Variable Capital Company (VCC) Fund

The information provided herein is for reference only and shall not constitute or be construed as constituting an invitation to buy or sell or the solicitation of an offer to buy or sell any product or services, including financial products and services, in any jurisdiction in which such distribution, offer or solicitation is not authorized or allowed. You should seek independent professional advice before making any investment decision.

It also does not warrant that such information or publication is accurate, up to date or applicable to the circumstances of any particular case.

The Company or its affiliates, any director or employee of the Company or its affiliate shall not be liable for any loss or damages arising from any person's reliance on any information on this website and shall not be liable for any error or omission (including but not limited to errors or omissions made by third parties) of such information.

The Company shall comply with local privacy laws and treat personal data as confidential.

The Company reserves the right to amend this Disclaimer at any time without notice.

Under no circumstances may the information contained herein, or any part thereof, be copied, reproduced, or redistributed without the express permission of the Company.

Personal Data Protection Policy

“Generations Asset Management (SG) Pte Ltd (“GenerationsAM”, together with its related corporations and overseas branches and offices as well as their respective representatives and/or agents, “GenerationsAM”, "us", "we" or "our") recognizes the importance of protecting your personal and financial information when you visit our website located at www.generationsam.sg ("Website"). The following information is designed to help you understand the information collection practices at this Website.

By visiting this Website, you are accepting and consenting to the practices described in this Personal Data Protection Policy. If you do not agree to this policy, please do not use this Website. Please review the Terms and Conditions on the website to learn of other terms and conditions applicable to your use of this Website.

1. Personal Data

In this Personal Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

2. Methods of Information Collection

We may receive your Personal Data you submit to or through our Website. The Personal Data that may be collected at our Website may also include information you provided to us through the "Contact Us" page (which may include your name and email address).

By disclosing your Personal Data to us via our Website, you consent to our collection, use and disclosure of your Personal Data for the purposes as set out in this Personal Data Protection Policy. Failure to provide such Personal Data may result in GenerationsAM being unable to provide you with the services or information requested.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, GenerationsAM collects, uses and discloses your Personal Data for the following purposes:

(a) responding to your queries, requests, feedback and suggestions sent to us;

(b) business administration;

(c) verifying your identity and customer due diligence;

(d) business operation and reporting;

(e) verifying or confirming trade orders or instructions from you or for your account (including but not limited to instructions on fund transfers or remittances);

(f) the provision of information on GenerationsAM products and services to you;

(g) project management;

(h) audit purposes;

(i) complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to GenerationsAM or that it is expected to comply;

(j) to assist in law enforcement and investigations by relevant authorities; and

(k) other directly related purposes.

4. Disclosure of Personal Data

GenerationsAM will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

(a) GenerationsAM’s related corporations and overseas branches and offices;

(b) counterparties and their respective banks in relation to transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of cheques;

(c) third party recipients of reference letters;

(d) companies providing services relating to insurance and/or reinsurance to GenerationsAM;

(e) insurers or brokers in relation to the insurance products or services that you have applied for or purchased;

(f) trustees, attorneys and asset managers appointed by you to manage your account held with GenerationsAM;

(g) referrers who have referred you to GenerationsAM;

(h) any person (1) who provides security or acts as surety for your liabilities and obligations to GenerationsAM or (2) for whom you act as surety or third party security provider;

(i) agents, contractors, vendors, installers, or third party service providers who provide administrative or operational services to GenerationsAM, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to GenerationsAM;

(j) agents, contractors, vendors or other third party service providers in connection with marketing, products and services offered by GenerationsAM;

(k) analytics, search engine providers or third party service providers that assist us in delivering our products, services, websites and platforms as well as improving and optimising the same;

(l) your employers which are financial institution, for their internal surveillance or monitoring purposes;

(m) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the GenerationsAM companies;

(n) our professional advisers such as our auditors and lawyers;

(o) third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with GenerationsAM;

(p) relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over GenerationsAM or any GenerationsAM company or over any transaction entered into by you, such as the Monetary Authority of Singapore, Singapore Exchange Limited, the Accounting and Corporate Regulatory Authority, the Insolvency and Public Trustee Office, the Inland Revenue Authority of Singapore and the Commissioner of Charities, as well as to comply with listing and other requirements or directions of Singapore Exchange Limited and/or any other relevant securities exchange;

(q) any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar official who has been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in Singapore or elsewhere, in respect of you or your assets;

(r) third parties who carry out registration of charge or pledge over the assets that you have pledged or charged to GenerationsAM;

(s) corporate service providers or lawyers, who are appointed by you;

(t) financial institutions, brokerage houses, clearing houses, depository, depository agents, managers, administrators, fund houses, registrars, custodians, external banks, the Central Depository, nominee banks and investment vehicles in relation to asset management and investment product settlement processing;

(u) collection and repossession agencies in relation to the enforcement of repayment obligations for loans;

(v) any person to whom GenerationsAM or any of the GenerationsAM companies is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to GenerationsAM or any of the GenerationsAM companies, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which GenerationsAM or any of the GenerationsAM companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of GenerationsAM or any of the GenerationsAM companies with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside Singapore and may be existing currently and in the future; and/or;

(w) any other party to whom you authorise us to disclose your Personal Data to.

5. Data Security

GenerationsAM will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and take any necessary precautions.

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

6. Retention Period

We will take practicable steps to ensure your Personal Data will not be retained by us longer than is necessary for the fulfilment of the Purposes.”

7. Contacting Us - Withdrawal of Consent, Access and Correction of your Personal Data

If you:

(a) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

(b) would like to obtain access and make corrections to your Personal Data records,

please contact us at info@generationsam.sg