Terms and Conditions

The following terms and conditions (“Terms”) govern the use of our website
www.farrocapital.com (“Website”) operated by Farro Capital Pte. Ltd. (“we”, “us”, or “our”). By
accessing or using our website, you agree to abide by these Terms. If you do not agree with any
part of these Terms, you are advised not to use our website.

Who we are and how to contact us?

Farro Capital Pte Ltd. is a Capital Markets Service License (CMS) Holder from Monetary
Authority of Singapore (MAS). We are a regulated organization, incorporated and
headquartered in Singapore. We are committed to protecting and respecting your privacy. This
Privacy Policy explains how we collect, use, disclose, and safeguard your information when you
visit our website and use our services.

Our full details are:

Legal Name: Farro Capital Pte Ltd.
Address: 3 Phillip St, #08-01 Royal Group Building, Singapore 048693
Email: [email protected]
Phone: +65 65399975

If you have any questions about this Privacy Policy or our privacy practices, please contact our
Data Protection Officer at [email protected] or at the address above.

By using our site, you accept these terms

By accessing or using the website of Farro Capital (“our site”), you acknowledge that you have
read, understood, and agree to be bound by these terms of use (“Terms”). These Terms govern
your use of our site and form a binding contractual agreement between you and Farro Capital.
If you do not agree to these Terms, you are advised not to use our site.

We recommend that you either print a copy of these Terms or save them to your computer for
future reference. We may amend these Terms from time to time. Every time you wish to use
our site, please check these Terms to ensure you understand the terms that apply at that time

There are other terms that may apply to you:

Privacy Notice: Our Privacy Notice outlines the manner in which we process any personal data
collected from you, or that you provide to us. By using our site, you consent to such processing,
and you warrant that all data provided by you is accurate.

Cookie Policy: Our Cookie Policy provides information about the cookies on our site, including
how we use them and how you can manage or delete them.

Please take the time to read and understand these additional terms, as they form part of our
contractual agreement with you when using our site.

We may make changes to these terms.

We reserve the right to amend these terms of use at our discretion and at any time. Whenever
we make changes to these terms, we will post the updated terms on our site and, where
appropriate, notify you by email or through a notice on our site.

It’s advisable that you review these terms periodically to stay informed of any changes. By
continuing to use our site following the posting of changes, you accept and agree to the revised
terms.

We may make changes to our site.

We may update and change our site from time to time to reflect changes to our products,
services, our users’ needs, or our business priorities. Whenever we make changes to these
terms, we will revise the updated date at the bottom of this page.

It’s important that you review these terms of use periodically to stay informed of any changes.
By continuing to use our site after changes to these terms are made, you acknowledge and
agree to be bound by the revised terms.

We may also provide notifications of changes to these terms or other matters by displaying
notices or links to notices generally on the site, or by sending you an email.
We may suspend or withdraw our site.

Our site is made available free of charge. We do not guarantee that our site, or any content on
it, will always be available or be uninterrupted. We may suspend, withdraw, discontinue, or
change all or any part of our site without notice. We will not be liable to you if for any reason
our site is unavailable at any time or for any period.

You are also responsible for ensuring that all persons who access our site through your internet
connection are aware of these terms of use and other applicable terms and conditions, and that
they comply with them.

Privacy Notice

This Privacy Notice is applicable to customers and prospective customers of FARRO CAPITAL
Pte. Ltd. (“FARRO CAPITAL”). It elucidates how we will collect, process, and manage the personal data we hold about you, along with delineating your rights under the Personal Data
Protection Act (PDPA) of Singapore concerning the data held.

FARRO CAPITAL will act as the Data Controller as defined under the Personal Data Protection
Act of Singapore legislation and regulations.

Lawful Basis and Purpose for Processing Your Data
We will process your personal data only when there is a legal basis for doing so, as detailed
below:

Consent: Where you have provided explicit consent for us to process your data for a specific
purpose.

Contractual Necessity: Where processing is essential for the performance of a contract to which
you are a party, or to take steps at your request before entering such a contract.

Legal or Regulatory Obligation: Where processing is necessary for compliance with a legal or
regulatory obligation to which FARRO CAPITAL is subject.

Legitimate Interests: Where processing is necessary for the purposes of the legitimate interests
pursued by us or by a third party, except where such interests are overridden by your interests
or fundamental rights and freedoms which require protection of personal data.

Any decision to process data based on legitimate interests will be made on a case-by-case basis
and in alignment with the guidance set forth in the Personal Data Protection Act of Singapore.
The information that we collect.

We collect personal data from you at various stages of your relationship with us, including at
the outset, during your application process, and throughout the course of our ongoing
relationship. This data may be collected directly from you, from third parties you authorize to
act on your behalf, or from other third parties such as your financial adviser or providers
transferring money or assets to us at your instruction.

The categories of personal data we may collect include, but are not limited to:
Contact Information: Including name, address, telephone numbers, and email addresses.
Communication Records: Including voice recordings from telephone calls, letters, and emails
exchanged with us.

Socio-demographic Information: Such as age, employment status, profession, earnings, gender,
and other sources of wealth.

Family Circumstances: Including marital status and beneficiary information.
Transactional Information: Such as account transactions and access to our online client portals.

Identification and Legal Documentation: Including national identifiers, copies of documents
relating to your identity, nationality, and citizenship such as birth certificates, passports, proof
of address documents, and marriage certificates.

Special Category Data (if necessary): Such as information relating to your health, including
medical conditions and disabilities.

We handle your personal data with the utmost care and in compliance with the Personal Data
Protection Act of Singapore. The processing of your personal data is necessary for the provision
of services to you, compliance with legal obligations, and for other legitimate interests pursued
by FARRO CAPITAL.

Sharing your personal data
We may share your personal data within FARRO CAPITAL and with third parties who provide
services related to the administration of your account. The circumstances under which we may
disclose your personal data are as follows:

Service Providers: We may share your personal data with third-party service providers involved
in the administration of your account.

Legitimate Business Purposes: We may disclose your personal data for legitimate business
reasons, or as necessitated by law and regulations, to your Financial Adviser, third parties
appointed by your Financial Adviser, third-party investment managers, and product providers
with whom you or your Financial Adviser instructs us to invest.

Credit Reference Checks: We may disclose your personal data to credit reference agencies to
verify your details during the application process and for the ongoing administration of your
account. This helps prevent fraud, money laundering, and verifies your identity. Please note
that these checks may be recorded on your credit history.

Legal, Regulatory, or Governmental Bodies: We may disclose your personal data to legal,
regulatory, or governmental bodies if required by applicable law and regulations.
Sensitive Personal Data: With your consent or instruction, or that of your Financial Adviser, we
may need to disclose sensitive personal data, such as health information, to third parties to
effectuate instructions regarding your account.

International Transfers: We may transfer your personal data to another country, ensuring that
your personal data is afforded the same level of protection as required under the Personal Data
Protection Act of Singapore legislation and regulations prior to the transfer.
We are committed to maintaining the confidentiality of your personal data and will not use it
for any other purpose, nor share it with third parties without your explicit consent, except as
outlined in this section or required by law.

Retention of your personal data
We are committed to retaining your personal data only for the duration necessary to fulfill the
purposes for which it was collected, including for the purposes of satisfying any legal,
regulatory, tax, accounting, or reporting requirements.

The retention period for personal data may vary based on the nature of the services provided,
the terms and conditions applicable to your account, and our legal or regulatory obligations.
Typically, we will retain your personal data for a period of seven years from the end of our
relationship, in accordance with regulatory requirements.

Under certain circumstances, we may retain personal data for longer periods if necessary for
legal proceedings, investigations, or other significant obligations.

We may also anonymize your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information indefinitely without
further notice to you.

At the end of the retention period, we will securely delete or destroy your personal data in
accordance with applicable laws and regulations.

Your Data Protection Rights
Under the Data Protection laws, you possess several rights concerning your personal data.
These rights include:

Access: You have the right to request a copy of the personal data we hold about you. This is
known as making a Subject Access Request (SAR). In most instances, this will be provided free
of charge, however, for repeated requests or further copies, an administrative fee may be
applied.

Data Portability: You have the right to have your personal data transferred securely to another
service provider in electronic form.

Rectification: You have the right to have any inaccurate personal data we hold about you
corrected.

Erasure: You have the right to have any out-of-date personal data deleted, provided there’s no
business necessity or legal requirement for us to retain it.

Processing Restrictions: You have the right to object or restrict processing in certain
circumstances, particularly when we do not have legitimate grounds for processing your
personal data.

Marketing Opt-out: You have the right to object to your personal data being used to send you
marketing material. We will only send you marketing material where you’ve provided consent,
and you may withdraw this consent at any time.

We are committed to honoring these rights in accordance with the applicable legal and
regulatory requirements. If you wish to exercise any of these rights, please contact us using the
information provided in the ‘Who We Are and How to Contact Us’ section of this Privacy Policy.

Important Information

If you have any inquiries or concerns regarding our data handling practices, please feel free to
contact us at [email protected]. We are committed to addressing any issues you may have
concerning your personal data.

Should you not be satisfied with our response or handling of your data, you have the right to
lodge a complaint with the Information Commissioner’s Office (ICO). Further information
regarding your rights under the Personal Data Protection Act of Singapore can be accessed on
the ICO’s website at https://www.pdpc.gov.sg/overview-of-pdpa/the-legislation/personal-data-
protection-act.

By signing our product application form, you provide consent for us to use your personal
information for the purposes and under the terms stipulated above. Please note that you have
the right to withdraw your consent at any time.

Cookies
Our website utilizes cookies to distinguish you from other users, which aids in providing a
personalized browsing experience and allows us to improve the functionality and user-
friendliness of our site.

Here are the categories of cookies we may use:

Strictly Necessary Cookies: These are essential for the operation of our site, enabling you to
navigate and use the features of our site.

Performance Cookies: These cookies collect information about how visitors use our website, for
instance, which pages visitors go to most often, and if they receive error messages from web
pages. The information collected by these cookies is aggregated and therefore anonymous.

Functionality Cookies: These are used to recognize you when you return to our site, enabling us
to personalize our content for you and remember your preferences.

Targeting/Advertising Cookies: These cookies record your visits to our site, the pages you have
visited, and the links you have followed. We will use this information to make our site and the
advertising displayed on it more relevant to your interests.

You have the ability to accept or decline cookies by modifying the settings in your browser.
However, you may not be able to use all the interactive features of our site if cookies are
disabled.

For more information on managing and deleting cookies, visit the help pages of your browser or
see www.allaboutcookies.org. For more detailed information about the cookies we use, please
contact us at [email protected].

Changes to this Privacy Notice
We may update our Privacy Notice from time to time to reflect changes in our data processing
practices, changes in legal or regulatory requirements, or for other purposes. Any changes we
make to our Privacy Notice in the future will be posted on this page.

We encourage you to review this Privacy Notice periodically to stay informed about how we are
protecting and using your personal data. If we make any significant changes to this Privacy
Notice that materially alter our privacy practices, we may also notify you by other means, such
as sending an email or posting a notice on our website.

Your continued use of our website and services after any changes to this Privacy Notice
constitutes your acceptance of the updated policy.

Contact

Should you have any questions, comments, or requests pertaining to this Privacy Notice, we
warmly invite you to reach out to us at the following contact details:

Email: [email protected]
Postal Address: 3 Phillip St, #08-01 Royal Group Building, Singapore 048693
Phone: +65 65399975

We are committed to addressing your inquiries and providing you with the necessary
information concerning our privacy practices.