Terms of Use and Privacy Policy
By accessing this website, you acknowledge that you have understood and accepted the following Terms of Use and Privacy Policy (the”Policy”). The Policy is subject to change without notice from time to time. Please read carefully every time before you access this website.
This website may include information regarding the AHP Umbrella Fund SPC’s Funds (the “Funds”) which are not authorized funds by the Securities and Futures Commission (“SFC”) in Hong Kong and are currently registered under the list of restricted schemes maintained by the Monetary Authority of Singapore (“MAS”) under the Securities and Futures Act. The Funds are not authorised or recognised by SFC and MAS and the offer of the Funds are not allowed to be made to the retail public in Hong Kong and Singapore. Specifically, the Funds are only available to accredited/professional and institutional investors as defined under section 4A of the Securities and Futures Act of Singapore (“SFA”), section 1 of Part 1 of Schedule 1 to the Securities and Futures Ordinance (Cap. 571) and Securities and Futures (Professional Investor) Rules (Cap. 571D) of Hong Kong respectively. The contents of this website have not been reviewed by the SFC or MAS. It is your responsibility to be aware of and to observe all applicable laws and regulations of any relevant jurisdiction.
1. NO OFFER / ADVICE / RECOMMENDATION / FIDUCIARY RELATIONSHIP
The information on this website is provided to introduce our company and is provided for information purposes only. This is not an offer, invitation, inducement, advice, recommendation or solicitation for the purchase or sale of the Funds or participate in any investment strategy. Where applicable, the information has been obtained from publicly available sources which Aspen Hill Partners believes to be reliable, but has not independently verified and we do not warrant or guarantee that it is accurate or complete. Investment involves risks. Past performance is no guarantee of future results. You should always consult with your financial, legal and tax advisors before making a commitment to invest.
2. LIMITATION OF LIABILITY
You agree and accept all the terms and conditions when you use this website. Aspen Hill Partners is not liable for any direct or indirect damages, losses or expenses arising from or in connection with the use of this website, including to any hyperlinked page or site or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure.
3. COPYRIGHT
All content on this website is the property of or is licensed to Aspen Hill Partners and is protected by copyright, trademarks or other proprietary rights and laws. Except as otherwise expressly permitted by Aspen Hill Partners and/or the copyright owner by written permission and/or under applicable copyright law, no modification, copying, redistribution, uploading, retransmission, publication or commercial exploitation of downloaded material is permitted.
4. INDEMNITY
By using this website, you agree to indemnify Aspen Hill Partners, its officers, directors, employees, contractors and agents in respect of any claim or third party claim for any direct or indirect injury, damages, losses or expenses that is the direct or indirect result of your use of this website or any information or content therein.
5. USE OF COOKIES
Cookies are data files stored on your browser. The information that the cookies collect, such as the number of visitors to the website, is aggregated and therefore anonymous. The cookies used in connection with this website do not contain any personally identifiable information about you unless you choose to give such information to us for a specific purpose through “Contact Us” or by other means, for example by email, post or telephone. You may refuse to accept cookies on your browser by modifying the settings in your browser or internet security software. Please note that removal of cookies may affect your use and experience of this website.
6. COLLECTION, USE, RETENTION AND DISCLOSURE OF YOUR PERSONAL DATA
Information we collect and how we use your personal data It is Aspen Hill Partners’ policy to protect the privacy of users of this website. Generally we do not collect any of your personal data unless it is provided to us voluntarily by you directly through “Contact Us” or by other means or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”). Any personal data collected from you or your authorized representative (such as name and contact details) will only be used for the specific purposes mentioned at the time of collection or for purposes directly related to those specific purposes (“Specific Purposes”).
Examples of such Specific Purposes include:
• To assist you with your enquiries;
• To communicate with you on matters relevant to your relationship with or interest in our Company;
• To keep you updated about our Company, services and events that may be relevant to you;
• To comply with any applicable rules, laws and regulations, codes or practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and
• Any other purpose relating to any of the above.
How your personal data is retained
We will only retain your personal data for so long as is necessary for fulfilling the purpose for which they were collected. Your data will be erased afterwards.
We will take all practicable steps, in compliance with applicable rules and regulations, to ensure the security of the personal data and to avoid unauthorized or accidental access, erasure or other uses.
Disclosure of your personal data
We generally do not transfer your personal data to places outside Hong Kong or Singapore. However, we may disclose your personal data where such disclosure is required to perform the Specific Purposes or under applicable laws. If we do so, we will obtain your consent for the transfer to be made and we will take reasonable steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to the requirements of data protections laws in Hong Kong or Singapore, as may be applicable.
For site visitors resident in Singapore, if you do not want Aspen Hill Partners to contact you by telephone or SMS, you may register with the Personal Data Protection Commission’s national Do-Not-Call register. Aspen Hill Partners will comply with the requirements under the Singapore Personal Data Protection Act 2012 on screening telephone communications with the Do-Not-Call register.
7. YOUR RIGHT OF ACCESS TO AND TO CORRECT PERSONAL DATA
In accordance with the Personal Data (Privacy) Ordinance of Hong Kong and the Singapore Personal Data Protection Act 2012, you are entitled to check whether we Aspen Hill Partners holds data about you and to request access to those data. If any of the data is incorrect or inaccurate, you have the right to correct or update them. You also have the right to withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the Specified Purposes. A fee may be charged for processing any of your data access or correction requests.
If you have any questions relating to your personal data or our privacy policy, please contact us through the communication channels set out in the “Contact Us” section or in the following manner.
For Hong Kong:
Compliance Officer Aspen Hill Partners (Hong Kong) Limited
10F, St. John’s Building, 33 Garden Road, Central, Hong Kong
Tel: (852) 3622 3851
E-mail:compliance@aspenhp.com
For Singapore:
Data Protection Officer: Terence Teo (CEO) Aspen Hill Partners (Singapore) Pte. Ltd.
30 Leng Kee Road #03-56, Singapore 159100
Email: ahp@aspenhp.com.sg
8. GOVERNING LAW
The Policy shall be subject to, governed by, and construed in accordance with the laws of Hong Kong, and you hereby submit to the non-exclusive jurisdiction of the Hong Kong Courts. For site visitors from Singapore, you will be subject to the laws of Singapore and submit to the non-exclusive jurisdiction of the Singapore Courts.
Personal Data Protection Policy – Singapore
Aspen Hill Partners (Singapore) Pte Ltd (“AHP”) is committed to protecting its potential investors’ and clients’ personal data in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and other applicable data protection laws.
“Personal data” means any data about an individual who can be identified from that data, as more specifically defined under the PDPA and other applicable data protection laws.
This Data Protection Policy outlines how AHP collects, uses, stores and protects personal data. The Policy also describes how you can control the personal data that AHP holds on you, and your rights on your personal data, where applicable.
AHP may from time to time update this Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Please check regularly for updated information.
1. Consent
You agree and consent to AHP collecting, using, disclosing and/or retaining your personal data in the manner set forth in this Data Protection Policy.
2. Personal Data that AHP may Collect from Users of the Website
AHP collects information about how to contact you and your interest in AHP. When visiting the Website, you can forward information to AHP about yourself, e.g. name, email address, phone number and any other information you wish to provide to AHP through “Contact Us”.
3. Purpose of the Collection, Use and Disclosure of Personal Data
Generally, AHP collects, uses and discloses your personal data for the following purposes:
• To assist you with your enquiries;
• To communicate with you on matters relevant to your relationship with or interest in AHP; • To keep you updated about our Company, services and events that may be relevant to you;
• To comply with any applicable rules, laws and regulations, codes or practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and
• Any other purpose relating to any of the above.
AHP may share your personal data with third parties only with your consent for the purpose for which the information was collected or to be used and any other reasonable purposes, for legal reasons, or where permitted under the PDPA and other applicable laws.
4. Retention of Your Personal Data
AHP shall retain your personal data for as long as is necessary for the purposes stated in Section 3 above and take reasonable measures to delete any personal data that is no longer necessary for the intended purposes.
5. Security and Confidentiality
All your personal data is kept confidential and AHP takes all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate controls.
6. How you can control your information
If you do not want AHP to contact you by telephone or SMS, you may register with the Personal Data Protection Commission’s national Do-Not-Call register. AHP will comply with the PDPA’s requirements on screening telephone communications with the Do-Not-Call register.
7. Your rights regarding your personal data
You are responsible for ensuring that the information you provide is accurate, complete, and not misleading. Subject to the PDPA and any other applicable laws, you may have the following rights:
• Access to your personal data
• Rectify errors or omissions in your personal data
• Erasure of your personal data
• Restrict processing of your personal data