Privacy Policy

Personal Data Protection Act 2012 of Singapore

Last Updated: 27/01/2026

1. Introduction

Mars Equity M.C. Pte. Ltd. (the “Company”) is incorporated in Singapore and licensed and regulated by the Monetary Authority of Singapore.

This Privacy Policy describes how the Company collects, uses, discloses, retains, and protects personal data in accordance with the Personal Data Protection Act 2012 of Singapore, as amended from time to time (“PDPA”).

2. Personal Data and Consent

In this Privacy Policy, “personal data” has the meaning given in the PDPA and refers to data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the Company has or is likely to have access.

By accessing, using or browsing this website, or submitting information to the Company (whether through the Company’s website, forms or otherwise), you consent to the collection, use and disclosure of your personal data by the Company in the manner set out in this Privacy Policy. For avoidance of doubt, this Privacy Policy supplements and does not supersede or replace any other consent you may have previously provided to the Company.

Depending on the nature of your interaction with the Company, the Company may collect your personal data in situations including when you:

• browse the Company’s website (please refer to the section 10 below);
• submit requests, feedback, inquiries or online forms on the Company’s website;
• indicate your interest in pursuing a career with the Company or our affiliates;
• submit a job application form, resume and/or CV;
• request for the Company’s officers or marketing agents to contact you;
• interact with any of the Company’s officers or marketing agents (whether over email correspondence, telephone conversations or face-to-face meetings or otherwise);
• respond to the Company’s further requests for personal data;
• take part into any events organized solely or jointly by the Company; or
• enter into agreements with the Company.

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Depending on the nature of your interaction with the Company, the Company may collect personal data including but not limited to: 

• Name, contact details (e.g. phone number and e-mail address), and identifying information (e.g. date of birth, identification number, nationality, gender, address)
• Identification, verification, and due diligence information
• Investor, shareholder, business, employment, or professional information
• Correspondence and records of communications 
• Information provided in connection with enquiries, applications, or employment 

If you provide the Company with any personal data relating to a third party, by submitting such information to the Company, you represent and warrant to the Company that you have obtained the requisite consent of such third party and are authorized to provide the Company with such personal data on the terms and conditions contained in this Privacy Policy.

3. Purposes for Collection, Use, and Disclosure

The Company may collect, use, and disclose your personal data for purposes that a reasonable person would consider appropriate in the circumstances, including:

• Managing investment, fund management, investor relations, and related activities
• Carrying out instructions given by (or purported to be given by) you or on your behalf
• Verifying your identity, conducting customer due diligence, KYC, AML, sanctions screening, and regulatory checks (including to detect, prevent and investigate any fraud, bribery, corruption or any act or omission which constitutes a violation of any law)
• Complying with applicable laws, regulations, guidelines, notices, directions, and requests from regulatory or supervisory authorities
• Communicating with you and responding to enquiries or requests (whether via phone/voice call, text message, fax message, email and/or postal mail)
• Managing the Company’s infrastructure, business operations, internal controls, risk management, security, compliance, and business continuity management (including carrying out administrative, operational and technology tasks (including technology infrastructure maintenance and support, application maintenance and support, risk management, systems development and testing) and complying with policies and procedures (such as those related to audit, finance and accounting, billing and collection) 
• Conducting data analytics for system and process improvements
• Protecting, enforcing and complying with the Company’s legal rights and obligations
• Recruitment, employment, and human resource management purposes, where applicable
• Storing, hosting, backing up (whether for disaster recovery or otherwise) 
• Any other purposes related to the above

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Additionally, subject to applicable law, if you attend events organized solely by the Company or jointly by the Company and a third party, photographs and/or video recordings may be taken at such events, and may be used and disclosed for the Company’s marketing and/or promotional purposes. Such photographs and videos may be published on the Company’s website, social media channels or made publicly available to recipients overseas for our marketing and/or promotional purposes.

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The Company will not collect, use, or disclose personal data for purposes other than those for which it was collected, except with consent or as permitted or required under the PDPA.

4. Consent

The Company will obtain an individual’s consent before collecting, using, or disclosing personal data, except where consent is not required under the PDPA. By accessing, using or browsing this website, or submitting information to the Company (whether through the Company’s website, forms or otherwise), you consent to the collection, use and disclosure of your personal data by the Company in the manner set out in this Privacy Policy. For avoidance of doubt, this Privacy Policy supplements and does not supersede or replace any other consent you may have previously provided to the Company.

An individual may withdraw consent at any time by giving reasonable notice to the Company by contacting the data protection officer (contact details in Section 14 below). Please note that withdrawal of consent may result in the Company being unable to continue providing services or engaging with the individual, where such personal data is required for legal or operational purposes.

5. Disclosure of Personal Data

The Company may disclose personal data to third parties for the purposes described above, including:

• Government agencies, regulators, and law enforcement authorities for the purposes of compliance with applicable law and regulations, court orders, arbitral awards or other requests
• Professional advisers such as auditors, lawyers, and accountants
• Service providers and vendors engaged by the Company (including those engaged to provide administrative, operational, market research, data storage or other services)
• Counterparties, investors, or portfolio companies, where relevant
• Any party to whom the Company may assign or transfer our rights or obligations
• Any other party to whom you authorize the Company to disclose your personal data

The Company will take reasonable steps to ensure that third parties receiving personal data are bound by confidentiality and data protection obligations.

6. Accuracy

The Company will make reasonable efforts to ensure that personal data in its possession or control is accurate and complete, particularly where the personal data is likely to be used to make a decision affecting the individual or disclosed to another organisation.

7. Protection

The Company will make reasonable security arrangements to protect personal data in its possession or control against unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.

Access to personal data is restricted to authorised personnel on a need-to-know basis.

8. Retention Limitation

The Company will retain personal data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws.

Where personal data is no longer required, the Company will take reasonable steps to securely dispose of or anonymise the personal data.

9. Transfer of Personal Data Outside Singapore

Where the Company transfers personal data outside Singapore, it will take appropriate steps to ensure that the transferred personal data is accorded a standard of protection comparable to that under the PDPA.

10. Use of Cookies

When you visit the Company’s website, the Company may use cookies, web beacons or other similar technology to collect and store information so that the Company can provide you with a better and faster web experience. A cookie is a small text file placed in the memory of your device or browser when you visit a website, to allow the website to recognize your device or browser.

Such cookies may convey information about you to the Company (such as the unique identifier of your browser, the pages you view, and the links to the different business segments you click on). The cookies are readable only by the Company and cannot access, read or modify any other data on your device.

Cookies can be disabled or removed by tools that are available in most browsers. The preferences for each browser you use will need to be selected separately and different browsers offer different options, please review your browser settings accordingly. However, please note that if you decline cookies and such other similar technologies, you may not be able to enjoy certain specific website features or service tools.

11. Access and Correction

Subject to the PDPA, an individual may request access to personal data in the Company’s possession or control, or request correction of inaccurate or incomplete personal data.

Requests must be made in writing to the data protection officer (contact details at Section 14 below). The Company will respond within the time prescribed under the PDPA and may charge a reasonable fee where permitted.

12. Links to Other Websites

The Company’s website may contain links to other third-party websites. The Company is not responsible for the privacy practices of such third-party websites. When you access third-party websites linked on the Company’s website, please read the applicable privacy policies for those third-party websites. 

For avoidance of doubt, this Privacy Policy applies only to this website.

13. Data Breach Notification

The Company has implemented procedures to identify, assess, and manage personal data breaches.

Where a data breach is notifiable under the PDPA, the Company will notify the Personal Data Protection Commission of Singapore and affected individuals in accordance with statutory requirements.

14. Data Protection Officer

The Company has appointed a Data Protection Officer to oversee compliance with the PDPA.

Contact details:
Email: Personal_Data_Protection@Dragonfunds.com
Attention: Data Protection Officer

15. Updates to This Policy

The Company may amend this Privacy Policy from time to time.
The latest version of this Privacy Policy will be made available on the Company’s website.

16. Governing Law

This Privacy Statement shall be governed in all respects by the laws of Singapore.