Insights across Indian real estate.

1. Introduction

Real Estate Growth Capital By Ascend Pte. Ltd. ("Ascend Capital", "we", "us" or "our") operates the website www.ascend-capital.in (the "Site"). We are headquartered in Singapore and this Policy is issued in accordance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012), as amended (the "PDPA"), and the accompanying regulations and advisory guidelines issued by the Personal Data Protection Commission of Singapore ("PDPC").

This Privacy Policy explains what personal data we collect through the Site, how and why we use it, who we share it with, how long we keep it, and the choices and rights available to you. By accessing or using the Site, you acknowledge that you have read and understood this Policy.

2. Scope of this Policy

This Policy applies to personal data collected:

• through your visit to and use of the Site;
• when you submit an enquiry, contact form, newsletter sign-up, investor interest form or job application through the Site;
• when you correspond with us by email, phone or in person after being referred from the Site.

This Policy does not apply to third-party websites linked from the Site, which are governed by their own privacy policies. It also does not override any separate confidentiality, subscription or investor-relations agreement you may have signed with us, which will govern to the extent of any inconsistency.

3. Personal Data We Collect

We do not knowingly collect sensitive categories of personal data (e.g. financial account numbers, national identification numbers) through the Site. If you are onboarded as an investor or counterparty, additional personal data (e.g. for KYC/AML purposes) is collected separately under dedicated subscription, KYC or onboarding documentation, not under this Policy.

4. How We Use Your Personal Data

We use personal data for the following purposes:

• Responding to enquiries, investor interest submissions and general correspondence.
• Assessing job applications and conducting recruitment.
• Sending newsletters, fund updates, deal alerts or event invitations, where you have opted in.
• Operating, maintaining, securing and improving the Site, including diagnosing technical issues.
• Understanding aggregate Site usage patterns through analytics.
• Complying with applicable legal, regulatory and tax obligations in Singapore and other relevant jurisdictions.
• Establishing, exercising or defending legal claims.

5. Legal Basis and Consent

Under the PDPA, we collect, use and disclose personal data only where you have given consent, or where an exception under the PDPA applies (e.g. where the collection is reasonable for a purpose that is clearly beneficial to you and consent cannot be obtained in a timely way, or where it is required to comply with the law).

By submitting a form on the Site, you consent to our collection, use and disclosure of the personal data you provide for the purposes described in Section 4. You may withdraw consent at any time by contacting us using the details in Section 15; withdrawal does not affect the lawfulness of processing carried out before withdrawal, and may affect our ability to respond to your enquiry or provide certain services.

6. Disclosure of Personal Data

We do not sell personal data. We may disclose personal data to:

• Group entities and affiliates (e.g. Ascend Real Estate Ventures / Real Estate Growth Capital by Ascend) for the purposes in Section 4.
• Service providers who process data on our behalf, such as website hosting, email/CRM platforms, analytics providers and IT support vendors, under contractual obligations of confidentiality.
• Professional advisers (legal, tax, audit) where necessary.
• Regulators, government authorities or law enforcement, where required by law or to protect our legal rights.
• A prospective buyer or successor in the event of a corporate transaction (e.g. merger, financing, restructuring), subject to confidentiality safeguards.

All third parties who process personal data on our behalf are required to protect it consistently with this Policy and applicable law.

7. Overseas Transfer of Data

Given our India-Japan-Australia cross-border focus, personal data may be transferred to, stored in, or processed in jurisdictions outside Singapore, including India, Japan and Australia. Where we transfer personal data overseas, we take steps required under the PDPA to ensure the recipient is bound by legally enforceable obligations to provide a standard of protection comparable to the PDPA, such as through contractual clauses, group data protection policies, or reliance on a recognised certification of the recipient jurisdiction or organisation.

8. Data Security

We implement reasonable technical and organisational security measures to protect personal data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, including access controls, encryption of data in transit (TLS), and restricting access to personal data to personnel who need it to perform their duties. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, tax and accounting rules, or to resolve disputes and enforce our agreements. Job application data that is not progressed is generally retained for up to 12 months in case suitable future roles arise, unless you ask us to delete it sooner. When personal data is no longer needed, we securely delete, anonymise or destroy it.

10. Your Rights

Subject to applicable exceptions under the PDPA, you may:

• request access to the personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• withdraw your consent to our collection, use or disclosure of your personal data (see Section 5);
• unsubscribe from marketing communications at any time using the unsubscribe link in any email or by contacting us; and
• ask us to explain how your personal data has been or may have been used or disclosed in the past year.

We may charge a reasonable fee for access requests and may need to verify your identity before acting on a request. We will respond within the timeframe required under the PDPA.

11. Cookies and Tracking Technologies

The Site uses cookies and similar technologies to:

• ensure core Site functionality;
• remember your preferences; and
• understand how visitors use the Site (analytics), where such analytics cookies are used.

You can control cookies through your browser settings, including blocking or deleting them; doing so may affect certain Site features. Continued use of the Site with cookies enabled constitutes acceptance of our use of cookies as described here.

[Placeholder: list the specific cookies/third-party analytics tools in use (e.g. Google Analytics) and add a cookie consent banner if targeting EU/UK visitors or if legally required.]

12. Children's Privacy

The Site is intended for institutional investors, business counterparties and professional audiences, and is not directed at children. We do not knowingly collect personal data from individuals under 18 years of age. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

13. Data Protection Officer

As required under the PDPA, we have appointed a Data Protection Officer ("DPO") responsible for ensuring our compliance with the PDPA. You may contact our DPO with any question, concern or request relating to this Policy or our handling of your personal data using the details in Section 15.

[Placeholder: name/title of the appointed DPO, if to be disclosed publicly.]

14. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices, technology, legal requirements, or business operations. The updated Policy will be posted on the Site with a revised effective date. We encourage you to review this Policy periodically. Continued use of the Site after changes take effect constitutes acceptance of the revised Policy.

15. Contact Us

If you have any question, concern, or wish to exercise any right described in this Policy, please contact us:

If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore (PDPC) at www.pdpc.gov.sg.