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Privacy Policy

NonPublic Group

Privacy Policy

(Last updated: 8 April 2025)

NonPublic Holdings Pte. Ltd. (UEN 202423860C), a company incorporated under the laws of Singapore, and its affiliates, subsidiaries and related entities – including NonPublic Pty Ltd (ACN 607 216 928), a company incorporated under the laws of Australia – together form the NonPublic Network (also referred to as the NonPublic Group).

NonPublic Pty Ltd is the operator of the NonPublic Platform, an exclusive platform that facilitates access to and participation in private market investment opportunities.

This Privacy Policy sets out the basis which the NonPublic Group (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal information and data in the course of our business activities and your interactions with us, which includes, without limitation:

  1. your access to and use of the NonPublic Group website at https://www.nonpublic.io/ (the “Website”) and the associated NonPublic Platform at https://app.nonpublic.io/ (the “Platform”), as well as any other websites, platforms or digital services that are or may be operated by the NonPublic Group; and
  2. the services and content we provide, whether through the Website, the Platform or otherwise (such services, the “Services”, and such content, the “Content”).

In this Privacy Policy, unless the context otherwise requires, "personal data" or “personal information” means information (and in Australia, includes an opinion), whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable, and includes (i) information that identifies an individual on its own or in combination with other information we have or are likely to have access to, and (ii) any other similar definition under applicable personal data protection laws.

This Privacy Policy takes into account the applicable privacy and data protection laws in the jurisdictions in which we operate, including, but not limited to, the Australian Privacy Act 1988 and the Personal Data Protection Act 2012 of Singapore. This Privacy Policy applies generally to all users, regardless of location. However, certain sections herein or supplements to this Privacy Policy (which may be issued from time to time) may address additional requirements applicable to users in specific jurisdictions.

This Privacy Policy may be supplemented or amended at our sole discretion from time to time. We encourage you to periodically review this Privacy Policy to be informed about how we are protecting your personal information.

By using the Website, the Platform and/or the Services, or otherwise engaging with us, you are agreeing to the collection and use of your personal information as described in this Privacy Policy.

1. Aggregate Data

We may generally record certain usage information, such as the number and frequency of visitors to the Website and the Platform. This information may include the websites that you access immediately before and after your visit to our site, the internet browser you are using, and your IP address. If we use such data at all, it will be on an aggregate basis, and we will not disclose to third parties any usage information that could be used to identify you personally.

2. Cookies

A “cookie” is a small text file placed on your computer or other device for user authentication and analytics.

The Website and Platform may utilise automated tracking devices or software such as “cookies” and identifiers for mobile devices (e.g., Android Advertising Identifier or Advertising Identifier for iOS) to distinguish you from other users of the Website and Platform and to help us to provide you with better user experience. By continuing to use the Website, Platform and/or the Services, you consent to our use of cookies and such other tracking devices and software.

Some cookies may be erased when you exit the Website and/or Platform or close the browser, while others may be saved on your device for future visits. You can delete all cookies placed by our Website and/or Platform on your device at any time. You can also set your browser to prevent all cookies from being placed by our Website and/or Platform or to provide you with a warning before a cookie is placed. However, please note that some functionalities of the Website and/or Platform may not work if all cookies are rejected or disabled. Please check your browser’s instructions or help screen to learn more about these functions.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we do not have any control over. These cookies are likely to be analytical/performance cookies or targeting cookies.

3. Google Analytics

We use Google Analytics and other Google services to analyse website traffic and usage. Google Analytics uses cookies to collect data about how users engage with our Website and/or Platform, such as how much time is spent on the site, which pages are visited, and how users navigate through the site. Based on browser settings, additional data such as location and language may also be collected. The reports provided by Google Analytics help us understand these interactions to improve user experience.

Additionally, we may use Google Ads for remarketing purposes, which means that Google may display ads to you based on the pages of our Website/Platform you have visited or interacted with.

For more information on how Google uses data, please refer to Google's Privacy & Terms and Google's Cookie Policy.

4. Meta Pixel

We may also use Meta Pixel, a tool provided by Meta, to track user interactions with our website(s) and measure the effectiveness of our ads on Facebook and other Meta platforms. This allows us to deliver more relevant ads to you based on your activity.

For more information on how Google uses data, please refer to Meta's Privacy Policy.

5. Collection of Personal Information

If you are a visitor of the Website, Platform and/or any of our other websites, you do not have to submit any personal information in order to use such platform/website(s). We only collect personal information that is specifically and voluntarily provided by you for the purpose which such personal information is collected, for example, when you send an expression of interest, opt to subscribe to our newsletter, register as a user on the Platform or register for access to specific content, or request communications about specific areas of interest. Such information collected may consist of, but is not limited to:

  • name and contact details, including your email address, telephone number, and address;
  • date of birth;
  • gender;
  • nationality and country of birth; and
  • employment details, such as your current job title, employer and career history.

For investors and other users of the Website, Platform and/or the Services, we may request and collect additional personal information from you, such as:

  • identification documents, such as a copy of your identity card or passport;
  • financial information;
  • details on your background and business;
  • details on your source of funds; and
  • any other information required (i) in connection with our KYC or onboarding processes, in compliance with applicable laws and legal obligations, particularly in relation to AML/CTF, (ii) to facilitate or carry out the activities contemplated by or ancillary to the Services, and/or (iii) in connection with any other incidental business purposes related to or in connection with the foregoing.

Generally, we may also collect, store and maintain any personal information that you provide to us through the following ways:

  • through application or subscription forms in relation to your participation in any activity conducted by us, such as collaborative, joint venture, project and investment opportunities;
  • job applications;
  • by email or other written mechanisms;
  • over a telephone call;
  • in person;
  • through transactions;
  • by technology that is used to support communications between us; and
  • through publicly available information sources (which may include telephone directories, the internet and social media sites).

Do not provide personal information to us, unless you consent to our use of that information for our legitimate business purposes.

“Sensitive Information” is a sub-set of personal information that is given a higher level of protection under certain data protection legislation. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. Unless otherwise permitted by applicable law, we will not collect sensitive information about you without first obtaining your consent.

Provided you consent, your sensitive information may only be used and disclosed for purposes you have consented to or which are directly related to the primary purpose for which the sensitive information was collected, including:

  • for the purpose of us maintaining a comprehensive company file;
  • for the purpose of information compilation or analysis for internal purposes; and
  • in an anonymised format for the purpose of information compilation or analysis to share with third parties.

Sensitive information may also be used or disclosed if required or authorised by law.

6. Information from Third Parties

In addition to the information we collect directly from you, we may also receive personal data and information about you from third parties. This can include information from:

  • members of the NonPublic Network, such as special purpose vehicles administered, managed, controlled or operated by the NonPublic Network which you may have previously made an investment in. Personal information which we receive pursuant hereto will be used to collate and consolidate, for example, your investment history, to facilitate the Services and enhance your user experience;
  • our business partners and service providers, such as payment processors, corporate services providers, analytics providers, advertising partners and third parties whom we might engage to conduct background checks, who may share information with us to facilitate our services, improve our platform, or enhance your user experience;
  • social media or other third-party platforms. For ease, we offer you the option to sign in or create an account on the Platform using your social media or other third-party account credentials, such as Apple-ID or Google Sign-In. if you choose to link your social media account(s) or sign in using such social media or other third-party account credentials, we may receive information from the respective social media/third-party platform. This may include your profile information, user ID, and friends list, depending on your settings and permissions;
  • recruiters or other businesses in our network;
  • publicly available sources – we may also collect information about you that is publicly available, such as information from news articles, public databases, or other online resources; and
  • other users – we may collect information about you from other users of our Website, Platform and the Services, for example, if you are engaged in any dealings via the Platform or if such user shares content with you.

We take steps to ensure that any information received from third parties is treated with the same level of care and security as the information we collect directly from you, in accordance with applicable law.

7. Use of Personal Information

Information we receive, whether from you directly or from a third party, may be used as follows:

General

  • performing obligations in the course of or in connection with our dealings with you;
  • verifying your identity;
  • facilitating transactions, dealings and activities contemplated by or ancillary to the Services;
  • responding to, handling, and processing queries, requests, applications, and feedback from you;
  • managing your relationship with us;
  • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • any other purposes for which you have provided the information and consented to the use thereof; and/or
  • any other incidental business purposes related to or in connection with the above.

When you visit the Website and/or Platform or otherwise interact with us

  • to provide the Website and Platform to you;
  • to contact and communicate with you about any enquiries you make with us;
  • for analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms; and/or
  • for advertising and marketing, including to send you promotional information about our products and services and other information that we consider may be of interest to you.

When you pitch your company to us

  • to assess your application and complete any due diligence;
  • to invest in your company and undertake any associated transactional steps;
  • to send you onboarding materials;
  • for internal record keeping and administrative purposes;
  • to contact and communicate with you; and/or
  • to provide advice, support and ongoing commercial assistance.

When you invest in, or apply to invest in our investment vehicles

  • to process an investment application from you and establish your investments in the relevant vehicle(s);
  • to manage our relationships with you and administer any investment you have with us;
  • for internal record keeping and administrative purposes;
  • to provide you with information about our investment vehicles and portfolio investments; and/or
  • to send onboarding materials.

When you apply for employment with us, are part of our talent network or provide us with services as a contractor

  • to assess your application;
  • where you are a contractor or employee, to onboard you;
  • to connect people within our community;
  • for internal record keeping, administrative, invoicing and billing purposes; and/or
  • to contact and communicate with you.

The purposes listed in the above paragraphs may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.

8. Disclosure of Personal Information and Data Transfers

We may disclose your personal information to third parties:

  • where such disclosure is required for performing obligations in the course of or in connection with our business or dealings with you;
  • where such disclosure is required for facilitating or carrying out the Services and the transactions, dealings and activities contemplated thereby or ancillary thereto. For example, if you participate in an opportunity that is presented or listed on the Platform as part of the Services, information about you may be disclosed to, for example, the relevant parties for KYC purposes;
  • if and when we introduce you to third parties, such as our portfolio entities or other entities within our network;
  • such as third-party service providers (including, without limitation, accounting and technology, corporate services and IT/admin service providers), contractors, professional or other advisors, agents, partners, and other organisations we have engaged in connection with our business, who may either require your personal information in fulfilment of their duties, or may have access to this information;
  • to comply with legal or regulatory obligations or requests, including disclosures to the relevant courts, tribunals, regulatory authorities, law enforcement agencies, or government bodies as required under applicable laws.

Additionally, your personal information may be shared with entities within the NonPublic Network for internal corporate compliance purposes, and/or in order to provide you with information that could be of interest to you and conduct market or other research. Personal information may also be disclosed to other entities within the NonPublic Network and other third parties (a) in order to respond to your requests or inquiries, (b) to share joint venture, project, collaborative and/or investment opportunities and deal flow, or (c) in the course of engaging in activities that are customary in our industry.

All of these disclosures may involve the transfer of personal information across geographical borders and to countries or regions without data protection rules similar to those in effect in your area of residence.

We may also store your personal information in the cloud, in other types of networked or electronic storage or in servers in a jurisdiction outside the country where the purpose is provided or where you are based. These countries/regions may change from time to time, and, if practicable and as qualified by the following sentence, we can provide a current list upon written request. As electronic or networked storage can be accessed from various countries via an internet connection, it’s not always practicable to know in which country your information may be held. Additionally, overseas organisations may be required to disclose information we share with them under a foreign law. In those instances, we will not be responsible for that disclosure.

Whenever we transfer personal information beyond the country/region of origin, we will do so in accordance with applicable laws, and will use reasonably appropriate safeguards for such transfer.

By providing personal information on our Website, Platform and/or through any other channel managed by us, you consent to such transfer and/or storage of personal information across borders, in accordance with the purposes described herein and applicable law.

9. Retention of Personal Information

We will retain your personal information for as long as the information is reasonably required to fulfil the purpose collection of the information or until you request that we delete that information.

10. Information Security

We have in place reasonable commercial standards of technology and operational security for an organisation of our size to protect all information in our possession from unauthorised access, disclosure, alteration, or destruction.

In the event that there is a security breach involving your personal data, we will inform you of the incident in accordance with the relevant data protection laws.

11. Your Rights

Access or Updates to Personal Information

If you would like to request access to your personal information, to update your details, or unsubscribe from communications, please contact us at privacy@nonpublic.io.

In all cases, we will treat requests to access information or change information in accordance with applicable legal requirements.

Questions, Restricting Disclosure, Withdrawal of Consent or Complaints

If you have any questions regarding this Privacy Policy, or if you would like to: (a) restrict or object to any processing or disclosure of your personal information, (b) withdraw your consent (where we rely on consent as the legal basis for processing at any time), or (c) make a complaint, please contact our Data Protection Officer at privacy@nonpublic.io.