Privacy Policy

Effective Date: 20/03/2024

Sunnov Investment Pte. Ltd. (UEN: 201225494E) (“Sunnov Investment”, “Sunnov”, “we”, “us” or “our”) is a Singapore‑based investment manager founded in 2012. We operate the website at
https://sunnov.com and any related online portals, pages and services that link to this Privacy Policy (together, the “Site”). Sunnov serves accredited investors, foundations, endowments and other professional or institutional investors globally, running long‑only equity strategies as its core, with complementary mandates.

This Privacy Policy explains how we collect, use, disclose and safeguard information relating to identified or identifiable individuals (“Personal Data”) when you visit or use the Site, communicate with us, or engage with us in connection with our investment management activities. It also describes your rights and choices under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) and, where it applies, the European Union and United Kingdom data protection regime (including Regulation (EU) 2016/679 and the “UK GDPR”) (together, “GDPR”).

By accessing or using the Site, or by providing Personal Data to us, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Site or otherwise provide Personal Data to us.

If you have any questions about this Privacy Policy or how we handle your Personal Data, please contact us at [email protected].

1. Personal Data We Collect

We collect Personal Data that you provide to us, that arises from our dealings with you, or that is generated or obtained from other sources in the course of operating the Site and our investment management business. The categories of Personal Data we may collect include:

• Identification and contact details – such as your name, title, date of birth, nationality, residential or mailing address, email address, telephone number and other contact information.
• Investor and account information – information relating to your status and eligibility (for example, accredited or institutional investor status), your investment objectives and risk profile, your holdings and transaction history in any funds, mandates or products managed or advised by Sunnov, and information relating to your relationship with us (including onboarding information, instructions, and records of services provided).
• KYC, compliance and regulatory information – information required for “know‑your‑client” checks, anti‑money laundering (“AML”), counter‑terrorism financing, sanctions screening and other regulatory or compliance purposes, such as copies of passports or other identification documents, signatures, tax identification numbers, residency or domicile information, information about source of wealth or source of funds, and results of screening against public or government watchlists.
• Financial and payment details – such as bank account details, payment instructions, records of subscriptions, redemptions and distributions, and other transactional information. We do not store full payment card numbers on the Site; such data may be processed by payment service providers where relevant.
• Professional and organisational details – such as your job title and role, the organisation you represent, your industry, regulatory status and related information where you interact with us in a professional capacity (for example, as an investor, intermediary, adviser, service provider or other counterparty).
• Communications and preferences – including records of communications with you (such as emails, letters, telephone calls and meeting notes), feedback you provide, and your marketing and communication preferences.
• Technical and usage data – such as your Internet Protocol (IP) address, browser type and version, time zone setting, device identifiers, operating system, pages you view, the dates and times of your visits, clickstream data, and information about how you interact with the Site (including error logs and performance data).
• Cookie and analytics data – information collected through cookies, web beacons, pixels and similar technologies on the Site. This may include information about how you arrive at and navigate the Site, and how you respond to content and emails from us.
• Any other information you choose to provide – for example, information provided in forms, in connection with events, surveys or webinars, or in documents you choose to send to us.

We may also collect, use and share aggregated or anonymised data (such as aggregated statistical or demographic information) which does not identify any individual. Aggregated data is not Personal Data for the purposes of this Privacy Policy.

In limited cases, we may process special categories of Personal Data or information relating to criminal offences or proceedings, for example where this arises in the context of regulatory and compliance checks (such as politically exposed person status, sanctions or adverse media screening) or where such information is apparent from documents you provide. We process such information only where necessary and permitted by applicable law (for example, to comply with legal and regulatory obligations) and, where required, on the basis of your explicit consent. We ask that you do not provide special categories of Personal Data unless we specifically request it for compliance or regulatory purposes.

2. How We Collect Personal Data

• Directly from you – We collect Personal Data that you provide to us, for example when you:
  • request information about Sunnov or our investment strategies;
  • complete subscription documents, onboarding questionnaires, know‑your‑client forms or other client or investor documentation;
  • sign up to receive reports, updates, newsletters or other materials from us;
  • create or access an online account, investor portal or data room operated by or on behalf of Sunnov;
  • attend meetings, events, calls or roadshows with us;
  • correspond with us by email, telephone or post, or otherwise contact us via the Site; or
  • provide us with business cards or other contact details.
• Automatically from your use of the Site – When you visit or use the Site, we automatically collect certain technical and usage data through cookies, log files and similar technologies. This may include your IP address, device and browser information, time zone setting, the pages you visit and links you click, the referring website, and information about how you interact with our content.
• From third parties – We may obtain Personal Data about you from third‑party sources, including:
  • administrators, custodians, brokers, distributors and other service providers involved in the establishment, operation or servicing of funds, mandates or products managed by Sunnov;
  • professional advisers, placement agents or intermediaries who introduce you to us or act on your behalf;
  • our group entities and affiliates, to the extent permitted by law and any applicable confidentiality restrictions;
  • publicly available sources, such as company registries, regulatory databases, sanctions lists and reputable online sources; and
  • screening and due‑diligence providers, identification verification services and other compliance‑related service providers.

The Site may use Google Analytics 4 or similar analytics services to help us understand how visitors use the Site and to improve its performance and security. These services use cookies and similar technologies to collect information in a pseudonymised manner (such as IP address, device identifiers and usage patterns). You may opt out of Google Analytics by installing the Google Analytics opt‑out browser add‑on available from Google, or by adjusting your browser and cookie settings. If you disable certain cookies, some features of the Site may not function as intended.

3. Purposes for Which We Use Personal Data

We use Personal Data for the purposes set out below, to the extent permitted by applicable law:

• To establish and manage our relationship with you – including assessing your suitability and eligibility to invest or engage with us, verifying your identity, carrying out onboarding, opening and maintaining accounts or relationships, and administering your investments, instructions and interactions with Sunnov.
• To provide our investment management services – including managing and operating funds and mandates, executing and settling transactions, calculating and paying fees and distributions, arranging custody and administration, and otherwise performing our contractual obligations to you or to the entity you represent.
• To comply with legal, regulatory and risk‑management obligations – including obligations under Singapore law (for example, MAS rules and guidelines, the PDPA, AML and counter‑terrorism financing legislation) and under foreign laws that may apply (including EU and UK regulatory regimes), such as:
  • conducting KYC, AML, sanctions and other due diligence checks;
  • maintaining records and accounts;
  • reporting to, and responding to requests from, regulators, tax authorities, exchanges and other public authorities; and
  • detecting, investigating and preventing fraud, financial crime, market abuse and other unlawful or improper conduct.
• To operate, maintain and improve the Site and our business – including monitoring and analysing usage, troubleshooting, preventing abuse and security incidents, testing and developing new features, and ensuring the integrity and resilience of our systems.
• To communicate with you – including responding to enquiries, sending service‑related communications (such as transaction confirmations, statements, updates, regulatory notices or changes to our terms), and otherwise corresponding with you during the course of our relationship.
• To conduct marketing and investor relations activities – including sending you newsletters, thought leadership, market commentary, event invitations or information about Sunnov strategies and products, in accordance with applicable law and your marketing preferences.
• To protect our rights and interests – including enforcing our agreements, managing potential or actual disputes, and establishing, exercising or defending legal claims.
• For any other purpose that is compatible with the purposes described above, that is communicated to you at the time of collection, or for which we have obtained your consent.

Direct marketing. We may use your contact details to send you electronic marketing communications (for example, emails about investment strategies, market updates or events) where permitted by the PDPA, GDPR or other applicable law, either on the basis of your consent or, where permitted, our legitimate interests in promoting our services to professional or existing clients. You may withdraw your consent or object to direct marketing at any time by following the unsubscribe instructions in the message or by contacting us using the details in section 13 below. Where required by Singapore’s Do Not Call provisions, we will honour your marketing preferences within 10 business days.

4. Legal Bases for Processing (EEA/UK)

Where the GDPR applies (for example, if you are located in the European Economic Area or the United Kingdom), we process your Personal Data only where we have a valid legal basis. Depending on the circumstances, we rely on one or more of the following legal bases:

• Performance of a contract – where processing is necessary to enter into or perform a contract with you or the organisation you represent, or to take steps at your request prior to entering into such a contract.
• Compliance with legal obligations – where processing is necessary for us to comply with obligations under applicable laws, regulations, rules or guidance (for example, AML and sanctions laws, financial services regulation, tax reporting and record‑keeping obligations).
• Legitimate interests – where processing is necessary for our legitimate interests or those of a third party, and those interests are not overridden by your interests or fundamental rights and freedoms. Our legitimate interests include operating, maintaining and improving our investment strategies and the Site; managing client and investor relationships; ensuring the security of our systems; preventing fraud and misuse; and promoting our services to existing and prospective professional investors in a proportionate manner.
• Consent – where we have obtained your consent for a specific purpose, such as certain categories of marketing, the use of non‑essential cookies, or (where required) the processing of special categories of Personal Data. You may withdraw your consent at any time as described in this Privacy Policy.

In limited circumstances, we may also process Personal Data on the basis of vital interests (for example, to prevent serious harm) or for the establishment, exercise or defence of legal claims. Where we rely on legitimate interests, we have carried out a balancing test and will make further information about this available on request.

5. Sharing and Disclosure of Personal Data

We do not sell your Personal Data. We only disclose Personal Data as described in this Privacy Policy, or as otherwise notified to you at the time of collection, and always in accordance with applicable law. We may share your Personal Data with:

• Group entities and funds managed by us – other entities under common control with Sunnov, and funds, portfolios or investment vehicles that we manage or advise, where reasonably necessary for the purposes described in this Privacy Policy and subject to appropriate confidentiality safeguards.
• Service providers and professional advisers – trusted third parties who provide services to us, such as fund administrators, custodians, depositaries, brokers, banks, IT and cloud hosting providers, analytics providers, KYC and screening service providers, consultants, auditors, accountants, legal counsel and other professional advisers. These service providers are authorised to use the Personal Data only as necessary to provide their services and are subject to contractual obligations of confidentiality and data protection.
• Business partners and intermediaries – including distributors, placement agents, arrangers, introducers and other intermediaries involved in our investment management activities, to the extent reasonably necessary for those activities.
• Counterparties and transaction‑related recipients – such as other financial institutions, executing brokers, trading venues, custodians or lenders involved in transactions or arrangements relating to your investments.
• Regulators, authorities and public bodies – including courts, law enforcement agencies, regulatory authorities (such as the Monetary Authority of Singapore) and tax authorities, where we consider this necessary to comply with legal or regulatory obligations, to respond to valid requests or orders, or to protect our rights, your rights or the rights of others.
• Successors and transaction parties – third parties involved in a proposed or actual reorganisation, merger, acquisition, joint venture, transfer or other disposition of all or part of our business, assets or shares (including in connection with any insolvency or similar proceedings). In such cases, Personal Data may be transferred to advisers, counterparties and their advisers as part of the due diligence process and to any successor entity, subject to appropriate safeguards.
• Other persons with your consent or at your direction – for example, where you ask us to share information with your advisers or representatives.

6. Data Retention

We retain Personal Data only for as long as is reasonably necessary to fulfil the purposes for which it was collected and to satisfy our legal, regulatory, tax, accounting and reporting obligations, or to establish, exercise or defend legal claims.

In determining how long to retain Personal Data, we consider factors such as:

• the nature and sensitivity of the Personal Data;
• the purposes for which we process it and whether those purposes can be achieved by other means;
• the applicable legal, regulatory and contractual requirements (for example, record‑keeping obligations under financial services and AML legislation, which may require us to keep certain records for a number of years after the end of the client or investor relationship); and
• the risk of harm from unauthorised use or disclosure.

When Personal Data is no longer required for the purposes for which it was collected and retention is no longer justified, we will take reasonable steps to delete, anonymise or otherwise permanently de‑identify it in a secure manner.

7. Your Rights and Choices

Subject to applicable law and certain limitations and exemptions, you may have the rights and choices set out below in relation to your Personal Data:

• Marketing communications – You may opt out of receiving electronic marketing communications from us at any time by following the unsubscribe instructions in the communication or by contacting us. We may still send you service or transaction‑related communications where permitted by law.
• Cookie controls – You can manage your cookie preferences through your browser settings and, where available, through any cookie management tools provided on the Site. Please note that disabling certain cookies may affect the functionality of the Site.
• Access and correction – You may be entitled to request access to Personal Data that we hold about you and to request that we correct any inaccurate or incomplete Personal Data.
• Deletion, restriction and objection – In some circumstances, you may have the right to request that we delete your Personal Data, restrict certain types of processing, or object to particular processing activities (including, for example, processing based on our legitimate interests or direct marketing, as permitted by law).
• Portability – Where applicable, you may have the right to receive certain Personal Data in a structured, commonly used and machine‑readable format and to have that data transmitted to another controller.
• Withdrawal of consent – Where processing is based on your consent, you have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

To exercise any of these rights, please contact us using the details in section 13 below. We may need to request specific information from you to help us confirm your identity and to ensure that you are entitled to exercise the relevant right. We will respond to all legitimate requests within a reasonable period, and in any event within any time limits required by applicable law.

Singapore (PDPA)

If the PDPA applies to our processing of your Personal Data, you have the right to request access to, and correction of, Personal Data that we hold about you, subject to applicable exceptions. You also have the right to withdraw your consent to our collection, use and disclosure of your Personal Data, subject to legal or contractual restrictions and reasonable notice. If you withdraw consent, this may affect our ability to continue to provide services to you or to maintain a relationship with you.

Under the PDPA, we may charge a reasonable fee to process access requests and will inform you of any such fee before proceeding. If you are dissatisfied with the way we handle your Personal Data, you may lodge a complaint with the Personal Data Protection Commission in Singapore, although we invite you to contact us first so that we may address your concerns.

EEA/UK (GDPR)

If the GDPR applies to our processing of your Personal Data, you have the rights set out above, which correspond to Articles 15–21 of the GDPR, including:

• the right of access to your Personal Data;
• the right to rectification of inaccurate Personal Data;
• the right to erasure (“right to be forgotten”) in certain circumstances;
• the right to restriction of processing in certain circumstances;
• the right to data portability in respect of Personal Data you have provided to us, where processing is based on consent or on a contract and carried out by automated means;
• the right to object, on grounds relating to your particular situation, to processing based on our legitimate interests, and an absolute right to object to direct marketing; and
• the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects on you, where applicable.

You also have the right to lodge a complaint with your local supervisory authority if you consider that our processing of your Personal Data infringes the GDPR. However, we would appreciate the opportunity to address your concerns before you contact a supervisory authority, and we invite you to contact us in the first instance.

8. Security

We take the security of your Personal Data seriously and implement appropriate technical and organisational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include access controls, encryption in transit, logical and physical security safeguards, and regular review of our security procedures.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for keeping any account credentials confidential and for using appropriate security measures when communicating with us.

9. International Transfers

Sunnov is established in Singapore and operates internationally. As a result, your Personal Data may be transferred to, stored in and processed in Singapore and in other jurisdictions where our group entities, funds, service providers, counterparties or other recipients are located. These jurisdictions may have data protection laws that differ from those in your country of residence.

Transfers from Singapore. Where we transfer Personal Data from Singapore to a country or territory outside Singapore, we will comply with the PDPA requirements in relation to such transfers. In particular, we will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection for Personal Data that is at least comparable to the protection under the PDPA, for example by entering into contractual arrangements with the recipient or by relying on other permitted transfer mechanisms.

Transfers from the EEA/UK. Where the GDPR applies and we transfer Personal Data from the EEA or the UK to a country that has not been recognised as providing an adequate level of protection for Personal Data (such as Singapore), we will implement appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, and supplementary technical and organisational measures where necessary. A copy of the relevant safeguards can be obtained from us on request, subject to redacting commercially sensitive information.

10. Children’s Privacy

The Site and our services are intended for professional and institutional investors and are not directed at children or individuals under the age of 18. We do not knowingly collect Personal Data from anyone under 18 years of age. If you are a parent or guardian and believe that your child has provided Personal Data to us, please contact us using the details in section 13 below. If we become aware that we have collected Personal Data from a child contrary to this section, we will take reasonable steps to delete such information as soon as practicable.

11. Third‑Party Links and Services

The Site may contain links to, or may be accessible from, third‑party websites, services or content that are not operated by Sunnov. We do not control and are not responsible for the privacy practices of such third parties. If you access third‑party sites, services or content, any Personal Data you provide will be processed in accordance with their privacy policies, which may differ from ours. We encourage you to review the privacy policies of any third‑party sites or services you visit.

12. Changes to This Privacy Policy

We may update or amend this Privacy Policy from time to time to reflect changes in our practices, technologies, legal or regulatory requirements, or other factors. When we do so, we will post the updated version on the Site and revise the “Effective Date” at the top of this Privacy Policy. Where required by applicable law, we will also notify you of material changes and, where necessary, seek your consent.

Your continued use of the Site or continued provision of Personal Data to us after any update to this Privacy Policy will constitute your acknowledgement of the updated Policy.

13. Contact Us

If you have any questions about this Privacy Policy, our handling of your Personal Data, or if you wish to exercise your rights, 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