This Policy Statement sets out the purpose, collection, use, disclosure and transfer of the personal data by EASTvine Capital Private Limited (“EASTvine Capital”) and the various funds , including but not limited to EASTVINE COMMODITY TRADE FUND (CAYMAN) LIMITED  and EASTVINE COMMODITY TRADE FUND PRIVATE LIMITED managed and advised by it, (collectively, “we” or “EASTvine Funds”).

Generally, we collect personal data through the following ways:

• when you request us to contact you;
• when you access our website;
• when you interact with any of the employees of EASTvine Funds;
• when you respond to our initiatives; and
• when you submit your personal data to us for any other reason.

We need to process your personal data for purposes including but not limited to the following:

• establishment, continuation and management of relationships and accounts;
• processing applications for products and services, effecting payments, transactions and completing instructions or requests;
• credit assessment, including conducting credit checks and setting credit limits;
• operational and administrative purposes;
• assessing suitability of the products and services;
• the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
• identity verification, government sanctions screening and due diligence checks; and
• compliance with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body.

Any personal data which you provide to EASTvine Funds will be kept confidential and protected but EASTvine Funds may provide such personal data to the following parties:

• any officer and employee of EASTvine Funds, and of any fund whether established in Singapore or otherwise managed by EASTvine Capital,
• any fund administrators, agents, representatives or third-party service providers (and their sub-contractors) of EASTvine Funds;
• any regulatory authorities, supervisory, tax, governmental or quasi-governmental or other authority (whether in Singapore or elsewhere), court of law, tribunal, or person with jurisdiction over EASTvine Funds whether in Singapore or elsewhere;
• any professional adviser, auditor, investor, risk participant; and
• any person to whom we are under a duty to disclose or to whom such disclosure is reasonably considered by EASTvine Funds to be necessary

If you have a question about EASTvine Funds’ privacy and information practices or if you require more information on or access to the information which you have earlier provided to EASTvine Funds, you may write in to [email protected].

For more information on Personal Data Protection Act, please refer to https://www.pdpc.gov.sg.