TWIN TOWERS VENTURES – PRIVACY STATEMENT FOR WEBSITE

This Privacy Statement was last updated on: 1 May 2024.

Privacy Statement 

Twin Towers Ventures Pte. Ltd. (“Twin Towers Ventures”) is committed to protecting and respecting the privacy and security of your personal data. Twin Towers Ventures are registered in Singapore and our registered address is at 158 Cecil Street, #10-01, Singapore (069545). 

Please read this privacy statement (“Privacy Statement”) carefully to understand our practices regarding your personal data. This Privacy Statement sets out the basis upon which Twin Towers Ventures and its Affiliates  (collectively “Twin Towers Ventures”, “we”, “us” or “our”) collect, use, disclose or otherwise process personal data about you in accordance with the Personal Data Protection Act 2012 (“PDPA”) and applicable law. This Privacy Statement describes:

i) what personal data we collect about you;
ii) how we obtain your personal data;
iii) the basis on which we will process any personal data we collect from you, or that you provide to us, through or in connection with this website and its associated services, including but not limited to email newsletters and TTV’s LinkedIn page (together the “Site”);
iv) how long we keep your personal data;
v) with whom and where we share your personal data;
vi) the transfer of your personal data outside of Singapore;
vii) how we protect your personal data;
viii) your rights regarding your personal data; and
ix) information on our use of cookies.

By visiting the Site, you are acknowledging our practices described in this Privacy Statement. Where necessary under the PDPA and applicable data privacy law, visiting the Site constitutes your consent to our processing your personal data as described in this Privacy Statement. We will only process your personal data in accordance with this Privacy Statement unless otherwise permitted or required by the PDPA and applicable law.

If you are an employee, personnel, consultant, or job applicant of TTV, your personal data will be also processed in accordance with our Employee Privacy Notice.

Our Site may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
If you have any questions, feel free to get in touch via one of the methods set out in the ‘Contact Us’ section below.

(a) Collection and processing of personal data‍

We collect personal data when you provide it to us, through registration, completion of forms, emails, enquiries and requests, and similar situations in which you have chosen to provide the information to us. We also collect personal data while monitoring our technology tools and services, including email communications sent to and from TTV.
The personal data you give us may include:

i) Your basic information – such as your name (including name prefix or title);

ii) Contact information – such as your home address, work address and email address;

iii) Technical information – such as:
information about the device you use to interact with us (including the unique device identifier, hardware model, operating system and version, and mobile network information); and
information from your visits to our websites (including the type of browser and operating system you use, access times, pages viewed, URLs clicked on, your IP address and the page you visited before navigating to our websites); and

iv) Other information – such as personal data you may include in an email that you send to us via the ‘Connect with Us’ section of our Site.

If you choose not to provide such information, it may not be possible for us to respond to your request or enquiry.

We will retain control of, and responsibility for, the use of any personal data you disclose to us. Such personal data shall remain in our possession, or that of data intermediaries and other service providers acting on our behalf.

Please note that we may process your personal data without your knowledge or consent, in compliance with applicable laws, where this is required or permitted by applicable law.

(b) Purposes of use‍
All personal data and other information collected may be used by TTV individually or collectively and may be combined with other information for the following purposes:

i) responding to your enquiries or requests pursuant to your emails, telephone calls, faxes and/or submission of form(s) including on the ‘Connect with Us’ section of our Site;
ii) responding to your job/internship application or your recruitment queries;
iii) responding to and taking follow-up action on complaints;
iv) performing office and operational administrative matters following your request;
v) seeking feedback and comments on TTV’s business and operational matters;
vi) to carry out due diligence or Know-Your-Customer screening activities;
vii) marketing (if, where required, you separately provide your consent to this); and/or
viii) complying with our legal obligations.

Generally, we only use personal data collected through the Site as necessary so that we can pursue these legitimate purposes. We may occasionally seek your consent to use your personal data for these or other specific purposes.‍

(c) Disclosure of your personal data‍

To respond to or process your requests to TTV, we may have to disclose your personal data to any member of our group or to third parties such as our service providers and professional advisors, who will process your personal data in accordance with this Privacy Statement. Your personal data will not be disclosed to any further parties, unless we have obtained your consent or are legally required or permitted to do so.

(d) ‍Transfers of your personal data outside of Singapore

The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us. For the purposes of European data protection laws (where they apply), you should be aware that Singapore and the other countries in which your personal data are located may not have data protection laws which have been acknowledged to ensure adequate protection for personal data for the purposes of those laws.

TTV will take appropriate steps to ensure that your data is treated securely and in accordance with this Privacy Statement, to the standards required by applicable law.

(e) Security‍

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we use a variety of appropriate administrative, organisational, physical and technical approved safeguards and security measures to protect your personal data, in accordance with applicable laws. 

(f) Personal Data retention‍

We may retain your personal data for as long as necessary for the fulfilment of the purposes for which it was collected or to which you have given your consent, except where otherwise permitted or provided for by applicable law. 

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected and are no longer necessary for legal or business purposes.

(g) Right to withdraw consent, request access to, and correction of personal data‍

In accordance with applicable laws, you may have the right to:

i) opt out from processing of your personal data for direct marketing purposes;
ii) withdraw any consent that you may have given (where TTV is processing your personal data based on your consent);
iii) ask TTV about the processing of your personal data, including to request access to your personal data;
iv) to request a copy of any personal data that you have provided to us (where we are processing your personal data on the basis of your consent); and
v) request the correction of the personal data that TTV holds about you,

by sending an email via the details set out in the ‘Contact Us’ section.

Where you are given the option to share your personal data with us, you can always choose not to do so.

This could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (see ‘Purposes of Use’) or that you are unable to make use of the services offered by us. After you have chosen to withdraw your consent TTV may be able to continue to process your personal data to the extent required or otherwise permitted by applicable law.

(h) Cookies‍
The Site uses cookies to distinguish you from other users of our website by storing, generally non-personally identifiable, information (e.g. session information such as the number of times you visit our website and the location from which you are accessing the website).

We reserve the right to track visitors to, and usage of, the Site through “cookies” and similar techniques and to use any resulting information as we determine in our sole discretion.

Therefore, during your use of the Site, TTV may issue to and request from your computer “cookies” to enable more convenient browsing when you revisit the Site.

You may manage your cookies at any time through the cookie settings on the Site. Please note that if you change your settings to opt out of receiving cookies, it will not retroactively delete or remove any previously collected information, but it will prevent your information from being shared through such cookies from that point on.

We use cookies: (i) to track how visitors move around on the Site; and (ii) the purposes described in this Privacy Statement, but they will not generally allow us to obtain information of a personal nature such as your name and address. We will only be aware of such information if you provide the information to us or you have set the preferences in your browser to provide this information automatically.

(i) Contact Us
If you have any questions about our processing of your personal data or would like to make an access or other request, please contact us:

• By email at: compliance@ttv.vc or yilyn@ttv.vc

• By writing at: Data Protection Officer, Twin Towers Ventures Pte. Ltd., 158 Cecil Street, #10-01, Singapore (069545)

(j) Effect of Privacy Statement and Changes to Privacy Statement
We keep this Privacy Statement under regular review, and we may change it from time to time. We encourage you to review this Privacy Statement periodically so that you are aware of any changes. This Privacy Statement was last updated at the date shown at the start.