Privacy Policy

1. Who We Are

HYZQ Capital Pte. Ltd. is a company registered in Singapore with its office at 238A Thomson Road, #25-07 Novena Square, 307684, Singapore (SG). The company operates a custody desk that receives, indexes, reviews and releases documentation for institutional clients, and it also provides computer systems design and related professional services. For the purposes of applicable data protection law, the company is the controller of the personal information described in this policy, which means the company decides why and how that information is used.

The developer name associated with this website is Hyzq Capital. The company name and the developer name refer to the same undertaking, but they are used differently in public materials. The company name appears on contracts, receipts and formal correspondence, while the developer name appears in website and technical contexts. Whichever name you see, the data protection obligations described here are the same.

The company can be reached by email at helpdesk@hyzqcapital.buzz or by telephone at +19593452598. These channels reach the custody desk directly during business hours and are monitored for privacy enquiries on working days.

2. Scope of This Policy

This policy covers personal information processed through the company website, through enquiries submitted to the custody desk, through custody and documentation services provided to clients, and through ordinary business correspondence. It does not cover information held by third parties whose own privacy policies apply, including banks, settlement agents, auditors and counterparties that you deal with outside the scope of the company engagement.

Where the company acts on the instruction of a client and processes personal information that belongs to that client, the client is the controller and the company acts as a processor. In those situations the client privacy notice governs the underlying purpose of processing, and this policy describes how the company carries out those instructions with appropriate security and confidentiality. If you are an individual whose information was provided to the company by a client, you should raise any question about the purpose of processing with that client first.

3. Information We Collect

The company collects only the information it needs to run the custody desk and the systems design practice. The categories of information are set out below, and each category is tied to a clear operational reason rather than collected for its own sake.

Identity and contact information includes names, job titles, employer names, business email addresses, business telephone numbers and business postal addresses. This information is needed to identify who is instructing the company, who is authorised to receive documents and who should be contacted when a custody record requires attention.

Engagement information includes the nature of the instruction, the documents delivered into custody, the counterparties involved and the settlement arrangements. For custody work this can include copies of board minutes, resolutions, safekeeping receipts, wire instructions and pledge documentation. Some of these documents may contain personal information about directors, officers or signatories, and the company treats them with the same care as any other record.

Website and technical information includes the ordinary data that a web server records when a page is requested, such as the requested address, the time of the request and basic browser information. The company does not use this information to build advertising profiles, and it does not sell this information to anyone.

Correspondence information includes the content of emails, contact form submissions and telephone notes. This information is used to answer your enquiry, to keep a record of what was agreed and to improve the quality of the desk.

4. How We Collect Information

The company collects information directly from you when you send an enquiry, call the desk, submit a contact form or deliver documents into custody. It also collects information from authorised representatives of a client when they provide instructions on the client behalf, and from counterparties and advisers who take part in a settlement sitting.

Information may also be collected automatically when you use the website, through the server logs described above. The company does not operate covert tracking, does not fingerprint devices and does not attempt to identify individual visitors from technical records unless there is a security or legal reason to do so.

In some cases the company receives information about you from a public register, from a professional adviser or from a counterparty. When that happens, the company records the source so that the origin of the information can be explained if you ask about it.

5. Why We Use Information

The company uses personal information to receive, index, review and release custody records, to verify the authority behind wire instructions and pledge releases, to schedule settlement sittings, to issue safekeeping receipts and to answer enquiries. Each of these uses is directly connected to the service that a client has asked the desk to perform.

The company also uses information to keep accurate business records, to manage its relationship with clients and counterparties, to comply with legal and regulatory obligations that apply in Singapore and elsewhere, to detect and prevent fraud or misuse of the desk, and to defend or pursue legal claims where that becomes necessary.

Where the company wishes to send you information about its services, it will do so only where it is permitted to, and it will honour any request to stop. The company does not use custody records for marketing and does not combine personal information from different clients into a shared marketing list.

7. Custody Records and Documentation

Documentation held in custody can contain a great deal of sensitive commercial information, and some of it can contain personal information about directors, officers, signatories and representatives. The company limits access to custody records to staff who need the record in order to perform a defined task, and it records who accessed a record and why.

Safekeeping receipts are issued against the documents received, and the receipt identifies the record set without disclosing its contents to anyone who is not entitled to know. Board minutes are indexed by entity and resolution so that access can be controlled at the level of the specific matter rather than the whole file. Wire instructions are handled in a separate and more tightly controlled run because of the risk that a misdirected instruction could cause financial loss.

Pledge release reviews are conducted by a reviewer who did not prepare the record, and the review produces a signed note that explains the conditions that were checked. Custody audit windows allow an independent reviewer to inspect the records without interrupting live work, and the findings are recorded and tracked to closure. Settlement sittings are witnessed, and the record of each sitting identifies what was released, retained or returned.

The company keeps custody records for as long as required by the engagement and by applicable law, and it follows a documented disposal routine when the retention period ends. Disposal is authorised, recorded and, where appropriate, witnessed, so that a client can be sure a record has not simply been misplaced.

8. Sharing and Disclosure

The company does not sell personal information. It does not share personal information with advertisers and does not trade information for commercial advantage. Information is shared only where there is a clear operational or legal reason and where the sharing is limited to what the situation requires.

Information may be shared with counterparties and their advisers where that is necessary to complete a settlement sitting or a pledge release. It may be shared with auditors and independent reviewers during a custody audit window. It may be shared with professional advisers such as legal counsel and accountants where their advice is needed. It may be shared with banks and settlement agents where a wire instruction run requires it.

Information may also be disclosed where the company is required to do so by law, by a court order, by a regulator or by another authority with lawful jurisdiction. Where disclosure is required and the company is permitted to notify you, it will do so, unless notification would itself be unlawful or would prejudice an investigation.

If the company is involved in a reorganisation, merger or transfer of its business, personal information may be transferred as part of that transaction. In that case the company will ensure that the recipient is bound by confidentiality and data protection obligations consistent with this policy.

9. Service Providers and Processors

The company uses a limited number of service providers to support its operations, including providers of email, document storage, information technology support and accounting services. These providers are chosen for reliability and for their ability to meet the security expectations of a custody desk.

Each provider acts on the written instructions of the company and is bound by confidentiality obligations. Providers are not permitted to use the information for their own purposes, to pass it on to others without authority or to process it in a way that is inconsistent with this policy. The company reviews its providers periodically and takes contractual steps to ensure that access is removed when a provider stops working for the company.

Where a provider processes information outside Singapore, the company takes reasonable steps to ensure that the information remains protected to a standard consistent with this policy, as described in the section on international transfers.

10. International Transfers

The company is based in Singapore, and its custody records are principally held there. Some service providers and some counterparties may be located in other countries, which means that personal information may be transferred across borders in the course of an engagement.

Where the company transfers personal information internationally, it takes steps to ensure that the transfer is lawful and that the information remains protected. These steps can include contractual clauses with the recipient, checks on the legal environment of the destination and limiting the information transferred to what is genuinely necessary.

If you would like more information about the safeguards used for a particular transfer, you may contact the desk using the details at the end of this policy, and the company will explain the safeguards that apply to your situation.

11. Retention of Information

The company keeps personal information for no longer than is necessary for the purpose for which it was collected, unless a longer period is required by law or by the terms of an engagement. Retention periods are set by reference to the type of record rather than by a single blanket rule, because custody records, correspondence and website logs have very different useful lives.

Custody records are generally retained for the duration of the engagement and for a defined period afterwards, so that a client can return for clarification or so that the company can respond to a lawful request. Correspondence is retained while the relationship is active and for a short period after it ends. Website logs are retained only for as long as they are useful for security and maintenance.

When a retention period ends, the company disposes of the information in a controlled way. Disposal is recorded, and where the information was held in custody for a client, the disposal is confirmed to that client where the engagement requires it.

12. Security of Information

The company protects personal information with a combination of physical, technical and organisational measures. Physical custody work takes place in a controlled office at Novena Square with restricted access. Digital records are held in systems that require authenticated access, and access rights are granted only to staff who need them for their role.

Staff who handle custody records receive guidance on confidentiality, handling and incident reporting. Access to wire instructions is separated from access to general correspondence so that the highest risk material is subject to the tightest controls. Records of access are retained so that the company can investigate an unusual event and explain what happened.

No system can be perfectly secure, and the company does not pretend otherwise. What the company does promise is that it takes security seriously, that it reviews its measures regularly and that it has a plan for responding to an incident. If a security incident affects your personal information, the company will investigate promptly and notify affected parties and relevant authorities as required by applicable law.

13. Cookies and Website Technologies

The website is deliberately simple. It does not use advertising cookies and does not embed third party tracking scripts for marketing purposes. If the website uses a cookie at all, it is used for a functional purpose such as remembering a preference during a single visit, and it does not follow you across other websites.

Your browser may allow you to block or delete cookies. Blocking functional cookies may affect how parts of the website behave, but it will not prevent you from reading the pages or contacting the desk. The company does not require you to accept tracking cookies in order to use the site.

If the company introduces a new website technology that changes this position, it will update this policy and, where required, ask for your consent before the technology is used.

14. Your Rights

Depending on where you live, you may have rights in relation to your personal information. These rights can include the right to be informed about how your information is used, the right to request access to the information the company holds about you, the right to ask for corrections where the information is inaccurate, and the right to ask for deletion where the information is no longer needed.

You may also have the right to restrict or object to certain processing, the right to withdraw consent where consent is the basis for processing, and the right to receive a copy of certain information in a portable format. Where the company processes information on behalf of a client, the client is the controller, and the company will pass your request to the client so that it can be handled in the right way.

To exercise any of these rights, contact the desk using the details at the end of this policy. The company will respond within the time required by applicable law and may ask for information to confirm your identity before acting on the request. There is normally no charge for exercising your rights, although the company may charge a reasonable fee where a request is clearly unfounded or excessive.

If you are not satisfied with how the company has handled your request, you may complain to the relevant data protection authority in your jurisdiction. The company would appreciate the chance to resolve the matter with you first.

15. Privacy for Children

The custody desk serves institutional clients and is not directed at children. The company does not knowingly collect personal information from children in the course of its ordinary work. If you believe that a child has provided personal information to the company, please contact the desk so that the information can be reviewed and, where appropriate, removed.

Where a document held in custody happens to contain information about a minor, that information is protected in the same way as any other custody record, and access is limited to the staff who need it for the engagement.

16. Marketing Communications

The company sends marketing communications only where it is permitted to do so. You can ask the company to stop sending marketing communications at any time by using the contact details below, and the company will act on the request promptly. Stopping marketing communications does not affect operational messages that are needed to run the custody desk, such as a notice that a safekeeping receipt has been issued or that a settlement sitting has been scheduled.

The company does not sell or rent contact details to other organisations for their marketing, and it does not use custody records to identify people for marketing purposes.

18. Changes to This Policy

The company may update this policy from time to time to reflect changes in its practices, its services or the law. When a change is made, the date at the top of the policy is updated. Where a change is significant, the company will take reasonable steps to bring it to the attention of clients and visitors, for example by placing a notice on the website.

The current version of the policy is always the version published on the website, and you should check it periodically if you wish to stay informed. If you continue to use the website or the custody desk after a change takes effect, the updated policy will apply to the information the company holds.

19. Contacting the Company

If you have a question about this policy, a request about your personal information or a concern about how information has been handled, please contact the company using the details below. The person responsible for data protection at HYZQ Capital Pte. Ltd. will review your message and respond within a reasonable time.

The desk is available during business hours on working days. Messages received outside those hours are reviewed on the next working day. The company welcomes feedback on this policy and uses it to improve the way information is handled across the custody desk.