BESPOKE CAPITAL PRIVACY POLICY

Effective Date: 27 February 2026

Bespoke Capital (“Bespoke Capital”, “we”, “us”, or “our”) is committed to protecting and respecting your personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws. This Privacy Policy explains how we collect, use, disclose, process and safeguard personal data.

1. Definition of Personal Data
“Personal Data” refers to data, whether true or not, about an individual who can be identified from that data alone, or from that data and other information to which Bespoke Capital has or is likely to have access.

2. Collection of Personal Data
We may collect personal data from clients, authorised representatives, relevant individuals connected to a client, third parties, and publicly available sources. This may include:

  • Identification details (e.g. name, NRIC/passport number, date of birth).

  • Contact information (e.g. address, email, phone number).

  • Employment, financial and background information.

  • Information relating to credit facilities, guarantees or securities.

  • Transaction records and account information.

  • Technical data collected through cookies or website usage analytics.

Where personal data is provided to us by a client on behalf of another individual, the client represents and warrants that consent has been obtained and that such individual has been informed of this Privacy Policy.

3. Purposes of Collection and Use
We may collect, use and process personal data for the following purposes:

  • Assessing and processing applications for credit facilities and financial products.

  • Administering, maintaining and reviewing client accounts and facilities.

  • Conducting credit checks, risk assessments and due diligence (including AML/KYC checks).

  • Complying with legal, regulatory and reporting obligations.

  • Preventing fraud, financial crime and managing risk.

  • Managing and maintaining our business operations.

  • Enforcing contractual rights and recovering outstanding amounts.

  • Facilitating business transfers, assignments or corporate restructuring.

  • Any other purpose reasonably related to the above.

4. Disclosure of Personal Data
Personal data may be disclosed on a need-to-know basis to the following parties, whether in Singapore or overseas:

  • Related corporations and affiliates of Bespoke Capital.

  • Directors, officers and employees of Bespoke Capital.

  • Professional advisers including auditors and legal counsel.

  • Credit bureaus, financial institutions and insurers.

  • Service providers providing IT, administrative or operational support.

  • Regulators, government agencies and law enforcement authorities.

  • Any party involved in business transfers or assignments.

Where personal data is transferred outside Singapore, we will ensure that appropriate safeguards are in place in accordance with the PDPA.

5. Withdrawal of Consent
Individuals may withdraw consent to the collection, use or disclosure of their personal data by providing reasonable written notice to us. However, withdrawal of consent may affect our ability to provide or continue providing services and may result in termination of facilities where applicable.

6. Retention of Personal Data
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected and to comply with legal, regulatory and internal requirements.

7. Protection of Personal Data
We implement reasonable administrative, physical and technical security measures to protect personal data against unauthorised access, collection, use, disclosure or similar risks.

8. Amendments to this Policy
We may amend this Privacy Policy from time to time. Any amendments will be published on our website or otherwise notified to clients and will take effect from the date specified.

10. Governing Law
This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore. Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the Courts of Singapore.

11. Contact Us
If you have any questions or requests relating to this Privacy Policy or your personal data, please contact us at info@bespoke-capital.co