Effective Date: 12/03/2024
This Cookie Policy explains how Sunnov Investment Pte. Ltd. (UEN: 201225494E) (“Sunnov Investment”, “Sunnov”, “we”, “us” or “our”) uses cookies and similar technologies on the website available at
https://sunnov.com and any related online portals, pages and services that link to this Cookie Policy (together, the “Site”).
Sunnov is a Singapore‑based investment manager founded in 2012. The firm serves accredited investors, foundations and endowments globally, running long‑only equity strategies as its core, with complementary long or short equity, global macro, event‑driven and systematic mandates, and structured avenues for eligible retail participation.
This Cookie Policy should be read together with our Privacy Policy, which explains in more detail how we process personal data and the rights available to you under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) and, where applicable, the European Union General Data Protection Regulation (Regulation (EU) 2016/679) and the United Kingdom data protection regime (together, the “GDPR”).
Where required by law (for example, in the European Economic Area or the United Kingdom), we will only place non‑essential cookies (as defined below) on your device after you have indicated your consent through our cookie banner or settings. You may withdraw or modify your consent at any time as described in this Cookie Policy.
1. What Are Cookies and Similar Technologies?
A “cookie” is a small text file that a website stores on your computer or mobile device when you visit the site. Cookies enable the website to recognise your device and store certain information about your preferences or past actions so that your experience can be tailored and the site can function effectively.
In addition to standard cookies, we may use related technologies such as web beacons, pixels, tags, local storage and software development kits (SDKs). In this Cookie Policy, we refer to all of these technologies collectively as “cookies”.
Cookies may be:
- First‑party cookies – set directly by us when you visit the Site; or
- Third‑party cookies – set by third parties, such as analytics or consent‑management providers, when you visit the Site.
Cookies can also be:
- Session cookies – which expire when you close your browser; or
- Persistent cookies – which remain on your device for a defined period or until you delete them.
2. How We Classify Cookies
We classify cookies according to their purpose and in line with guidance under the PDPA and GDPR:
- Strictly necessary (essential) cookies – These cookies are required for the Site to function and to provide services that you expressly request, such as secure navigation, basic security features, and access to pages that require authentication. The Site cannot function properly without these cookies.
- Functional (preference) cookies – These cookies enable the Site to remember choices you make, such as language preferences or display settings, and to provide enhanced and more personalised features.
- Analytics / performance cookies – These cookies help us understand how visitors use and interact with the Site, for example which pages are visited most often and whether users receive error messages. The information is generally aggregated and used to improve the Site’s performance and usability.
- Marketing / targeting cookies – These cookies are used to track your browsing habits and may be used to deliver advertising that is more relevant to your interests or to measure the effectiveness of our communications and campaigns.
Some cookies may involve the processing of personal data (for example, IP addresses, unique identifiers or device information). Where this is the case, we will process such personal data in accordance with our Privacy Policy.
3. Cookies Used on the Site
The specific cookies that we use on the Site may change over time as we improve or update our services. The categories below describe the types of cookies that may be deployed.
3.1 Strictly Necessary Cookies (Enabled by Default)
These cookies are essential for the operation of the Site and are always active. They are typically set in response to your actions, such as setting your privacy preferences, logging in, or filling in forms. Without these cookies, services you have requested may not function correctly.
Because these cookies are strictly necessary to deliver the Site and its core features, they do not require your consent. You may configure your browser to block or alert you about these cookies, but some parts of the Site may then cease to function properly.
3.2 Functional (Preference) Cookies
Functional cookies enable the Site to provide enhanced functionality and personalisation, for example by remembering your region or language or by retaining certain display settings. If you choose to disable these cookies, some features may be less tailored, but the Site should still be usable.
As at the Effective Date, we [do / do not] place functional cookies on the Site. If we introduce functional cookies in future, we will update this Cookie Policy to describe them and, where required, seek your consent.
3.3 Analytics / Performance Cookies
We use analytics cookies to obtain aggregated statistics about how visitors use the Site, which helps us understand and improve its performance and relevance. For example, we may use:
- Google Analytics 4 – to collect pseudonymised information such as the number of visitors to the Site, the pages visited, approximate location based on IP address, and technical information about browsers and devices. Google Analytics sets cookies in connection with these services.
Where required by law, we will only set analytics cookies if you give your consent through our cookie banner or preferences centre. If you withdraw your consent, we will stop using these cookies for your device from that point onwards.
You may also opt out of Google Analytics by installing the Google Analytics opt‑out browser add‑on (available from Google) or by adjusting your browser settings, as described in section 5 below.
3.4 Marketing / Targeting Cookies
Marketing or targeting cookies may be used to build a profile of your interests and to show you relevant content on our Site or on third‑party sites. They may also be used to measure and analyse the effectiveness of our communications.
As at the Effective Date, we [do / do not] use marketing or targeting cookies on the Site. If we decide to use such cookies in the future, we will update this Cookie Policy and seek your consent before placing them, where required by law.
4. Legal Basis for the Use of Cookies
Our use of cookies may involve the processing of personal data. In such cases, we rely on one or more of the following legal bases, depending on the type of cookie and the context in which it is used:
- Strictly necessary cookies – Processing is necessary for the performance of a contract or for taking steps at your request prior to entering into a contract (for example, to provide you with access to secure areas of the Site) and for our legitimate interests in operating a secure and user‑friendly Site (PDPA sections 13 and 15; GDPR Article 6(1)(b) and 6(1)(f)).
- Functional, analytics and marketing cookies – We rely on your consent to set these cookies and to process any personal data obtained through them (PDPA section 13; GDPR Article 6(1)(a)). Where required, we will ask for your consent via our cookie banner or preferences centre before placing such cookies on your device.
You may withdraw your consent at any time using the mechanisms described in section 5. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
5. Your Choices and How to Control Cookies
You have several options for controlling or limiting how cookies are used on the Site.
- Cookie banner and preferences centre – When you first visit the Site, you may be presented with a cookie banner that allows you to accept or reject different categories of non‑essential cookies. You can update your preferences at any time by using the cookie settings link or icon made available on the Site (where implemented).
- Browser settings – Most web browsers allow you to manage cookies through their settings, including blocking cookies altogether, deleting existing cookies or receiving alerts before cookies are stored. The exact steps depend on your browser; please refer to the “help” or “settings” section of your browser for more information.
- Third‑party tools – For certain third‑party services, additional opt‑out options may be available. For example, you may use the Google Analytics opt‑out browser add‑on to prevent your data from being used by Google Analytics.
Please note that if you disable or reject certain cookies, some parts of the Site may become inaccessible or may not function correctly.
6. International Transfers
Some of our third‑party service providers that set or access cookies on the Site may be located outside Singapore and outside the European Economic Area or the United Kingdom. This includes, for example, providers of analytics, hosting and consent‑management services.
Where personal data collected through cookies are transferred internationally, we will take appropriate steps to ensure that your data are afforded a level of protection that is at least comparable to that under the PDPA and adequate under the GDPR. These safeguards may include:
- ensuring that the recipient is located in a jurisdiction recognised as providing an adequate level of data protection; or
- entering into appropriate contractual arrangements with the recipient, such as the European Commission’s Standard Contractual Clauses, together with supplementary technical and organisational measures where necessary.
7. Retention of Cookie Data
Cookies are stored for different periods depending on whether they are session or persistent cookies and on their specific purpose. In general:
- session cookies are deleted when you close your browser; and
- persistent cookies remain on your device for the period indicated in your browser or device settings or until you delete them.
Personal data derived from cookies are retained only for as long as necessary to fulfil the purposes described in this Cookie Policy, after which they are deleted, anonymised or aggregated in accordance with our data retention practices and applicable law. Aggregated analytics data may be retained for longer periods for statistical and reporting purposes.
8. Changes to This Cookie Policy
We may update or amend this Cookie Policy from time to time, for example to reflect changes in the cookies we use, our legal or regulatory obligations, or our technical or business practices. When we make changes, we will post the updated Cookie Policy on the Site and revise the “Effective Date” at the top.
Where required by law, we will also provide additional notice of material changes (for example, by displaying a prominent notice on the Site or by contacting you directly if we hold your contact details) and, where appropriate, seek your renewed consent for the use of certain cookies.
9. Contact Us
If you have any questions about this Cookie Policy or our use of cookies on the Site, or if you wish to exercise any of your rights under applicable data protection laws, please contact us using the details below:
Sunnov Investment Pte. Ltd.
UEN: 201225494E
Registered address: 60 Paya Lebar Road, Paya Lebar Square, Singapore 409051
Email: [email protected]
Telephone: +65 3106 1460
Data Protection Officer: Wentao Zhang