THE FIRST FELLOWS PRIVACY POLICY
APPLICATION OF THIS 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 individuals who apply or who are selected to be part of our “The First Fellows” programme (“Applicants” or “you”), in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Policy applies to personal data of Applicants in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
In connection with the “The First Fellows” programme (“Programme”), we may also collaborate and share your personal data with third parties (“Partners”), who may include [corporate partners, advisers, mentors, coaches, university partners, legal firms, cloud credit providers, potential pilot customers]. These Partners may be collecting, using, and/or disclosing personal data, for their own purposes and their own separate privacy policies may also apply.
PERSONAL DATA
- As used in this Policy, “personal data” means 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.
- Personal data of Applicants we may collect includes, without limitation:
(a) name or alias, gender, year of birth, and nationality;
(b) telephone numbers, email address and other contact details;
(c) resume, educational background and qualifications, professional qualifications and certifications and employment references; and
(d) employment and training history.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally collect personal data which: (a) you knowingly and voluntarily provide to us or our Partners in connection with the Programme, either directly or via a third party who has been duly authorised by you (your “authorised representative”), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use without consent is permitted or required by the PDPA or other laws, such as from publicly available information. We generally 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).
- Your personal data may be collected, used, and disclosed by us and or by any of our Partners for any of the following purposes:
(a) assessing and evaluating your suitability or continued suitability for the Programme;
(b) conducting, administering, supporting, and publishing publicly available material regarding the Programme, including sharing personal data to facilitate Partner engagements with you in connection with the Programme (e.g. to provision accounts or verify eligibility);
(c) verifying your identity and the accuracy of your personal details, credentials and other information;
(d) to enable peer-to-peer learning amongst your cohort in the Programme, or between cohorts in the Programme, by sharing contact information and profiles;
(e) assessing and evaluating your suitability for activities that we may conduct now or in the future in relation to our business and capacity as a Capital Markets Services Licence holder for venture capital fund management activities, such as activity in relation to assessing the viability of any proposed startup, sharing data with potential co-investors, carrying out investment committee processes;
(f) facilitating compliance with any laws, customs and regulations which may be applicable to us or our Partners (which may include foreign laws, customs and regulations, and responding to request from regulators or authorities); and
(g) sending Programme updates, Partner communications, and any invitations, announcements, and operational messages;
(h) processing stipends, reimbursements, travel bookings, grants or other benefits;
(i) monitoring for misuse and protecting the Programme and all its participants;
(j) measuring outcomes (e.g. fundraising, hiring, revenue growth), generating aggregated reports for stakeholders or Partners, which may also involve sharing limited personal data to substantiate outcomes; and
(k) handling complaints, managing conflicts and dealing with disputes.
- The purposes listed in the above clauses shall remain applicable even after the end of the Programme or any part of the Programme.
ACCURACY OF PERSONAL DATA
- 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 provided below.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
- 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We will only transfer your personal data to countries outside of Singapore. in a manner compliant with the PDPA.
DATA PROTECTION OFFICER
- If you have any enquiries or feedback on our personal data protection policies and procedures or if you wish to make any request, you may contact our Data Protection Officer via email at privacy@january.capital.
EFFECT OF POLICY AND CHANGES TO POLICY
- This Policy applies in addition with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued participation in the Programme or further interactions with us in connection with the Programme constitute your acknowledgement and acceptance of such changes. If you do not agree to any revised terms, you must immediately discontinue your participation in the Programme and notify our Data Protection Officer in writing.