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Privacy Policy
Our Privacy Policy was last updated on 20.09.2025
Introduction
Labna Capital Pte Ltd. (UEN: 202450892G, incorporated in Singapore with its registered office at 68 Circular Road, #02-01, Singapore 049422) and its group of companies (collectively "Labna Capital", "we", "our" or "us") is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore ("PDPA") and other applicable laws.
Your Consent
By providing us with your personal data voluntarily, such as by filling out a form, contacting us, or signing an agreement, you consent to our collection, use, and disclosure of your personal data for the purposes described in this policy.
For specific processing activities, such as:
● The use of non-essential cookies and similar technologies for analytics and advertising;
● The sending of marketing and promotional communications;
we will seek your separate, explicit consent through our consent management platform. You have the right to withdraw your consent for any of these purposes at any time by using the "Manage Preferences" or "Manage Cookies" link in our website footer or by contacting our Data Protection Officer.
Please read this Privacy Policy carefully to understand our practices.
1. Personal Data
1.1. In this Privacy Policy, “Personal Data” means any data, whether true or false, which can be related to a specific identifiable individual, whether such individual is identifiable from the data itself, or from other information which is available to us, including data in our records as may be updated from time to time.
1.2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
1.3. The Subject of personal data has the right to request clarification of their Personal Data, its blocking or destruction if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.
2. Collection of Personal Data
2.1. Labna Capital is committed to protecting and respecting your privacy when you use our website/services. Generally, Labna Capital may collect your Personal Data in several different ways, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, from publicly available sources or through our website
2.2. Whenever you interact with Labna Capital, you may or may be asked to provide us your Personal Data. For example, when you:
● purchase or engage our services through the signing of forms or agreements;
● submit enquiries on products and/or services via our Company email, we may keep information about the enquiry, including your name, your contact details, and the subject matter of your enquiry;
● respond to marketing and promotion activities;
● submit job applications, resume and other information required for the recruitment process;
● subscribe for email alerts or make enquiries on our Investor Relations portal;
● visit any of our premises, you may be asked to provide your personal details to our security officers;
● when you provide us with payment information (all payment transactions are processed securely by our PCI-DSS compliant third-party payment service providers. We do not store, process, or retain your full credit card details(such as full Permanent Account Number (PAN) or CVV/CVC codes) on our servers. The payment data you provide is transmitted directly to our payment processors and is subject to their privacy policies);
● when you enable or utilise services requesting location data; and
● when you submit your Personal Data to us for any other reason.
2.3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the purposes as listed below.
2.4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
If you do not accept and agree to this Privacy Policy, please do not provide your Personal Data to us.
3. Purpose of Collection, Use, Disclosure of Your Personal Data and Storage of Personal Data
3.1. Labna Capital processes Personal Data - operations performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
3.2. Personal data is processed in compliance with the principles and rules provided for by current legislation. The processing of Personal Data is limited to the achievement of specific, predetermined, and lawful purposes.
3.3. Only Personal Data that meets the purposes of its processing is subject to processing. The content and scope of the personal data processed must correspond to the stated purposes of processing.
3.4. Generally, Labna Capital collects, uses and discloses your Personal Data for the following purposes:
● using cookies to ensure the functioning and security of the website, improve the quality of the services, products, and services provided, and generate personalized offers;
● processing requests on the Website;
● monitoring compliance with confidentiality conditions;
● communicating with customers;
● providing access to services, information, and/or materials contained on the Website;
● sell and lease real estate;
● promoting products and services (marketing);
● providing customer service including but not limited to the resolution of complaints, feedback and other after sales services;
● asking for your opinions on Labna Capital products and services and conducting product surveys;
● facilitating and processing your searches and requests for information when you contact us about Labna Capital and its products and services;
● analyzing, investigating, handling, resolving any security matters or any vulnerability;
● providing media announcements and responses;
● organising promotional events;
● legal purposes (including but not limited to obtaining legal advice and dispute resolution);
● conducting investigations relating to disputes, billing or fraud;
● meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Labna Capital (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
● any purposes which are reasonably related to the aforesaid.
3.2. In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.3. Personal Data shall be stored in a form that allows the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by law or by a contract to which the data subject is a party. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided by law.
4. Marketing Communications & Compliance with Do Not Call (DNC) Requirements
4.1. We may send you marketing and promotional messages via SMS, telephone calls, fax, and other digital messaging services (e.g., WhatsApp) about our products, services, and events that may be of interest to you, but only if you have provided your clear and explicit consent to receive such messages.
4.2. Respecting the Do Not Call (DNC) Registry: In compliance with Singapore's DNC provisions, we will:
● Check the relevant DNC Registry before sending any promotional SMS, fax, telephone call, or other digital message to a Singapore number, unless you have given us clear and unambiguous consent in writing or have been notified that we may contact you for marketing purposes and have not withdrawn such consent.
● Not send such messages to numbers listed on the DNC Registry, unless an exception under the law applies.
4.3. Withdrawal of Consent (Unsubscribe): You can withdraw your consent for receiving marketing communications at any time, free of charge, by:
● Clicking on the "Unsubscribe" link present in any of our marketing emails or SMS.
● Contacting our Data Protection Officer at dpo@labnacapital.com
4.4. We will process your unsubscribe request and cease sending marketing messages within 10 business days of receiving your request.
4.5. Labeling of Messages: In accordance with the Spam Control Act (SCA), our commercial electronic messages (e.g., SMS) will be clearly identified as advertisements and will include accurate sender identification and contact information. SMS messages of a commercial nature will be prefixed with “ADV”.
5. Disclosing and Transferring Personal Data
5.1. Labna Capital will take appropriate and commercially reasonable technical, physical, and administrative measures to protect any Personal Data it possesses or controls from misuse or accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access in accordance with the Act. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
● Labna Capital’s related corporations or affiliates and their employees to provide content, products and services to you or Labna Capital;
● agents, contractors or third party service providers who provide services to Labna Capital;
● any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of Labna Capital’s related corporations or affiliates;
● our professional advisers such as auditors, financial advisers and lawyers;
● relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
● any other party to whom you specifically authorise us to disclose your Personal Data.
5.2. Your Personal Data may be transferred, stored, and processed outside of Singapore, including in countries where data protection laws may differ from those of Singapore. We will ensure that any such international transfer is governed by appropriate safeguards designed to provide a comparable level of protection for your Personal Data. You consent and agree to Labna Capital transferring your Personal Data outside of Singapore for any of the purposes as listed above.
5.3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Labna Capital may not be able to continue to provide its products and/or services to you.
6. Cookies and Similar Technologies
6.1. Our website uses cookies, pixels, local storage, and other similar technologies (collectively, "Cookies and Technologies") to ensure security, analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole.
6.2. Some of these technologies may collect information that constitutes Personal Data, such as your IP address, device identifiers, and online browsing behavior, especially when combined with other information we or our third-party partners may hold.
6.3. We treat information collected by cookies and similar technologies as Personal Data when it can be linked to an identifiable individual or device. This data is used in accordance with this Privacy Policy.
6.4. For detailed information on the specific types of cookies and technologies we use, their purposes, providers, duration, and how to manage your preferences, please refer to our dedicated Cookies and Similar Technologies Policy.
6.5. You can control the use of non-essential cookies and technologies at the individual category level by using the "Manage Cookies" link, which is permanently available in the footer of our website. You can also change your browser settings to refuse cookies. Please note that disabling essential cookies may affect the functionality of our website and your ability to use some of our services.
6.6. Information collected in aggregate form about cookies, similar technologies and tracking may be shared with third parties. Some of our business partners whose content is featured on the site may also use cookies, but we do not have access to or control over them or their websites.
7. Your Rights: Access and Correction
7.1.Under the Personal Data Protection Act (PDPA), you have the right to access and correct your Personal Data in our records.
7.2. To exercise your right to access or correct your Personal Data, please submit a written request to our Data Protection Officer (dpo@labnacapital.com) via the contact details provided in Section 10 of this Policy. For clarity, please indicate "PDPA Access Request" or "PDPA Correction Request" in the subject line of your email or letter.
To process your request, we will need to verify your identity. Please be prepared to provide necessary details for this verification.
7.3. Processing Time and Fees
● Access: We will provide the requested information within 30 calendar days upon successful verification of your identity and receipt of your request. A reasonable fee may be charged for the cost of retrieving and providing the requested information. We will inform you of the fee beforehand.
● Correction: We will process your correction request within 30 calendar days. If we are unable to make the correction within this time, we will inform you of the earliest practicable time within which we can do so. Please note that no fee will be charged for correcting your data.
7.4. Please note that in certain circumstances, we may be permitted under the PDPA to refuse your access or correction request. If we are unable to comply with your request, we will generally inform you of the reasons for refusal within 30 calendar days.
8. Specific Jurisdictional Privacy Rights
8.1. Depending on your country of residence, you may be entitled to specific additional privacy rights under local laws. This section provides information for residents of certain jurisdictions.
8.2. For Data Subjects in Indonesia:
If you are located in Indonesia, the following provisions apply in addition to the rest of this Policy, in compliance with Undang-Undang No. 27 Tahun 2022 tentang Perlindungan Data Pribadi (PDP Law).
8.2.1. Data Subject Rights: In addition to the rights outlined in Section 8 of this Policy, you have the right to:
● Obtain information on the clarity of purpose and legal basis for processing.
● Object to automated decision-making.
● Request the deletion and/or destruction of your Personal Data.
● Withdraw your consent to the processing of your Personal Data.
8.2.2. Cross-Border Data Transfer: We will only transfer your Personal Data outside the territory of the Republic of Indonesia under one of the following conditions, as required by Article 56 of the PDP Law:
● The recipient country has a data protection standard that is equal to or higher than the provisions of the PDP Law (as determined by the Indonesian authorities); or
● We provide adequate and binding protection for the transferred data, through mechanisms such as Standard Contractual Clauses that incorporate data protection principles; or
● We have obtained your explicit consent for the specific transfer after informing you of the potential risks.
8.2.3. Data Breach Notification: In the event of a data breach that significantly impacts your interests, we will notify you and the relevant authorities (Kementerian Komunikasi dan Informatika/ KOMINFO) in accordance with the timelines and procedures stipulated by the PDP Law.
8.2.4. Data Protection Officer: Our Data Protection Officer (DPO), whose contact details are provided in Section 11, also serves as the point of contact for inquiries and requests from data subjects in Indonesia.
Hak-hak subjek data di Indonesia diatur dalam Undang-Undang PDP. Kami mematuhi hukum ini dan menghormati hak-hak Anda. Kebijakan ini menjelaskan cara kami memenuhi kewajiban kami under PDP Law.
8.3. For Data Subjects in the European Economic Area (EEA), United Kingdom (UK), and Switzerland:
● Legal Basis: Our processing of your Personal Data is based on the legal bases outlined in Article 6 of the GDPR, such as consent, contract performance, or legitimate interests.
● International Transfers: When transferring your data outside the EEA/UK to countries not deemed to provide an adequate level of data protection (such as Singapore), we rely on approved transfer mechanisms, such as Standard Contractual Clauses (SCCs).
● Data Subject Rights: You have the right to access, rectify, port, and erase your data, as well as the right to restrict and object to certain processing. You can exercise these rights by contacting our DPO (dpo@labnacapital.com.
8.3.2. Legal Bases for Processing: We rely on the following legal bases for processing your personal data under the GDPR/UK GDPR:
● Performance of a Contract: When processing is necessary for the performance of a contract with you (e.g., providing requested services).
● Consent: For sending marketing communications and using non-essential cookies and similar technologies. You can withdraw your consent at any time.
● Legitimate Interests: For purposes such as security, fraud prevention, and improving our services, where our interests are not overridden by your data protection rights.
● Compliance with a Legal Obligation. When processing is necessary to comply with a legal obligation.
8.3.3. Your Data Subject Rights: In addition to the rights outlined in Section 7 of this Policy, you have the right to:
● Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.
● Object to Processing: Object to processing based on our legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds.
● Restriction of Processing: Request the restriction of processing of your personal data under certain circumstances.
● Lodge a Complaint: You have the right to lodge a complaint with your local supervisory authority.
● International Transfers: When transferring your data outside the EEA/UK to countries not deemed to provide an adequate level of data protection (such as Singapore), we rely on approved transfer mechanisms, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
8.4. For For Residents of California, Colorado, Connecticut, Utah, and Virginia
If you are a resident of the states listed above, you have specific rights regarding your personal information under state privacy laws (such as the CCPA/CPRA in California).
8.4.1. Your Privacy Rights: You have the right to:
● Know/Access: Request information about the categories and specific pieces of personal information we collect, use, disclose, and "sell" or "share".
● Delete: Request deletion of your personal information, subject to certain exceptions.
● Correct: Request correction of inaccurate personal information.
● Opt-Out of Sale/Sharing: Opt-out of the "sale" of your personal information or its "sharing" for cross-context behavioral advertising.
● Opt-Out of Targeted Advertising: Opt-out of the processing of your personal data for targeted advertising (as defined under the laws of Colorado, Connecticut, Utah, and Virginia).
● Limit Use of Sensitive Personal Information: Request to limit the use and disclosure of your sensitive personal information to purposes necessary to provide the services or as otherwise permitted by law.
● Non-Discrimination: Not to receive discriminatory treatment for exercising any of your rights.
8.4.2. How to Exercise Your Rights: You can exercise these rights, including your right to opt-out of the "sale" or "sharing" of your personal information, by:
● Clicking on the link "Your Privacy Choices" or "Do Not Sell or Share My Personal Information" in the footer of our website.
● Contacting our Data Protection Officer at the details provided in Section 11.
● Utilizing the Global Privacy Control (GPC) signal. We will process such signals as a valid request to opt-out.
8.4.3. Verification: We will need to verify your identity before processing most requests, which may require you to provide additional information.
8.4.4. Authorized Agents: You may designate an authorized agent to make a request on your behalf. We will require proof of your consent for the agent to act and will still need to verify your identity directly.
8.4.5. Appeals: In certain states, if we decline to take action on your request, you have the right to appeal our decision.
9. Data Breach Notification
9.1. In the event of a data breach affecting your Personal Data, Labna Capital is committed to complying with the data breach notification obligations under Singapore's Personal Data Protection Act (PDPA).
9.2. What constitutes a data breach: A "data breach" occurs when there is unauthorized access, collection, use, disclosure, copying, modification, or disposal of Personal Data, or the loss of any storage medium or device on which Personal Data is stored in circumstances where the unauthorized access, collection, use, disclosure, copying, modification, or disposal is likely to occur.
9.3. Our Response and Assessment: Upon becoming aware of a suspected data breach, we will promptly activate our internal incident response team to assess the breach and determine if it is notifiable.
9.4. When we will notify:
● Notification to PDPC: We will notify the Personal Data Protection Commission (PDPC) as soon as practicable, but in any case no later than 3 calendar days after assessing that the breach is notifiable. A breach is notifiable if it results in, or is likely to result in, significant harm to the affected individuals, or is of a significant scale.
● Notification to Individuals: If the data breach is likely to result in significant harm to you, we will also notify you as soon as practicable. The notification will include details of the breach, the types of personal data involved, and steps you can take to mitigate potential adverse effects.
9.5. Our Commitment: We are committed to taking all reasonable steps to contain, investigate, and mitigate the effects of any data breach and to prevent future occurrences.
10. Governing Law and Dispute Resolution
10.1. This Privacy Policy and your use of this website shall be governed by and construed in all respects in accordance with the laws of the Republic of Singapore. You shall submit to the non-exclusive jurisdiction of the Singapore courts.
10.2. Your use of this website and any dispute or claim arising out of or in connection with them shall be governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict of law principles.
10.3. Any dispute, controversy, or claim arising out of or relating to these Terms of Use, including the breach, termination, or invalidity thereof, shall be finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.
10.4. The arbitral tribunal shall consist of one (1) arbitrator appointed in accordance with the SIAC Rules. The language of the arbitration shall be English. The arbitration proceedings shall be confidential.
11. Data Protection Officer & Contact Information
11.1. You may contact our Data Protection Officer ("DPO") if you have any enquiries or feedback regarding our personal data protection policies and procedures, or if you wish to make any request regarding your Personal Data (e.g., access, correction, withdrawal of consent).
Data Protection Officer
Email: dpo@labnacapital.com
You may also contact us through our website:
By visiting our contact page: http://labnacapital.com/Contacts
11.2. We reserve the right to make changes to this policy. Any material changes to this policy will be posted on our website.
Introduction
Labna Capital Pte Ltd. (UEN: 202450892G, incorporated in Singapore with its registered office at 68 Circular Road, #02-01, Singapore 049422) and its group of companies (collectively "Labna Capital", "we", "our" or "us") is committed to protecting your personal data.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore ("PDPA") and other applicable laws.
Your Consent
By providing us with your personal data voluntarily, such as by filling out a form, contacting us, or signing an agreement, you consent to our collection, use, and disclosure of your personal data for the purposes described in this policy.
For specific processing activities, such as:
● The use of non-essential cookies and similar technologies for analytics and advertising;
● The sending of marketing and promotional communications;
we will seek your separate, explicit consent through our consent management platform. You have the right to withdraw your consent for any of these purposes at any time by using the "Manage Preferences" or "Manage Cookies" link in our website footer or by contacting our Data Protection Officer.
Please read this Privacy Policy carefully to understand our practices.
1. Personal Data
1.1. In this Privacy Policy, “Personal Data” means any data, whether true or false, which can be related to a specific identifiable individual, whether such individual is identifiable from the data itself, or from other information which is available to us, including data in our records as may be updated from time to time.
1.2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
1.3. The Subject of personal data has the right to request clarification of their Personal Data, its blocking or destruction if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect their rights.
2. Collection of Personal Data
2.1. Labna Capital is committed to protecting and respecting your privacy when you use our website/services. Generally, Labna Capital may collect your Personal Data in several different ways, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, from publicly available sources or through our website
2.2. Whenever you interact with Labna Capital, you may or may be asked to provide us your Personal Data. For example, when you:
● purchase or engage our services through the signing of forms or agreements;
● submit enquiries on products and/or services via our Company email, we may keep information about the enquiry, including your name, your contact details, and the subject matter of your enquiry;
● respond to marketing and promotion activities;
● submit job applications, resume and other information required for the recruitment process;
● subscribe for email alerts or make enquiries on our Investor Relations portal;
● visit any of our premises, you may be asked to provide your personal details to our security officers;
● when you provide us with payment information (all payment transactions are processed securely by our PCI-DSS compliant third-party payment service providers. We do not store, process, or retain your full credit card details(such as full Permanent Account Number (PAN) or CVV/CVC codes) on our servers. The payment data you provide is transmitted directly to our payment processors and is subject to their privacy policies);
● when you enable or utilise services requesting location data; and
● when you submit your Personal Data to us for any other reason.
2.3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the purposes as listed below.
2.4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
If you do not accept and agree to this Privacy Policy, please do not provide your Personal Data to us.
3. Purpose of Collection, Use, Disclosure of Your Personal Data and Storage of Personal Data
3.1. Labna Capital processes Personal Data - operations performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
3.2. Personal data is processed in compliance with the principles and rules provided for by current legislation. The processing of Personal Data is limited to the achievement of specific, predetermined, and lawful purposes.
3.3. Only Personal Data that meets the purposes of its processing is subject to processing. The content and scope of the personal data processed must correspond to the stated purposes of processing.
3.4. Generally, Labna Capital collects, uses and discloses your Personal Data for the following purposes:
● using cookies to ensure the functioning and security of the website, improve the quality of the services, products, and services provided, and generate personalized offers;
● processing requests on the Website;
● monitoring compliance with confidentiality conditions;
● communicating with customers;
● providing access to services, information, and/or materials contained on the Website;
● sell and lease real estate;
● promoting products and services (marketing);
● providing customer service including but not limited to the resolution of complaints, feedback and other after sales services;
● asking for your opinions on Labna Capital products and services and conducting product surveys;
● facilitating and processing your searches and requests for information when you contact us about Labna Capital and its products and services;
● analyzing, investigating, handling, resolving any security matters or any vulnerability;
● providing media announcements and responses;
● organising promotional events;
● legal purposes (including but not limited to obtaining legal advice and dispute resolution);
● conducting investigations relating to disputes, billing or fraud;
● meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Labna Capital (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
● any purposes which are reasonably related to the aforesaid.
3.2. In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.3. Personal Data shall be stored in a form that allows the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by law or by a contract to which the data subject is a party. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve these purposes ceases to exist, unless otherwise provided by law.
4. Marketing Communications & Compliance with Do Not Call (DNC) Requirements
4.1. We may send you marketing and promotional messages via SMS, telephone calls, fax, and other digital messaging services (e.g., WhatsApp) about our products, services, and events that may be of interest to you, but only if you have provided your clear and explicit consent to receive such messages.
4.2. Respecting the Do Not Call (DNC) Registry: In compliance with Singapore's DNC provisions, we will:
● Check the relevant DNC Registry before sending any promotional SMS, fax, telephone call, or other digital message to a Singapore number, unless you have given us clear and unambiguous consent in writing or have been notified that we may contact you for marketing purposes and have not withdrawn such consent.
● Not send such messages to numbers listed on the DNC Registry, unless an exception under the law applies.
4.3. Withdrawal of Consent (Unsubscribe): You can withdraw your consent for receiving marketing communications at any time, free of charge, by:
● Clicking on the "Unsubscribe" link present in any of our marketing emails or SMS.
● Contacting our Data Protection Officer at dpo@labnacapital.com
4.4. We will process your unsubscribe request and cease sending marketing messages within 10 business days of receiving your request.
4.5. Labeling of Messages: In accordance with the Spam Control Act (SCA), our commercial electronic messages (e.g., SMS) will be clearly identified as advertisements and will include accurate sender identification and contact information. SMS messages of a commercial nature will be prefixed with “ADV”.
5. Disclosing and Transferring Personal Data
5.1. Labna Capital will take appropriate and commercially reasonable technical, physical, and administrative measures to protect any Personal Data it possesses or controls from misuse or accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access in accordance with the Act. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
● Labna Capital’s related corporations or affiliates and their employees to provide content, products and services to you or Labna Capital;
● agents, contractors or third party service providers who provide services to Labna Capital;
● any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of Labna Capital’s related corporations or affiliates;
● our professional advisers such as auditors, financial advisers and lawyers;
● relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
● any other party to whom you specifically authorise us to disclose your Personal Data.
5.2. Your Personal Data may be transferred, stored, and processed outside of Singapore, including in countries where data protection laws may differ from those of Singapore. We will ensure that any such international transfer is governed by appropriate safeguards designed to provide a comparable level of protection for your Personal Data. You consent and agree to Labna Capital transferring your Personal Data outside of Singapore for any of the purposes as listed above.
5.3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Labna Capital may not be able to continue to provide its products and/or services to you.
6. Cookies and Similar Technologies
6.1. Our website uses cookies, pixels, local storage, and other similar technologies (collectively, "Cookies and Technologies") to ensure security, analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole.
6.2. Some of these technologies may collect information that constitutes Personal Data, such as your IP address, device identifiers, and online browsing behavior, especially when combined with other information we or our third-party partners may hold.
6.3. We treat information collected by cookies and similar technologies as Personal Data when it can be linked to an identifiable individual or device. This data is used in accordance with this Privacy Policy.
6.4. For detailed information on the specific types of cookies and technologies we use, their purposes, providers, duration, and how to manage your preferences, please refer to our dedicated Cookies and Similar Technologies Policy.
6.5. You can control the use of non-essential cookies and technologies at the individual category level by using the "Manage Cookies" link, which is permanently available in the footer of our website. You can also change your browser settings to refuse cookies. Please note that disabling essential cookies may affect the functionality of our website and your ability to use some of our services.
6.6. Information collected in aggregate form about cookies, similar technologies and tracking may be shared with third parties. Some of our business partners whose content is featured on the site may also use cookies, but we do not have access to or control over them or their websites.
7. Your Rights: Access and Correction
7.1.Under the Personal Data Protection Act (PDPA), you have the right to access and correct your Personal Data in our records.
7.2. To exercise your right to access or correct your Personal Data, please submit a written request to our Data Protection Officer (dpo@labnacapital.com) via the contact details provided in Section 10 of this Policy. For clarity, please indicate "PDPA Access Request" or "PDPA Correction Request" in the subject line of your email or letter.
To process your request, we will need to verify your identity. Please be prepared to provide necessary details for this verification.
7.3. Processing Time and Fees
● Access: We will provide the requested information within 30 calendar days upon successful verification of your identity and receipt of your request. A reasonable fee may be charged for the cost of retrieving and providing the requested information. We will inform you of the fee beforehand.
● Correction: We will process your correction request within 30 calendar days. If we are unable to make the correction within this time, we will inform you of the earliest practicable time within which we can do so. Please note that no fee will be charged for correcting your data.
7.4. Please note that in certain circumstances, we may be permitted under the PDPA to refuse your access or correction request. If we are unable to comply with your request, we will generally inform you of the reasons for refusal within 30 calendar days.
8. Specific Jurisdictional Privacy Rights
8.1. Depending on your country of residence, you may be entitled to specific additional privacy rights under local laws. This section provides information for residents of certain jurisdictions.
8.2. For Data Subjects in Indonesia:
If you are located in Indonesia, the following provisions apply in addition to the rest of this Policy, in compliance with Undang-Undang No. 27 Tahun 2022 tentang Perlindungan Data Pribadi (PDP Law).
8.2.1. Data Subject Rights: In addition to the rights outlined in Section 8 of this Policy, you have the right to:
● Obtain information on the clarity of purpose and legal basis for processing.
● Object to automated decision-making.
● Request the deletion and/or destruction of your Personal Data.
● Withdraw your consent to the processing of your Personal Data.
8.2.2. Cross-Border Data Transfer: We will only transfer your Personal Data outside the territory of the Republic of Indonesia under one of the following conditions, as required by Article 56 of the PDP Law:
● The recipient country has a data protection standard that is equal to or higher than the provisions of the PDP Law (as determined by the Indonesian authorities); or
● We provide adequate and binding protection for the transferred data, through mechanisms such as Standard Contractual Clauses that incorporate data protection principles; or
● We have obtained your explicit consent for the specific transfer after informing you of the potential risks.
8.2.3. Data Breach Notification: In the event of a data breach that significantly impacts your interests, we will notify you and the relevant authorities (Kementerian Komunikasi dan Informatika/ KOMINFO) in accordance with the timelines and procedures stipulated by the PDP Law.
8.2.4. Data Protection Officer: Our Data Protection Officer (DPO), whose contact details are provided in Section 11, also serves as the point of contact for inquiries and requests from data subjects in Indonesia.
Hak-hak subjek data di Indonesia diatur dalam Undang-Undang PDP. Kami mematuhi hukum ini dan menghormati hak-hak Anda. Kebijakan ini menjelaskan cara kami memenuhi kewajiban kami under PDP Law.
8.3. For Data Subjects in the European Economic Area (EEA), United Kingdom (UK), and Switzerland:
● Legal Basis: Our processing of your Personal Data is based on the legal bases outlined in Article 6 of the GDPR, such as consent, contract performance, or legitimate interests.
● International Transfers: When transferring your data outside the EEA/UK to countries not deemed to provide an adequate level of data protection (such as Singapore), we rely on approved transfer mechanisms, such as Standard Contractual Clauses (SCCs).
● Data Subject Rights: You have the right to access, rectify, port, and erase your data, as well as the right to restrict and object to certain processing. You can exercise these rights by contacting our DPO (dpo@labnacapital.com.
8.3.2. Legal Bases for Processing: We rely on the following legal bases for processing your personal data under the GDPR/UK GDPR:
● Performance of a Contract: When processing is necessary for the performance of a contract with you (e.g., providing requested services).
● Consent: For sending marketing communications and using non-essential cookies and similar technologies. You can withdraw your consent at any time.
● Legitimate Interests: For purposes such as security, fraud prevention, and improving our services, where our interests are not overridden by your data protection rights.
● Compliance with a Legal Obligation. When processing is necessary to comply with a legal obligation.
8.3.3. Your Data Subject Rights: In addition to the rights outlined in Section 7 of this Policy, you have the right to:
● Data Portability: Receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.
● Object to Processing: Object to processing based on our legitimate interests. We will cease processing unless we demonstrate compelling legitimate grounds.
● Restriction of Processing: Request the restriction of processing of your personal data under certain circumstances.
● Lodge a Complaint: You have the right to lodge a complaint with your local supervisory authority.
● International Transfers: When transferring your data outside the EEA/UK to countries not deemed to provide an adequate level of data protection (such as Singapore), we rely on approved transfer mechanisms, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
8.4. For For Residents of California, Colorado, Connecticut, Utah, and Virginia
If you are a resident of the states listed above, you have specific rights regarding your personal information under state privacy laws (such as the CCPA/CPRA in California).
8.4.1. Your Privacy Rights: You have the right to:
● Know/Access: Request information about the categories and specific pieces of personal information we collect, use, disclose, and "sell" or "share".
● Delete: Request deletion of your personal information, subject to certain exceptions.
● Correct: Request correction of inaccurate personal information.
● Opt-Out of Sale/Sharing: Opt-out of the "sale" of your personal information or its "sharing" for cross-context behavioral advertising.
● Opt-Out of Targeted Advertising: Opt-out of the processing of your personal data for targeted advertising (as defined under the laws of Colorado, Connecticut, Utah, and Virginia).
● Limit Use of Sensitive Personal Information: Request to limit the use and disclosure of your sensitive personal information to purposes necessary to provide the services or as otherwise permitted by law.
● Non-Discrimination: Not to receive discriminatory treatment for exercising any of your rights.
8.4.2. How to Exercise Your Rights: You can exercise these rights, including your right to opt-out of the "sale" or "sharing" of your personal information, by:
● Clicking on the link "Your Privacy Choices" or "Do Not Sell or Share My Personal Information" in the footer of our website.
● Contacting our Data Protection Officer at the details provided in Section 11.
● Utilizing the Global Privacy Control (GPC) signal. We will process such signals as a valid request to opt-out.
8.4.3. Verification: We will need to verify your identity before processing most requests, which may require you to provide additional information.
8.4.4. Authorized Agents: You may designate an authorized agent to make a request on your behalf. We will require proof of your consent for the agent to act and will still need to verify your identity directly.
8.4.5. Appeals: In certain states, if we decline to take action on your request, you have the right to appeal our decision.
9. Data Breach Notification
9.1. In the event of a data breach affecting your Personal Data, Labna Capital is committed to complying with the data breach notification obligations under Singapore's Personal Data Protection Act (PDPA).
9.2. What constitutes a data breach: A "data breach" occurs when there is unauthorized access, collection, use, disclosure, copying, modification, or disposal of Personal Data, or the loss of any storage medium or device on which Personal Data is stored in circumstances where the unauthorized access, collection, use, disclosure, copying, modification, or disposal is likely to occur.
9.3. Our Response and Assessment: Upon becoming aware of a suspected data breach, we will promptly activate our internal incident response team to assess the breach and determine if it is notifiable.
9.4. When we will notify:
● Notification to PDPC: We will notify the Personal Data Protection Commission (PDPC) as soon as practicable, but in any case no later than 3 calendar days after assessing that the breach is notifiable. A breach is notifiable if it results in, or is likely to result in, significant harm to the affected individuals, or is of a significant scale.
● Notification to Individuals: If the data breach is likely to result in significant harm to you, we will also notify you as soon as practicable. The notification will include details of the breach, the types of personal data involved, and steps you can take to mitigate potential adverse effects.
9.5. Our Commitment: We are committed to taking all reasonable steps to contain, investigate, and mitigate the effects of any data breach and to prevent future occurrences.
10. Governing Law and Dispute Resolution
10.1. This Privacy Policy and your use of this website shall be governed by and construed in all respects in accordance with the laws of the Republic of Singapore. You shall submit to the non-exclusive jurisdiction of the Singapore courts.
10.2. Your use of this website and any dispute or claim arising out of or in connection with them shall be governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict of law principles.
10.3. Any dispute, controversy, or claim arising out of or relating to these Terms of Use, including the breach, termination, or invalidity thereof, shall be finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause.
10.4. The arbitral tribunal shall consist of one (1) arbitrator appointed in accordance with the SIAC Rules. The language of the arbitration shall be English. The arbitration proceedings shall be confidential.
11. Data Protection Officer & Contact Information
11.1. You may contact our Data Protection Officer ("DPO") if you have any enquiries or feedback regarding our personal data protection policies and procedures, or if you wish to make any request regarding your Personal Data (e.g., access, correction, withdrawal of consent).
Data Protection Officer
Email: dpo@labnacapital.com
You may also contact us through our website:
By visiting our contact page: http://labnacapital.com/Contacts
11.2. We reserve the right to make changes to this policy. Any material changes to this policy will be posted on our website.