationally

We may transfer your Personal Data to our group members, members of Altive’s partnership and related parties, and to third party service providers outside of Hong Kong SAR, Australia, or Singapore, which may not have similarly strict data protection and privacy laws. By continuing to visit our website you agree to and are deemed to be consent to the aforementioned transfer of Personal Data.

10. Consent – and your right to withdraw it

With the exception of the limited instances described above, we do not generally rely on obtaining your consent to process your Personal Data.

If we do, you have the right to withdraw this consent at any time.

Please contact us or send us an email at privacy@altivecapital.com at any time if you wish to do so.

We may revise this Private Policy from time to time and we encourage you to review our Privacy Policy periodically to be informed of how we collect, store and use your information. You agree that by continuing to access or use this Site, with or without notice from us, you consent to the changes to this Privacy Policy.

11. Retention and Deletion of your Personal Data

Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us under a reasonable security arrangement in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above.

• We will generally retain Personal Data about you throughout the life cycle of any investment you are involved in
• Some Personal Data will be retained after your relationship with us ends subjected to the discretion of the company

We will usually delete your Personal Data (at the latest) after you cease to be an investor in any fund and there is no longer any legal or regulatory requirement or business purpose for retaining your Personal Data.

12. Your rights

You are entitled to access or correct your Personal Data held by us. You have certain data protection rights, including:

• the right to access your Personal Data
• the right to restrict the use of your Personal Data
• the right to have incomplete or inaccurate Personal Data corrected
• the right to ask us to stop processing your Personal Data
• the right to require us to delete your Personal Data in some limited circumstances
• the right in some circumstances to request for us to “port” your Personal Data in respect of such relationship in a portable, re-usable format to other organisations (where this is possible).

If you would like to exercise any of the rights, or if you believe that any of your Personal Data which we collect and maintain is inaccurate or would like to request for information regarding our policies and practices and the kinds of Personal Data held by us, please contact us through the methods outlined in “15. Contact Us”.

13. The use of cookies on our website

Upon visiting our Site, we may use cookie files to store and track information about you and your preferences. A cookie is a small text file that transfers from our website  to your computer's or device’s hard disk. We use cookies to make the navigation and use of our website as user-friendly as possible. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. However, if you disable cookies or refuse to accept a request to place a cookie, certain functionalities on our websites may not be available.

Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.

After your successful login to the protected area, we require the cookies to identify and authorise you for the entire duration of your visit. We are not able to draw any references to customers with the cookies. You can deactivate the option to store these cookies at any time in the system preferences of your browser and delete any existing cookies. You may disable cookies in your browser, but certain functionalities of the Site may not work if cookies are disabled.

14. Data Processing Details

Personal Data is collected for the following purposes:

• Analytics
• Platform Services and Hosting
• Tag Management
• Interaction with Data Collection Platforms and Other Third Parties
• Managing Data Collection and Online Surveys
• Registration and Authentication
• User Database Management

These services include but is not limited to:

• Amazon Web Services
• Google Analytics
• Google Tag Manager

15. Contact Us

We take your concerns very seriously. We encourage you to bring it to our attention if you have any concerns about our processing of your Personal Data. You may contact us if you wish to understand more about this Privacy Policy. Our contact details are below:

Contact us by email at privacy@altivecapital.com.

Contact us in writing using this address:

Unit 4612-13, 46/F, The Center,

99 Queen's Road Central,

Central, Hong Kong

Attention to: Head of Legal & Compliance

16. Changes to this Data Privacy Notice

We may revise this Privacy Policy from time to time and we encourage you to review our Privacy Policy periodically so that you are always informed of the way we collect and use Personal Data.

THIS DATA PRIVACY NOTICE WAS LAST UPDATED ON SEPTEMBER 2021.