Privacy Policy

01Who We Are & What This Policy Covers

• Company (data controller and app developer): Ascent Global Fintech Solutions Pte Ltd
• Registered office: 8 Temasek Boulevard, #34-03 Suntec Tower Three, Singapore 038988
• Brand: One Constellation
• Website: one-constellation.com
• Mobile app: OC Onboarding, published by Ascent Global Fintech Solutions Pte Ltd on Google Play (Android package com.anonymous.scbb) and the Apple App Store
• Privacy contact: info@one-constellation.com

This policy applies to the website and to the OC Onboarding app. Section 02 explains the information the app handles.

02The OC Onboarding Mobile App

OC Onboarding lets investors and their authorised representatives complete onboarding with a fund, fund administrator or other financial institution that uses One Constellation. We process the information you provide in the app to carry out that onboarding for the institution that invited you, and to meet legal and regulatory obligations such as anti-money-laundering and know-your-customer requirements.

Information processed through the app may include:

• Account details you create to sign in, such as your email address, user ID and login credentials
• Identity and contact details you enter, such as your name, date of birth, nationality, address, email address and phone number
• Personal or corporate account details, including fund or ISIN codes and, when you onboard a company, information about its directors and beneficial owners
• Tax information, such as tax identification numbers and tax residency, collected for FATCA and CRS reporting
• Identity documents and other supporting documents you upload
• Facial images and short liveness captures (photos or video) taken for face verification, liveness detection and e-KYC checks
• Electronic signatures on agreements and forms, completed through DocuSign
• The status and history of your onboarding application
• Device and usage information, such as device identifiers, push-notification tokens, app interactions, crash logs and diagnostics, used to deliver notifications, keep the app secure and stable, and improve it

Device permissions. The app uses your device camera only when you choose to photograph a document or complete face verification and liveness checks. If you allow notifications, we use them to tell you about the progress of your application. You can refuse or withdraw camera access in your device settings, but those steps cannot then be completed in the app.

Who we share app information with. The institution you are onboarding with; DocuSign, for electronic signatures; identity-verification, liveness and screening service providers used for KYC and AML checks; analytics, crash-reporting and push-notification service providers that help us run the app; our cloud hosting provider; tax authorities where FATCA or CRS reporting requires it; and regulators or other authorities where the law requires it. We do not sell personal data.

How long we keep it. Onboarding records are kept for as long as the institution you onboarded with needs them and for the record-keeping periods that anti-money-laundering laws require, often at least five years after the relationship ends. They are then securely deleted or anonymised.

Deleting your account and data. To ask us to delete your OC Onboarding account and the data linked to it, email admin@one-constellation.com from the email address used in your application, with the subject "OC Onboarding data deletion". We will confirm what has been deleted. Records that the law requires us or the institution to keep are retained only for the required period.

03Information We Collect

We collect personal data that you provide to us voluntarily when you:

• Register for our services
• Subscribe to our newsletter
• Contact us for inquiries or support
• Participate in surveys, events, or promotions
• Apply for a job or partnership opportunity

The types of personal data we collect may include:

• Name, contact number, and email address
• Business or company details (if applicable)
• IP address and browser details for security and analytics
• Payment and billing information (if applicable)

Additionally, we may collect anonymised data, such as website usage statistics, to improve our services.

04How We Use Your Information

We use your personal data to:

• Provide and manage our services
• Respond to inquiries and provide customer support
• Improve our website and user experience
• Send you relevant updates, newsletters, or promotional materials
• Conduct research, analysis, and troubleshooting
• Comply with legal obligations and regulatory requirements

If you have subscribed to our communications, you may opt out at any time by contacting us at info@one-constellation.com.

05How We Collect Your Information

We collect personal data through various means, including:

• Direct interactions (e.g., filling out forms, sending emails, or making inquiries)
• Automated technologies (e.g., website analytics, cookies, and tracking tools)
• Third-party partners who help us operate our business

06How We Protect Your Information

We implement strict security measures to protect your personal data against unauthorised access, alteration, or disclosure. These measures include:

• Secure servers and encryption technologies
• Access controls and authentication procedures
• Regular system monitoring and security audits

While we take every reasonable precaution to safeguard your information, no method of data transmission over the internet is 100% secure. We encourage you to take additional precautions when sharing your personal data online.

07Sharing & Disclosure of Information

We do not sell or trade your personal data. However, we may share your information with trusted third parties under the following circumstances:

• Service Providers: To help us deliver our services, such as payment processors, IT support, and marketing platforms.
• Legal & Regulatory Authorities: If required to comply with applicable laws, regulations, or legal processes.
• Business Transfers: If our company undergoes a merger, acquisition, or sale of assets, your data may be transferred as part of the transition.

08Cookies & Tracking Technologies

Our website uses cookies to enhance your browsing experience. These cookies help us analyse web traffic, personalise content, and improve functionality. You can manage your cookie preferences through your browser settings.

For more information on how we use cookies, please contact us at info@one-constellation.com.

09Your Rights & Choices

Depending on your location, you may have the following rights regarding your personal data:

• Access & Correction: Request a copy of the personal data we hold about you and correct any inaccuracies.
• Data Deletion: Request that we delete your personal data, subject to legal and contractual obligations.
• Objection & Restriction: Object to or restrict certain types of data processing.
• Withdraw Consent: If you have previously given consent for marketing communications, you can withdraw it anytime by contacting us.

To exercise these rights, please email us at info@one-constellation.com.

10Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy or as required by law. Once data is no longer needed, it is securely deleted or anonymised.

11International Data Transfers

Your data may be transferred and stored in locations outside your country of residence, including jurisdictions that may not provide the same level of data protection. We ensure appropriate safeguards are in place to protect your personal data when transferred internationally.

12Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Any updates will be posted on this page, and we encourage you to review it regularly.