These regulations for protected Personal Data have been prepared for the purpose of explaining the details and as guidelines for the accurate, suitable, and safe collection, compilation, storage, use, and disclosure of Personal Data in order to protect the rights of Personal Data owners such as customers, service users, employees or stakeholders who provide Personal Data to the Company either directly or through the Company's information technology system and for practice in compliance with the tenets set forth in the Personal Data Protection Act (2012) (PDPA).
Company, “we”, “us” or “our” means 9 Basil Limited Partnership, 9 Basil Pte. Ltd., 9 Basil Fund 2 LP, and 9 Basil Fund 2 Pte. Ltd. (the 9 Basil Funds), each of the direct or indirect subsidiaries of 9 Basil Funds (the "9 Basil Group") and 9 Basil Group managed products. 9 Basil Funds, 9 Basil Group functions, and the entity you contract with are the controllers of your Personal Data.

Personal Data means information about a person that can be used to either directly or indirectly identify said person. An officially Authorized Person is a person whom the highest-ranking executives have assigned to oversee, take responsibility for, and perform work. Cookies mean tiny components of data stored in the equipment of customers or service users or stakeholders enabling the website to store as memory in accessing the website or methods for each use of the website.
References to "you" or "your" refer to individuals whose Personal Data is processed by the Company, including individual investors and client employees, officers or agents (together "Representatives") with direct or indirect relationships (such as those who invest through an intermediary); and beneficial owners of an organization or entity in connection with:
  • the provision of services to potential and actual clients;
  • transactions to which we are party (including those which we effect on behalf of clients); or
  • services provided to us by a third-party vendor.
The Company respects and gives importance to Personal Data rights and Personal Data protection. In addition, the Company is well aware that you need security and safety when using services. Personal Data received by the Company and/or the Company's group, such as names, age, addresses, telephone numbers, identification numbers, and financial information, etc., which can identify the data owner and are complete, accurate, up-to-date and quality Personal Data will be used only in line with the Company's operating objectives. The Company enacts strict security measures and prevents Personal Data from being used without permission from data owners. The Company will report breaches of Personal Data to data owners immediately when violations occur.
The Company collects Personal Data from various channels. Personal Data collected by the Company might include the following types (the PI listed for each category are non-exhaustive examples):
  1. Data Provided Directly by Customers, Service Users or Stakeholders
    • Contact data
      Personal address, telephone number, email address.
    • Financial data
      Account number, client reference number, account statements, and investment history.
    • Marketing, Behavioral, and Communications data
      Marketing and communication preferences; information about your use of our websites, our portals and platforms as explained in our Cookie Notice.
    • Professional Information data
      Position/job title, business address, business telephone number, business email address.
    • Profile data
      Username and password for our online services that you have access to, investments made by you, services requested, marketing communications responded to survey responses.
    • Services data
      Payment details to and from you, details of services you have provided to us, or we have provided to you.
    • Technical data
      Your use of and interaction with our online services, your IP address browser type and version, browser plug in types and versions operating system.
    • Sensitive Personal Information
      In limited circumstances we may collect information about criminal convictions and offences, when legally required; dietary requirements, if we are arranging catering; disability, to make reasonable accommodations for you in our buildings; political affiliations, for us to determine whether you are a politically exposed person.
  2. Data Used by Customers, Service Users or Stakeholders
    • Technical data
      Your use of and interaction with our online services, such as IP numbers, dates and times of use, equipment code, equipment type, mobile phone network data, connection data, geographic positioning data, browser type, website entry-exit logging data, referring website data, website history data, login logs and transaction logs.
    • Electronic Monitoring data
      To the extent permitted by law, we may record and monitor your electronic communications with us.
    • Audio recording data
      To the extent permitted by law, we may record and monitor your audio recording data when communications are made to the Company or logs of contact details.
    • We may collect data created by analysis and collection of statistics on the use of services or systems, such as customer behavior, website entry statistics, website access time, searched data, use of website functions, and data collected by the Company through cookies
Unless we otherwise indicate that the provision of specific Personal Data is optional, any Personal Data we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.
The Company stores the aforementioned Personal Data for objectives in the Company's legal operations and to enhance the Company's operations. The Company stores only necessary Personal Data for operations such as the following:
  • For reports/activities involving the Company's business activities.
  • For delivering the services you have requested, including liaising with third parties and providing access to our technology solutions services.
  • For the benefit of studies, research, and statistics.
  • For entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud, and other due diligence checks.
  • For managing payments, fees, and charges and to collect and recover money owed to the Company.
  • For managing our relationship with you, which will include notifying you about changes to our terms of business or this privacy notice.
  • For interacting with governmental or regulatory bodies or other competent national authorities.
  • For managing and protecting our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities.
  • For development of services, marketing, advertisement, sending newsletters on products and promotions related to the Company's products and services.
  • For detecting or preventing fraud and/or other criminal activity and to protect our employees and assets.
  • For marketing communications and service updates (including by paper and electronic channels), to better understand how our websites and platforms are used and to improve user experience.
  • For improvement, development, and enhancement of the Company's operations.
  • For accepting complaints, recommendations, criticisms or for expressing opinions.
  • For contacting data owners via any channels to make inquiries, notifications, examinations, and confirm data related to data owners or survey opinions as necessary.
  • For checking data in compliance with the law and associated criteria and rules currently enforced and future revisions or additions.
If Personal Data collection objectives change afterward, the Company will notify or advertise objectives to data owners without hesitation.
To facilitate the Company's business operations or perform the Company's duties to customers, the Company may disclose Personal Data to service providers who are third parties, representatives, subsidiaries, or associated persons located domestically or abroad for any objective of Personal Data storage, utilization, disclosure, and processing. Furthermore, the Company may disclose Personal Data to government officials or agencies to comply with laws, rules, guidelines, regulations, or management systems enforced on the Company. The Company will require third-party agencies to maintain the secrecy and safety of Personal Data, and the Company forbids the use of the aforementioned Personal Data for any objectives other than those specified by the Company. The following examples are examples of third parties to whom the Company may disclose personal data:
  • Other members of the 9 Basil Group;
  • Professional advisors, third parties, agents, or independent contractors that provide services to any member of the 9 Basil Group (such as IT systems providers, data import service providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants);
  • Goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them), intermediaries, brokers, management service providers, and operation service providers involved in the Company's business such as telecommunications, information technology, logistics, product transformation, assembly, installation, publication, postal services or marketing services and sales promotion activities and other individuals and entities that partner with us;
  • competent authorities (including any national and/or international regulatory or enforcement body, agency, court, or other form of tribunal or tax authority) or their agents where the Company is required or allowed to do so under applicable law or regulation;
  • a potential buyer, transferee, merger partner, or seller and their advisers in connection with an actual or potential transfer or merger of part or all of the Company's business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it;
  • credit reference agencies or other organizations that help us conduct anti-money laundering and anti-terrorist financing checks, detect fraud and other potential criminal activity
  • any person to whom disclosure is allowed or required by local or foreign law, regulation, or any other applicable instrument; and
  • third parties with whom the Company engages in business have the right to use Personal Data for only operations specified in contracts made with the Company. Part of the specifications in contracts made by the Company with third parties require the aforementioned persons to comply with any laws and policies specified by the Company, and these persons must use appropriate measures to ensure that your Personal Data will be protected and safe.
Where the Company is about to use the personal data for purposes other than the original purpose, the Company must inform the customer and seek the customer's prior consent unless the Company has determined that:
  • the purpose is within the scope of the purposes for which the individual concerned had originally been informed (e.g., if it would fall within the Company's servicing of the existing business relationship with the individual); and
  • whether consent can be deemed to have been given by the individual in respect of use or disclosure for that purpose.
In certain circumstances, you may have the following rights in relation to the processing of your Personal Data:
  • To know, access, Object, Correct, restrict, delete, revise or ask to check Personal Data.
  • To not accept any marketing communication data from the Company.
  • To ask the Company to send or transfer Personal Data to other Personal Data controllers when able to do so automatically. You may notify the Company of objectives and identification in writing. When the Company accepts the aforementioned request, the Company will notify the existence or details of data-to-data owners within an appropriate time.
Requests pursuant to the rights of yours will be considered and recorded. The Company will consider taking action based on your requests only after the Company checks and finds no conflicts with any specifications of the law, which the Company is required to comply with. To the extent permitted by applicable law or regulation, the Company reserves the right to charge an appropriate fee in connection with you exercising your rights.

The Company may need to request specific information from you to help us confirm your identity and ensure your right to access the Personal Data requested or to exercise any of your other rights. This is to ensure that Personal Data is not disclosed to any person who does not have the authority to receive it. We may also request further information in relation to your request to help us to locate the Personal Data processed in relation to you, including, for example, the nature and location of your relationship with us.

We will respond to all legitimate requests in line with the timescales set out in applicable law.
To manage Personal Data safely and appropriately, the Company has security and safety measures to prevent unauthorized or unlawful loss, access, use, edition, revision, or disclosure of personal data.

Once the Company has credible grounds to believe that a data breach has occurred, the Company is required to take reasonable and expeditious steps to assess whether the data breach is notifiable under the PDPA and to notify the affected individuals and/or the Personal Data Protection Commission ("PDPC") where it is assessed to be notifiable. The Company is required to perform the assessment within 30 calendar days.

Where the data breach is assessed to likely result in significant harm or impact to the affected individuals, or if the data breach is of a significant scale (i.e., involving the personal data of 500 or more individuals), the Company shall notify the Personal Data Protection Commission ("PDPC") as soon as practicable and not later than three (3) calendar days, and the affected individuals as soon as practicable.
The Company appointed Personal Data protection officers with the duty to oversee compliance with this policy. If you have questions concerning this policy or wish to send petitions under any rights, you can contact the Customer Center at [email protected] or the Company’s website at
The Company may modify this policy to be consistent with changes in the it's operations in response to recommendations or opinions from you or to make modifications in line with legal requirements. If revisions or changes are made to this policy, the Company will announce changes to you before making changes via or the Company may send notifications to remind you directly.
You agree and acknowledge that this Personal Data protection policy is effective on all Personal Data collected by the Company, and you agree for the Company to have the right to collect, store, use, or disclose Personal Data collected by the Company (if any), including Personal Data currently collected by the Company or Personal Data to be collected by the Company to other persons within the scope specified in this Personal Data protection policy.
Terms and Conditions of Use
These Terms and Conditions of Use (the "Terms of Use") apply to the 9Basil Group website located at and all associated sites linked to by 9Basil Group, its subsidiaries and affiliates (collectively, the "Site"). The Site is the property of 9Basil Group ("9Basil") and its licensors.


Limited Right to Use:
9Basil grants you a limited right to use the Site. Your right to use the Site is subject to your agreement to abide by these Terms of Use in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. At any time and for any reason 9Basil may revoke your right to use all or any portion of the Site.
Updates to the Site:
9Basil reserves the right, at its sole discretion, to change, modify, add or remove portions of these Terms of Use, at any time. It is your responsibility to check these Terms of Use periodically for changes. Such changes shall be effective immediately upon posting. Your continued use of the Site following the posting of changes will mean that you accept and agree to the changes.
Site Security:
You are prohibited from violating or attempting to violate the security of the Site. This includes tampering with any part of the Site, providing false or inaccurate information, misrepresenting your identity, or engaging in fraudulent activities on the Site, whether directly or through agents. Any such actions constitute a violation of these Terms of Use.
You are prohibited from violating or attempting to violate the security of the Site, including, without limitation, (a) accessing data not intended for you or logging into a server or an account which you are not authorized to access; (b) disabling, removing, defeating, or avoiding any security device or system, including, without limitation, any password and login functionality used to authenticate users; (c) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; (d) attempting to interfere with service to any user, host or network, including, without limitation, via means of submitting a virus to the Site, overloading, “flooding,” “mailbombing” or “crashing;” (e) forging any TCP/IP packet header or any part of the header information in any email or posting; (f) scraping or otherwise collecting data or information through automated means; (g) removing any notices, warnings, labels, annotations or instructions from any portion of the Site or any related material, including, without limitation, any patent, trademark, copyright, or other proprietary notices or license provisions; or (h) otherwise invading the privacy of, obtaining the identity of, or obtaining any personal information about any user of the Site. Violations of the Site security may result in civil or criminal liability. 9Basil will investigate occurrences which may involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting those who are involved in such violations.
Ownership of Materials on Site:
You may not download or copy content on the Site unless such download is expressly permitted in writing on the Site. No right, title or interest in any downloaded materials or software is transferred to you as a result of any such downloading or copying. You may not reproduce (except as noted above), publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any of the Site, any content thereof, or any related software.
All content included on the Site, such as text, images, graphics, logos, articles and other materials, is the property of 9Basil or third parties who have licensed their materials to 9Basil, as applicable, and is protected by Singapore and international copyright and other laws.
All trademarks and logos displayed on the Site are the property of their respective owners, who may or may not be affiliated with 9Basil. Nothing contained on the Site shall be interpreted as granting, any license or right to use any content or trademark displayed on the Site without the express written permission of 9Basil or such other third party that may own the content or trademark displayed on the Site. Nothing in these Terms of Use shall constitute a waiver of any trademark or other intellectual property rights concerning name, logo or trademark.
9Basil may collect certain aggregate and non-personal information when you visit the Site. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Site features.
No Offers or Reliance:
This Site is for information purposes only and is not intended to be relied upon as a forecast, research or investment advice. Nothing on this Site should be construed as a recommendation, offer or solicitation to buy or sell any securities of 9Basil or any other issuer.

While 9Basil uses reasonable efforts to obtain information from reliable sources, 9Basil makes no representations or warranties as to the accuracy, timeliness or completeness of any information or document at the Site. The Site contains forward-looking statements, which reflect our views with respect to, among other things, the operations and financial performance. Such forward-looking statements are subject to various risks and uncertainties and speak only as of the date on which they are made. Forward-looking statements are subject to various risks and uncertainties. You can identify these forward-looking statements by the use of words such as “outlook,” “believe,” “expect,” “indicator,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “intend,” “will,” “plan,” “optimistic,” “estimate,” “anticipate” or the negative version of these words or other similar expressions. 9Basil undertakes no obligation to publicly update or amend any information on the Site, regardless of whether it's due to new information, future developments, or otherwise. Opinions and content on the Site may change without prior notice.

9Basil does not use the Site to offer investment or any other advice. None of the information or materials on the Site should be deemed as a recommendation to buy or sell securities or as a basis for making investment decisions. Moreover, no information, content, or other materials on the Site should be interpreted or relied upon as investment, legal, accounting, tax, or any other professional advice, nor should it be associated with any offer or sale of securities. Any transactions mentioned on the Site are provided as representative transactions and are not reflect the overall performance.
Past Performance:
Past performance is no guarantee of future results. Investments involve risk, including the risk of loss of principal. 9Basil does not guarantee any specific investment results.
No Warranty; Limitation on Liability:
The site and related services are provided on an “as is”, “as available” and “with all faults” basis and without warranties of any kind, either expressed or implied. To the fullest extent permissible pursuant to applicable law, 9Basil or its respective officers, directors, employees, agents, third-party content providers, designers, contractors, distributors, merchants, sponsors, licensors or the like (collectively, “Associates”) makes no representations or warranties and specifically disclaims any and all warranties of any kind, express or implied, including, but not limited to, any warranty of non-infringement of third-party rights and any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, availability, security, accuracy, freedom from viruses or malware, completeness, timeliness, functionality, reliability, sequencing or speed of delivery.

9Basil or its Associates does not warrant, either expressly or impliedly, the accuracy or completeness of the information contained on this Site and does not warrant that the functions contained in this Site will be uninterrupted or error-free, that defects will be rectified, or that the Site will be free from viruses or other harmful components. 9Basil expressly disclaims all liability for errors and omissions in the materials on this Site and for the use or interpretation by others of information contained on the Site.

In no event shall 9Basil or its associates or be liable to any party for any claims, liabilities, losses, costs or damages under any theory, including but not limited to any direct, indirect, punitive, special, exemplary, incidental, or consequential damages arising out of in connection with any access, use (or inability to use) or distribution of the Site, or any content therein. This is true even if 9Basil has been advised of the possibility of such damages or losses.
Third Party Content and Linked Sites:
References on this Site to any names, marks, products or services of third parties who may or may not be affiliated with 9Basil, or hypertext links to third party websites or information or content provided by third parties, are provided solely as a convenience to you and do not in any way constitute or imply 9Basil’s endorsement, sponsorship, referral or recommendation of the third party, its information, materials or services. 9Basil does not review or monitor any websites linked from or to the Site and is not responsible for the practices or policies of such third parties, nor the content of any such websites, or any materials or services contained on or accessible through such other websites, their terms of use or privacy policies. 9Basil has not independently verified the content of any such third party sites. If you decide to link to any such third party sites, you do so entirely at your own risk. You are advised to review the terms of use and privacy policies of any website that you visit. 9Basil disclaims responsibility for the privacy policies and customer information practices of third-party internet websites linked from the Site.
Privacy Policy
Please review our Privacy Policy , which is a part of these Terms of Use and hereby incorporated by reference, to learn about our information collection practices and the measures we take to preserve the privacy and security of your information. Additionally, by using the Site, you acknowledge and agree that Internet transmissions are never completely private or secure. You understand that any message or information you send to the Site may be read or intercepted by others, even if there is a special notice that a particular transmission (for example, credit card information) is encrypted.
Password and Security Notification
Certain areas of the Site are password-protected. You may not attempt to access any password-protected areas of the Site without authorization. If you have been issued a password for the Site, you agree that 9Basil has granted you limited access to specific files pertaining to investments relevant to you, and you agree not to attempt to access other computer files.
All information that 9Basil provides to Site users supplying a password is confidential and intended solely for the information of its intended recipient and/or such recipient’s financial, legal or tax advisors, provided that such advisors agree not to disclose any information that is confidential.
You are entirely responsible for maintaining the confidentiality of the information you hold for your account, including your user names, password, and for any and all activity that occurs under your account as a result of your failure to keep this information secure and confidential. You agree to notify 9Basil immediately of any unauthorized use of your account or password, or any other breach of security. If you share your password with a third party, you assume all responsibility for all such party’s activity related to the Site.
Termination of Use:
These Terms of Use are effective unless and until terminated by either you or 9Basil. You may terminate these Terms of Use at any time, provided that you discontinue any further use of the Site. We also may terminate these Terms of Use, in our sole discretion, at any time and may do so immediately without prior notice or warning of any kind, and accordingly restrict, deny or terminate your access to the Site. Upon any termination of these Terms of Use by either you or us, you must promptly destroy all materials downloaded or otherwise obtained from the Site, as well as all copies of such materials, whether made under these Terms of Use or otherwise.
As a condition of use of the Site, you agree to indemnify, defend and hold 9Basil and its Associates harmless from and against any and all claims (including, but not limited to, claims for defamation, trade disparagement, privacy and intellectual property infringement), losses, liability, costs and expenses (including, but not limited, to attorney’s fees), as incurred, arising from your use of the Site or related services, from your violation of these Terms of Use or from any decisions that the visitor makes based on such information. If you are dissatisfied with any material on this Site, your sole and exclusive remedy is to discontinue using the Site.
Representations and Warranties:
You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms of Use; (ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms of Use; and (iii) you will not delete any content.
Effect on Other Agreements:
Nothing contained in these Terms of Use is intended to modify or amend any other written agreement you may have with 9Basil (including without limitation any customer agreement, participation agreement or account agreement) (collectively, “Other Agreements”), if any, that may currently be in effect. In the event of any inconsistency between these Terms of Use and any Other Agreement, the Other Agreement will govern. Some pages within the Site contain supplemental terms and conditions and additional disclosure and disclaimers, which are in addition to these Terms of Use. In the event of a conflict, such supplemental terms and conditions and additional disclosures and disclaimers will govern for those sections or pages.
Headings used in these Terms of Use are for reference purposes only and in no way define or limit the scope of the section.

These Terms of Use will be deemed severable. In the event that any provision is determined to be unenforceable or invalid, such provision will nonetheless be enforced to the fullest extent permitted by applicable law, and such determination will not affect the validity and enforceability of any other remaining provisions.

The failure of 9Basil to act with respect to a breach of these Terms of Use by you or others does not constitute a waiver and will not limit 9Basil’s rights with respect to such breach or any subsequent breaches.
Dispute Resolution and Binding Arbitration:
These Terms of Use are governed by the laws of Singapore. For any action allowed to proceed in court, or to enforce these Terms of Use, the parties agree to exclusive personal jurisdiction and venue in Singapore. Any claim under these Terms of Use must be brought within one (1) year after the cause of action arises, or such claim or cause of action is barred.

By using the Site, you agree that 9Basil, at its sole discretion, may require you to submit any disputes arising from the use of the Site, related services or these Terms of Use concerning or, including disputes arising from or concerning their interpretation, violation, nullity, invalidity, non-performance or termination, as well as disputes about filling gaps in this contract or its adaptation to newly arisen circumstances, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, by one or more arbitrators appointed in accordance with the SIAC Rules. This arbitration agreement will survive the termination of your relationship with 9Basil.
Contact Information
For any questions regarding these Terms of Use, please contact 9Basil at [email protected].