Privacy Policy
- Data Controller. Vitor Investment Pte. Ltd., [address], is the data controller for personal data collected via the Site.
- Data Collected. Contact details submitted via enquiry forms; professional/firm information volunteered; technical and device data (IP address, browser, analytics cookies) no financial or KYC data is collected at Site level.
- Purpose (PDPA purpose limitation). To respond to enquiries, assess preliminary eligibility to proceed to the Investor-Controlled tier, comply with AML/CFT law where triggered, and improve the Site.
- Legal Basis. Deemed consent for Site analytics; express consent collected before any onboarding step begins.
- Disclosure to Third Parties. Limited to named categories: fund administrator, auditor, custodian, professional advisers and regulators never sold, never disclosed for marketing by a third party.
- Cross-Border Transfer. Where data is transferred outside Singapore (e.g., to an offshore administrator), Vitor ensures the recipient provides comparable protection under PDPA s.26, via contractual clauses or an equivalent mechanism.
- Retention. Per the Records Retention Policy (C7) general enquiry data held no longer than [24] months absent onboarding; AML-linked data held 5 years post relationship.
- Your Rights. Access, correction and withdrawal of consent noting withdrawal may prevent onboarding from proceeding.
- Security. Encryption in transit and at rest, access controls see the Cybersecurity Policy (C8).
- Breach Notification. Assessed on discovery; PDPC notified within 3 calendar days of determining a breach is notifiable; affected individuals notified as soon as practicable where required.
- Data Protection Officer. [Name / role], contact: [dpo@vitorinvestments.com] published per PDPA s.11 (3).
- Children. The Site is not directed at, and does not knowingly collect data from, minors.
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Public Risk Disclosure
- Capital at risk for partners and investors may lose some or all of the amount invested.
- Illiquidity private fund interests are not freely tradable and may be locked up for the Fund’s term.
- No guaranteed return, and past performance (including of the Investment Manager’s principals in prior roles) is not indicative of future results.
- Currency / FX risk for investors subscribing in a non-fund-base currency.
- Leverage risk, where the Fund or its portfolio companies use gearing.
- Concentration and key-person / manager risk.
- Valuation risk private assets have no active market and rely on periodic, judgement-based valuation.
- Regulatory and legal risk across the multiple jurisdictions in which the Fund, its investors and its portfolio companies operate.
- Conflicts of interest risk see the Conflict of Interest Summary (A8).
- Cybersecurity and operational risk.
Regulatory Status Statement
Vitor Investment Pte. Ltd. is incorporated in the Republic of Singapore. Vitor will apply in future to become a Singapore based Variable Capital Company, regulated by the Monetary Authority of Singapore. VCC status does not itself imply MAS product authorization.
This statement is not, and must not be read as, an MAS endorsement of Vitor, Vitor Fund, or any product Vitor offers. Registration or licensing (where held) relates to Vitor’s conduct as a fund manager; it is not a determination of investment merit and gives no assurance against loss.
Vitor Investment Pte. Ltd. is incorporated in the Republic of Singapore. Vitor will apply in future to become a Singapore based Variable Capital Company (VCC), regulated by the Monetary Authority of Singapore. VCC status does not itself imply MAS product authorisation; each sub-fund’s offer is made under a specific SFA exemption see the Regulatory Disclosure Legend carried on every investor document (B1/B9/B10).
Cross-Border Notice / Jurisdictional Restrictions
This Site is not directed at any person in a jurisdiction where its content, or an investment in Vitor Fund, would be unlawful. In particular, without limitation:
- United States not an offer of securities in the US. Vitor Fund is not, and does not intend to become, registered under the US Investment Company Act of 1940; interests are not registered under the US Securities Act of 1933. No offer will be made to, and no interest sold to, any US Person absent a valid exemption (e.g., Rule 506(c) with verified accredited-investor status, paired with a 3(c) (7) or 3(c)(1) fund exemption).
- European Economic Area / UK this Site does not constitute AIFMD marketing or UK financial promotion. Any offer will be made solely via a permitted National Private Placement notification to professional investors.
- India no content is an offer under the Companies Act 2013 or SEBI (FPI) Regulations. Indian residents accessing the Site do so on their own initiative; any resulting investment is subject to RBI’s Overseas Investment (ODI) framework and FEMA.
- UAE / Saudi Arabia not directed at retail investors. Any offer to persons in DIFC/ADGM will be made only under the DFSA/FSRA Qualified Investor exemption; any offer to persons in Saudi Arabia will comply with CMA private placement rules.
- All other jurisdictions access is at the visitor’s own initiative and their own responsibility to confirm local legality. Vitor reserves the right to decline any enquiry from a jurisdiction where lawful access cannot be confirmed.
Conflict of Interest Summary
Vitor and its affiliates conduct multiple lines of business, including fund management (Vitor Fund. In the ordinary course, actual, potential or perceived conflicts of interest may arise for example, where Vitor personnel hold an interest in, advice, or transact with a portfolio company, co-investor or counterparty connected to another Vitor group entity.
Vitor maintains a Conflict of Interest Policy, an information-barrier framework, and a related-party transaction approval process to identify, manage and, where necessary, mitigate such conflicts in the interests of Fund investors. A summary of currently identified conflicts is available on request; the full Conflict of Interest Policy is provided to investors as part of onboarding.
Intellectual Property Notice
All content on this Site text, graphics, logos, the Vitor name and marks, data compilations and software is the property of Vitor Investment Pte. Ltd. or its licensors, protected under Singapore and international intellectual property law. No licence is granted to reproduce, modify, distribute or create derivative works from any content, beyond the limited personal, non-commercial use permitted under the Terms of Use (A2), without Vitor’s prior written consent.
Third-party names, logos and trademarks referenced on the Site (e.g., portfolio companies, partners) remain the property of their respective owners and are used solely to identify the relevant entity under fair-use principles; such use does not imply endorsement, sponsorship or affiliation.