Privacy
Policy

Our Commitment to Your Privacy

This privacy notice explains how Alto Partners Pte. Ltd. trading as Analog Capital (UEN 201318750H) of 501 Orchard Road #18-01 Wheelock Place Singapore 238880 (“Analog Capital”, “we”, “us”, “our”) processes personal data, and how to contact us with questions or requests. This notice also describes the rights that you may have regarding our processing of your personal data under applicable local law.

Who are we?

Analog Capital provides investment management and advisory services to institutional investors, technology founders and corporate partners across Asia.

Analog Capital operates as:

    • a data controller where we collect personal data directly (for example from investors, employees, business partners, service providers, or visitors to our website); and

    • a data processor where we handle personal data on behalf of our funds, clients or other counterparties in the course of providing investment management and advisory services.

We are regulated by the Singapore Personal Data Protection Act 2012 (PDPA) and other applicable laws and regulations, including relevant requirements issued by the Monetary Authority of Singapore (MAS) for LFMCs (where applicable).

What personal information do we collect?

In the course of our business, we may collect personal information about you that is necessary for us to perform our functions and activities.

The types of personal information we may collect and hold may vary depending on the nature of our interaction with you and may include:

    • Identity and contact details (name, business contact details, employer, job title)

    • Investor and client onboarding data (KYC/AML, identity documents, source of funds/wealth, tax residency/identifiers, banking/payment details, investor classification)

    • Deal and portfolio engagement data (professional background, role, communications, meeting notes, corporate information relevant to due diligence)

    • Website and enquiry data (contact form details, messages, IP address, browser type, device identifiers, and basic analytics)

    • Recruitment data (if you apply for a role or internship)

We do not intentionally collect children’s personal data as part of routine business activities.

If you do not provide certain personal data, we may not be able to onboard you, respond to your request, or provide our services.

Sensitive data and KYC/AML

During KYC/AML and regulatory due diligence, we may incidentally collect or process sensitive information (for example identification document details, nationality, political exposure, criminal records, or other information required for verification and risk assessment). We handle such information with heightened care and restrict access to authorised personnel.

How we collect personal data

We collect personal data from:

    • you directly (forms, emails, meetings, subscriptions)

    • your organisation or advisers (where relevant to our relationship)

    • public and third-party sources used for due diligence (for example corporate registers and screening providers, where lawful)

    • our website and systems (logs and analytics)

How we use personal data (and our legal basis)

We use personal data for the purposes set out below.

Cookies and similar technologies

When you visit our website, small data files called cookies may be placed on your device. Cookies help the site operate properly, remember your preferences, and understand how visitors use our pages. We use only a limited number of cookies that are:

    • Necessary for our website to function, you can block these in your browser settings but parts of our site will not work

    • Used for aggregate analytics (ie Google Analytics) to understand our site and its performance. You are not personally identifiable from these cookies.

    • Required to remember your preferences, passwords or enhanced features. These are optional and set only with your consent.

For more information on how to control cookies, visit www.allaboutcookies.org.

Profiling and automated decision-making

Analog Capital does not make decisions that have legal or similarly significant effects on individuals based solely on automated processing. Any analytical or compliance tooling supports human decision-making and is subject to human review.

Who we share personal data with

We may share personal data with trusted third parties where necessary for the purposes set out in this notice, including:

    • Service providers that support our operations (for example IT, hosting, security, communications, and document management)

    • Professional advisers (for example legal, tax, audit, and compliance)

    • Fund, financing and transaction counterparties (for example fund administrators, banks, custodians, portfolio companies, co-investors, and their advisers)

    • Regulators and authorities (including regulators, law enforcement, and courts) where we are required or permitted to do so

We may also disclose personal data in connection with a corporate transaction (such as a merger, acquisition, restructuring or sale of assets), or to comply with law, legal process or lawful requests, and to protect rights, property and security, including for fraud prevention and investigations.

Storage, security and data quality

We store personal data as encrypted electronic data on Amazon Web Services (AWS) servers, with access controls designed to protect confidentiality and integrity.

We take reasonable steps to destroy or de-identify personal data that is no longer required, including under contractual or legal requirements.

Overseas transfers

Your personal data may be processed and stored outside the jurisdiction where you are based (including in the US and Ireland). Where required by applicable law, we use appropriate safeguards (such as contractual commitments) to protect your data. We take steps to ensure overseas recipients provide a comparable standard of protection to that required under applicable law.

Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws.

Your rights

The rights available to you depend on the laws applicable to your relationship with us. Under Singapore’s PDPA, your rights include access, correction, and withdrawal of consent.

To exercise rights, email DataPrivacy@analog-cap.com with the subject line “Data Subject Request”. We may need to verify your identity, and where we act as a processor we may need to consult the relevant controller.

Complaints

If you have concerns about how we handle personal data, contact us at DataPrivacy@analog-cap.com. If you are not satisfied with our response, you can contact your local data protection authority.

Contact

For any questions about this privacy notice, our data practices or the way you can exercise your rights, you can contact the Data Protection Officer (DPO) by email at DataPrivacy@analog-cap.com.

 

Last Updated: Feb 2026