Privacy Policy

Arohi is committed to protecting the privacy and confidentiality of personal data entrusted to us. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data in accordance with the Singapore Personal Data Protection Act 2012 (PDPA), U.S. SEC Regulation S-P, and other applicable laws.

This policy applies to personal data we collect through our website, through our client and prospect interactions, and through our business operations.

1. Personal Data We Collect

We collect personal data in the following ways:

(a) Information Submitted Through Website Forms

If you contact us through the website’s contact form, we collect:

• Name
• Email address
• Message or inquiry details

(b) Client and Prospect Information (Off-Website)

In the course of providing investment management services, we may collect:

• Contact details (e.g., name, email, phone, address)
• Organisation and role
• Records of communications
• Data necessary to assess suitability or onboarding requirements
• KYC/AML information (collected by us or by our fund administrator on our behalf)
• Information relating to investor status (e.g., accredited or institutional investor qualification)

(c) CRM and Mailing List Data

We maintain CRM databases and mailing lists containing:

• Contact information
• Relationship history
• Notes on interactions
• User preferences (e.g., subscription to communication updates

2. Purpose of Collecting and Using Personal Data

We use personal data for the following purposes:

• Responding to inquiries submitted through the website
• Managing client relationships and providing investment management services
• Investor onboarding, including KYC/AML compliance
• Maintaining CRM records, mailing lists, and communication logs
• Performing administrative, operational, or support functions, including through our group entities
• Complying with legal, regulatory, and supervisory requirements
• Internal reporting, governance, audits, and risk management
• Recruitment or HR purposes, where applicable

We will not use personal data for purposes unrelated to these activities without first obtaining consent or ensuring compliance with applicable laws.

3. Disclosure of Personal Data

We may disclose personal data to the following parties for the purposes described above:

(a) Group Entities

Personal data may be shared with:

• Iroha Investment Management Private Limited (India)
• AI.XYZ Services Private Limited (India)
• Arohi LLC (United States)

These entities may perform operations support, administrative functions, shared services, or HR-related activities.

(b) Third-Party Service Providers

We may share data with third parties that support our operations, including:

• Fund administrator
• Cloud and IT service providers (including Microsoft 365)
• Professional advisers (legal, audit, compliance)
• Vendors supporting our internal processes

These parties are required to protect personal data and use it only for authorised purposes.

(c) Regulators and Authorities

We may disclose data where required by law or regulation, including to:

• The Monetary Authority of Singapore (MAS)
• The U.S. Securities and Exchange Commission (SEC)
• The Ontario Securities Commission (OSC)
• The Securities and Exchange Board of India (SEBI)
• Other regulatory or government bodies as required

4. Cross-Border Transfers

As part of our international operations, personal data may be transferred to:

• India (Iroha, AI.XYZ)
• United States (Arohi LLC)
• Other jurisdictions where our service providers are located

Where personal data is transferred overseas, we ensure that the receiving party is bound by acceptable data-protection standards consistent with PDPA requirements.

5. Protection of Personal Data

We implement reasonable administrative, technical, and organisational measures to safeguard personal data against:

• Loss
• Unauthorised access
• Misuse or alteration
• Disclosure or destruction

Access to personal data is limited to authorised personnel with a business need to know. We use secure cloud systems, access controls, and confidentiality safeguards consistent with regulatory expectations.

6. Data Retention

We retain personal data for as long as necessary to fulfil the purposes outlined in this policy or as required by applicable laws and regulations. Retention periods may vary depending on:

• Regulatory obligations
• Legal requirements
• The nature of our relationship with the individual

Information may be retained for extended periods for audit, regulatory, or record-keeping obligations.

7. Your Rights

Individuals may request to:

• Access the personal data we hold about them
• Correct inaccurate or incomplete data
• Withdraw consent to the collection or use of personal data (subject to legal and contractual restrictions)

Requests may be submitted using the contact information below. Processing of requests may be subject to verification and allowable exemptions under applicable law.

8. Third-Party Websites

Our website may contain links to external websites, including the login portal of our fund administrator. These websites operate independently of us and have their own privacy policies. We are not responsible for their content, security, or data-handling practices.

9. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in legal or regulatory requirements or changes in our business practices. Updates will be posted on this website with the effective date.

10. Contact – Data Protection Officer

For questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

Data Protection Officer
Arohi Asset Management Pte. Ltd.
Email: info@arohi.com