This Privacy Policy explains how JYT Growth Capital Pte. Ltd. collects, uses, stores and protects personal information when you visit our website, contact our desk, apply for seed-stage capital or work with us after an investment. The policy is written by the developer and operator named JYT Growth, and it applies to every page and form on https://www.jytgrowth.mom. Our registered office is JYT Growth Capital Pte. Ltd., 3 Yunnan Drive 1, Singapore - 638272, Singapore (SG). We have tried to write this document in plain language so that a founder, a job applicant or a visitor can understand what happens to personal information without needing a legal dictionary.
1. Who We Are
JYT Growth Capital Pte. Ltd. is a private company incorporated in Singapore that provides seed-stage capital administration and related advisory services to early companies, primarily in computer systems design and integrated technical services. The developer and operator of this website is JYT Growth, acting on behalf of the company. For the purposes of Singapore personal data protection law and comparable rules in other jurisdictions, the company is the organisation responsible for the personal information described in this policy.
Our registered address is JYT Growth Capital Pte. Ltd., 3 Yunnan Drive 1, Singapore - 638272, Singapore (SG). You can reach the desk by email at sales@jytgrowth.mom or by telephone at +14722464473. The same desk handles both investment enquiries and privacy requests, which means a request about your personal data reaches a person who already understands the context of our work.
This policy covers the website at https://www.jytgrowth.mom, the contact form on that site, email and telephone correspondence with the desk, and the administration of investments after a cheque has been released. It does not cover the separate practices of companies we invest in, or of any external website you may reach through a link on our pages.
2. Scope of This Policy
This policy applies to personal information that we collect directly from you, that you provide through our forms and correspondence, or that we receive from a founder, a co-investor, a professional adviser or a public source in the course of our work. Personal information means information about an identified or identifiable individual, such as a name, an email address, a telephone number, a role at a company or an ownership record.
Where we handle information about a company rather than an individual, this policy still applies to the extent that the company information includes personal details of founders, directors, shareholders or employees. We treat business contact details with the same care as personal contact details, because in a small seed practice the two are usually the same thing.
If you are visiting from a jurisdiction with its own privacy rules, the rights described in this policy are offered to you in addition to any rights you hold under local law. Nothing in this policy limits a right that the law gives you and that cannot be waived by agreement.
3. Information We Collect
We collect a limited set of information, and we try to collect only what a seed-stage capital desk genuinely needs. The categories below describe what we may hold at different points in a relationship.
- Contact details. Your name, email address, telephone number, postal address and, where relevant, your preferred language and time zone.
- Company details. The name, registration number, jurisdiction, address and sector of a company you represent, together with your role and authority to speak for it.
- Investment materials. Decks, screening memos, financial summaries, cap table extracts, term sheets, tranche schedules and any other documents you choose to send to the desk.
- Correspondence. The content of emails, messages and notes of calls or meetings, kept so that both sides share a record of what was agreed.
- Identity and compliance records. Where the law requires it, identification documents, beneficial ownership details and source of funds information needed to complete know-your-client checks.
- Technical information. A limited amount of information generated when you load our pages, such as the type of device and browser, the pages viewed and the referring address, as described in the automated information section below.
We do not ask for sensitive categories of personal information, such as health data, religious beliefs or biometric identifiers, unless a specific legal obligation requires it. If such information reaches us by accident, we will delete it unless we are required to keep it.
4. Information From Founders and Applicants
Most of the personal information we hold comes from founders who approach the desk or who are introduced to us. When you send an intake note through the contact form, we receive the name, email address, subject and message that you type. The form does not transmit your message to a server operated by us; instead it prepares an email in your own mail client and sends it to sales@jytgrowth.mom. This approach keeps the message under your control until you press send.
If a conversation develops, we may ask for a screening memo, a data room link, a cap table extract and details of the founding team. We may also ask for the names and roles of directors, shareholders and key employees, because the structure of a company matters to a seed investor. We use that information to assess the opportunity, to prepare terms and to run the milestone tranche planning described on our services page.
For founders in the existing batch, we hold check-in notes, portfolio reports, tranche schedules and reconciliation records. These documents are needed to administer the investment and to report to our own partners and investors. They are kept in a restricted area that only the desk and the fund administrator can open.
If you apply for a role at the company rather than for capital, we collect the information in your application, any notes from interviews and, where you provide them, references. We keep unsuccessful applications for a limited period so that we can consider you for a later role, unless you ask us to delete them sooner.
5. Information From Investors and Partners
JYT Growth Capital Pte. Ltd. also receives personal information about the people who fund the practice, the co-investors who join a round, and the professional advisers who support a transaction. This includes names, contact details, entity records, subscription documents, banking details where they are necessary for a transfer, and correspondence about a deal.
We use this information to manage the relationship, to complete subscription and transfer formalities, to meet anti-money-laundering obligations and to send the reporting that an investor is entitled to receive. Where a co-investor shares information about a founder with us, we treat it as confidential and use it only for the purpose for which it was shared.
Professional advisers, such as lawyers, accountants and auditors, may share personal information with us in the course of a transaction. We keep such information to the minimum needed and retain it according to the schedule described later in this policy.
6. Automated Information and Cookies
Our website is a small set of static pages, and we have kept it deliberately light. We do not run advertising networks, behavioural profiling scripts or third party tracking pixels. We do not set cookies for marketing purposes. If a future version of the site uses a cookie for a functional purpose, such as remembering a form preference, we will describe it here before the change takes effect.
Our hosting provider may record basic technical logs, such as the internet protocol address, the time of a request, the page requested and the browser type. These logs are used to keep the site available and secure, to diagnose faults and to protect against abuse. They are not used to build a profile of individual visitors, and they are retained only for the short period that the hosting provider needs for operational purposes.
If you click a mail or telephone link on our pages, your own device and service provider handle the connection. We do not receive any information from that action until you choose to send a message or make a call.
7. Why We Are Allowed to Process Information
Under Singapore law and comparable frameworks, we need a lawful basis for handling personal information. Depending on the situation, we rely on one or more of the following grounds.
- Consent. Where you send us an enquiry, submit a form or agree to receive updates, we rely on the consent you give at that moment. You may withdraw consent at any time by writing to the desk.
- Contract. Where you are a founder, investor or adviser with an agreement with us, we process information because it is needed to perform that agreement or to take steps before it is signed.
- Legal obligation. We may be required to keep records, verify identity or report to a regulator. In those cases the law, rather than consent, is the basis for processing.
- Legitimate interests. We have a legitimate interest in running a sound investment practice, protecting the website, preventing fraud and communicating with the people we work with. We balance that interest against your rights and expectations.
Where we rely on legitimate interests, we keep the processing proportionate and we stop if your rights outweigh the interest. Where we rely on consent, we make it easy to say no and easy to change your mind.
8. How We Use Personal Information
We use personal information for the following purposes, all of which relate to the operation of a seed-stage capital practice.
- To read and respond to enquiries, including intake notes sent through the contact page.
- To assess an investment opportunity, draft a screening memo and prepare a term sheet.
- To plan and release milestone tranches and to record the evidence that unlocks each instalment.
- To hold founder check-in rounds, prepare portfolio report cycles and reconcile cap tables.
- To carry out follow-on readiness checks and, where appropriate, to introduce a company to new investors.
- To meet legal, tax, accounting and anti-money-laundering obligations.
- To keep the records that allow us to answer a question months or years after a decision was made.
- To protect the website, the desk and the people we work with against fraud, misuse and security incidents.
We do not use personal information to make automated decisions that produce legal or similarly significant effects. We do not sell personal information, and we do not trade it for marketing lists. Any analysis we perform on portfolio data is done in aggregate and does not single out an individual for adverse treatment.
10. Service Providers and Processors
Like most small practices, we rely on a handful of service providers. These may include a website hosting provider, an email provider, a document storage service, an accounting platform and a payment or banking partner. Each provider processes personal information on our instructions and only for the purpose for which it was engaged.
Before we engage a provider that will handle personal information, we check that it offers appropriate security, that it will notify us of a breach and that it will return or delete information when the engagement ends. We keep a short internal register of these providers, and we review it at least once a year. If a provider is located outside Singapore, we apply the transfer safeguards described in the next section.
We do not allow a service provider to use our information for its own marketing, and we do not grant it a broader licence than the service requires.
11. International Transfers
Our desk is in Singapore, and most of the information we hold stays there. Some service providers and professional advisers operate in other countries, and a founder or investor may be based abroad. Where personal information leaves Singapore, we take reasonable steps to ensure that it receives a comparable standard of protection.
Those steps may include contractual clauses that require the recipient to protect the information, a check that the destination has adequate privacy law, or the use of a provider that applies a recognised certification. Where we transfer information to a co-investor or adviser in another country, we do so on the understanding that the information is used only for the transaction in question.
If you would like to know which countries may be involved in a particular relationship, write to the desk and we will explain the position for your case.
12. How Long We Keep Information
We keep personal information only for as long as we need it for the purpose for which it was collected, or for as long as the law requires. The periods below are our normal practice, and we may keep information longer where a legal obligation, a dispute or a regulatory request requires it.
- Enquiries that do not proceed. Contact details and correspondence are kept for up to twenty four months, then deleted, unless you ask us to remove them sooner.
- Applications we do not take forward. Recruitment records are kept for up to twelve months, then deleted, unless you agree to a longer period.
- Founder and portfolio records. Screening memos, tranche schedules, check-in notes, reports, cap table reconciliations and readiness checks are kept for the life of the investment and for seven years after it ends.
- Investor and compliance records. Subscription documents, identity checks and transfer records are kept for at least seven years after the relationship ends, or longer where the law requires it.
- Technical logs. Hosting logs are kept for the short operational period set by the hosting provider, normally a few weeks.
When a retention period ends, we delete the information or, where deletion is not immediately possible because of a backup cycle, we isolate it and delete it at the next cycle. We do not keep personal information indefinitely simply because it is convenient to do so.
13. How We Protect Information
We take the security of personal information seriously, and we apply measures that are appropriate to the size and nature of our practice. Access to founder and investor records is limited to the desk and the fund administrator. Accounts are protected by strong passwords and multi-factor authentication where the provider supports it. Devices are kept updated, and documents are stored in a restricted area rather than on shared drives that anyone can open.
Staff and contractors receive a short briefing on confidentiality when they join, and they are reminded of the policy each year. Physical documents, where any exist, are kept in a locked cabinet at the plot office. Visitors are not left alone with records, and the office is not open to the public without an appointment.
No system is perfectly secure. If a security incident affects personal information, we will investigate promptly, take steps to contain it and notify the affected individuals and any relevant regulator where the law requires it. We will also tell you what we have done to reduce the risk of a repeat.
14. Your Privacy Rights
Subject to the law that applies to you, you have a set of rights over your personal information. We will honour those rights within the time limits set by law, and we will not charge a fee unless a request is manifestly unfounded or excessive.
- Access. You may ask what personal information we hold about you and receive a copy.
- Correction. You may ask us to correct information that is inaccurate or incomplete.
- Deletion. You may ask us to delete information that we no longer need, subject to legal retention duties.
- Restriction and objection. You may ask us to limit how we use your information, or object to a use based on legitimate interests.
- Portability. Where the law provides it, you may ask for a copy of information you gave us in a structured format.
- Withdrawal of consent. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of earlier processing.
- Complaint. You may complain to us, and you may also complain to the data protection regulator in your jurisdiction.
To exercise a right, write to sales@jytgrowth.mom with enough detail for us to identify you and the information concerned. We may ask for proof of identity to protect your records. We will respond within thirty days, or tell you if a longer period is needed and why.
15. Privacy for Children
Our website and our services are intended for adults who are running or funding a business. We do not knowingly collect personal information from anyone under the age of eighteen. If you believe that a child has sent us personal information, please write to the desk and we will delete it promptly.
Where a founder shares information about a young employee or an intern, we expect the founder to have the authority to do so and to have told the person concerned. We keep such information to the minimum needed for the investment record.
16. Marketing and Communications
We do not run a newsletter, and we do not send promotional email to people who have not asked for it. If we write to you after an enquiry, it is because we are following up on that enquiry or because you have asked to stay in touch. Every such message tells you how to stop hearing from us, and we action the request promptly.
We may send an existing founder or investor a short note about a change to the practice, a reporting deadline or a regulatory development that affects the relationship. Those notes are part of the service rather than marketing, and we keep them brief.
If you receive a message that appears to come from us but seems unusual, please contact the desk using the email address and telephone number on this page before you reply or click. We would rather answer a cautious question than have you act on a message we did not send.
17. Third Party Sites and Links
Our pages may link to external websites, such as a founder website or a professional adviser page. We do not control those sites, and this policy does not apply to them. When you leave our site, the privacy policy of the destination applies, and we encourage you to read it before sharing personal information.
Where a founder sends us a link to a data room or a shared folder operated by a third party, the third party privacy terms apply to that service. We use the link only to review the materials that the founder has chosen to share, and we do not ask the provider to give us wider access.
Our website may also be reached through a search engine or a social platform. Those services have their own policies, which we do not control.
18. Changes to This Policy
We review this policy at least once a year, and we update it sooner if our practice, our providers or the law change. When we make a material change, we will update the effective date at the top of this page and, where the change affects a founder or investor relationship, we will send a short notice to the people concerned.
A change does not apply retrospectively to information that we have already deleted, and it does not reduce a protection that we have promised in an agreement. If a change is significant, we may ask you to confirm that you have read the updated policy before we continue a particular process.
The current version of this policy is always the one published on this page. If you would like a copy by email, write to the desk and we will send a plain text version.
19. How to Contact Us
If you have a question about this policy, a request about your personal information or a concern about the way we have handled it, please contact the desk. One of the small team reads every message, and we will give you a clear answer.
Organisation: JYT Growth Capital Pte. Ltd.
Developer and operator: JYT Growth
Address: 3 Yunnan Drive 1, Singapore - 638272, Singapore (SG)
Email: sales@jytgrowth.mom
Phone: +14722464473
Business hours: Monday to Friday, 9:00 to 18:00 Singapore time
If you are not satisfied with our response, you may raise the matter with the Personal Data Protection Commission of Singapore or with the data protection authority in your own jurisdiction. We will cooperate with any such review and will provide the records needed to resolve the question.
Thank you for taking the time to read this policy. A seed-stage practice depends on trust, and we believe that trust begins with being clear about how we handle the information you share with us.