Privacy Policy

This Privacy Policy (“Policy”) sets out the basis upon which JAN CAP PTE. LTD. (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of Applicants in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we haveengaged to collect, use, disclose or process personal data for our purposes.

APPLICATION OF THIS POLICY

1. This Policy applies to all persons who have applied to us (“Applicants”) for ourThe First Fellows programme (the “Programme”).
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PERSONAL DATA

2. As used in this Policy, “personal data” means data, whether true or not, about an Applicant who can be identified: (a) from that data; or (b) from that data and otherinformation to which we have or are likely to have access.

3. Personal data which wemay collect includes, without limitation, your:

(a) name or alias, gender, year of birth, and nationality;

(b) telephone numbers, email address and other contactdetails;

(c) resume, educational background and qualifications,professional qualifications and certifications and employment references; and

(d) employment and training history.

4. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

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COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

5. We generally collectpersonal data that (a) you knowingly and voluntarily provide for the Programme, or via a third party who has been duly authorised by you todisclose your personal data to us (your “authorised representative”), after (i) you (or your authorised representative) havebeen notified of the purposes for which the data is collected, and (ii) you (oryour authorised representative) have provided written consent to the collectionand usage of your personal data for those purposes, or (b) collection and useof personal data without consent is permitted or required by the PDPA or otherlaws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

6. Your personal data will be collected and used byus for the following purposes and we may disclose yourpersonal data to third parties where necessary for the following purposes:

(a) assessing and evaluating your suitability for the Programme now or in the future;

(b) to conduct the Programme;

(d) all administrative related matters for the Programme and developing policies;

(e) assessing and evaluating your suitability for activities that we may conduct now or in the future in relation to our businessand capacity as a Capital Market Services Licence holder for venture capital fund management activities, and our ability to connect with you in this regard;and

(f) facilitating our compliance with any laws, customs and regulations which may be applicable to us.

7. The purposes listed in the above clauses may continue to apply following the conclusion of the Programme.

WITHDRAWING CONSENT

8. The consent that you provide forthe collection, use and disclosure of your personal data will remain validuntil such time it is being withdrawn by you in writing. As an Applicant, youmay withdraw consent and request us to stop collecting, using and/or disclosingyour personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

9. Upon receipt of your writtenrequest to withdraw your consent, we may require reasonable time (depending onthe complexity of the request and its impact on our relationship with you) foryour request to be processed and for us to notify you of the consequences of usacceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within 14 days of receiving it.

10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your application for the Programme. We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you orinformation about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the feebefore processing your request.

14. We will respond to your request assoon as reasonably possible. In general, our response will be within 14 days. Should we not be able to respond to your access request within 14 days after receiving your access request, we will inform you in writing within 14 days ofthe time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

15. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

PROTECTION OF PERSONAL DATA

16. To safeguard your personal datafrom unauthorised access, collection, use, disclosure, copying, modification,disposal or similar risks, we have introduced appropriate administrative,physical and technical measures such as minimised collection of personal data,authentication and access controls (such as good password practices,need-to-basis for data disclosure, etc.), encryption of data, up-to-dateantivirus protection, regular patching of operating system and other software,securely erase storage media in devices before disposal, web security measuresagainst risks, and security review and testing performed regularly.

17. You should be aware, however, thatno method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

18. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details providedbelow.

RETENTION OF PERSONAL DATA

19. We may retain your personal data for as long asit is necessary to fulfil the purposes for which they were collected, or asrequired or permitted by applicable laws.

20. We will cease to retain your personal data, orremove the means by which the data can be associated with you, as soon as it isreasonable to assume that such retention no longer serves the purposes forwhich the personal data were collected, and are no longer necessary for legalor business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

21. We generally do not transfer yourpersonal data to countries outside of Singapore. However, if we do so, we willobtain your consent for the transfer to be made and will take steps to ensurethat your personal data continues to receive a standard of protection that isat least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

22. If you have any enquiries or feedback on our personal data protection policies and procedures or if you wishto make any request, you may contactour Data Protection Officer via email at privacy@january.capital.

EFFECT OF POLICY AND CHANGES TO POLICY

23. This Policy applies in conjunctionwith any other policies, notices, contractual clauses and consent clauses thatapply in relation to the collection, use and disclosure of your personal databy us.

24. We may revise this Policy from timeto time without any prior notice. You may determine if any such revision hastaken place by referring to the date on which this Policy was last updated.Your continued participation in the Programme or further interactions with us constituteyour acknowledgement and acceptance of such changes. If you do not agree to anyrevised terms, you must immediately discontinue your participation in theProgramme and notify our Data Protection Officer in writing.

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Effective date : 02 Feb 2026

Last updated : 02 Feb 2026