This Privacy Policy explains how Sung Partnership ApS (“we”, “us”, or “our”) collects, uses, discloses, and protects your personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Danish data protection laws. We are committed to protecting your privacy and ensuring that your personal data is handled transparently and securely.
This policy applies to personal data processed through our website at https://sungpartnership.com/ (the “Website”) and in connection with our activities as a private alternative investment fund managed by Sung Capital ApS. The Website is primarily for informational purposes, and we do not actively solicit investments from non-qualified investors.
If you have any questions about this Privacy Policy, please contact us using the details in Section 11.
This Privacy Policy was last updated on October 05, 2025. We may update it from time to time. Any changes will be posted on this page, and where appropriate, we will notify you directly.
1. Data Controller
The data controller responsible for your personal data is:
Sung Partnership ApS CVR: 45926931 Smallegade 24, 2. th 2000 Frederiksberg Denmark
Email: oliver@sungcap.com (Attn: Oliver Sung)
We are registered in Denmark and subject to supervision by relevant Danish authorities for our activities as an alternative investment fund.
2. Personal Data We Collect
We collect and process limited personal data, as our Website is informational and does not include forms, sign-ups, or interactive features. Personal data may be collected in the following ways:
- Inquiries and Communications: If you contact Oliver Sung directly (e.g., via email or telephone) with inquiries about the partnership, we may collect your name, email address, telephone number, and any other information you provide in your message.
- Investor Relations: For qualified investors or partners, we may collect additional data such as identification details, financial information, address, and investment-related data to manage investments, comply with legal obligations (e.g., anti-money laundering checks), and fulfill contractual commitments.
- Website Usage Data: Automatically collected data when you visit the Website, including IP address, browser type, device information, referring pages, and access times. This may be collected via server logs or cookies (if implemented). Currently, the Website does not use cookies for tracking, but if introduced in the future, we will update this policy and provide notice where required.
- Other Sources: We may receive personal data from third parties, such as regulatory authorities or service providers, in connection with our fund management activities.
We do not collect special categories of personal data (e.g., data revealing racial or ethnic origin, health, or political opinions) unless required by law or with your explicit consent.
3. Purposes and Legal Bases for Processing
We process your personal data for the following purposes, based on the specified legal bases under GDPR:
- Responding to Inquiries: To handle and respond to your questions or requests. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) in communicating with potential partners or interested parties.
- Managing Investments and Partnerships: To onboard qualified investors, manage fund positions, and fulfill contractual obligations. Legal basis: Performance of a contract (Art. 6(1)(b) GDPR) or compliance with legal obligations (Art. 6(1)(c) GDPR), such as financial regulations under the Danish Financial Business Act or EU AIFMD.
- Compliance and Risk Management: For anti-money laundering (AML), know-your-customer (KYC), tax reporting, and other regulatory requirements. Legal basis: Compliance with legal obligations (Art. 6(1)(c) GDPR).
- Website Operation and Improvement: To analyze usage patterns and improve the Website’s functionality. Legal basis: Legitimate interests (Art. 6(1)(f) GDPR) in maintaining and enhancing our online presence.
- Marketing (Limited): We do not engage in direct marketing. However, if you are a qualified investor, we may send updates related to the fund. Legal basis: Consent (Art. 6(1)(a) GDPR) or legitimate interests (Art. 6(1)(f) GDPR) where applicable.
We will only process your data for the purposes for which it was collected or compatible purposes. If we need to process it for another purpose, we will inform you and provide the legal basis.
4. Sharing Your Personal Data
We may share your personal data with:
- Service Providers: Third parties providing services such as legal advisors, auditors, IT hosting, or payment processors (e.g., banks for investment transactions). These providers act as processors and are bound by data processing agreements compliant with GDPR.
- Affiliates: Sung Capital ApS, as our manager, for fund administration.
- Regulatory Authorities: As required by law, such as the Danish Financial Supervisory Authority (Finanstilsynet) or tax authorities.
- Professional Advisors: In connection with fund operations, such as accountants or lawyers.
We do not sell your personal data. Sharing is limited to what is necessary and subject to confidentiality obligations.
5. International Transfers
Your personal data is primarily processed within the European Economic Area (EEA). If we transfer data outside the EEA (e.g., to global equity markets or service providers), we ensure appropriate safeguards, such as EU Standard Contractual Clauses, adequacy decisions, or other mechanisms approved under GDPR to protect your data.
6. Data Retention
We retain personal data only as long as necessary for the purposes outlined above or to comply with legal requirements:
- Inquiry data: Up to 1 year after resolution, unless leading to a partnership.
- Investor data: For the duration of the investment relationship plus 5-10 years post-termination, as required by financial regulations (e.g., AML retention periods).
- Website usage data: Up to 6 months for logs, unless needed for security purposes.
Data is securely deleted or anonymized when no longer required.
7. Your Rights Under GDPR
As a data subject, you have the following rights:
- Access: Request a copy of your personal data.
- Rectification: Correct inaccurate or incomplete data.
- Erasure (“Right to be Forgotten”): Request deletion where there is no compelling reason for continued processing.
- Restriction: Restrict processing in certain circumstances.
- Portability: Receive your data in a structured, machine-readable format and transfer it to another controller.
- Objection: Object to processing based on legitimate interests, including profiling (we do not engage in automated decision-making).
- Withdraw Consent: Where processing relies on consent.
- Complaint: Lodge a complaint with the Danish Data Protection Agency (Datatilsynet) at https://www.datatilsynet.dk/ or your local supervisory authority.
To exercise these rights, contact us using the details in Section 11. We will respond within one month, extendable by two months for complex requests. There is no fee unless requests are manifestly unfounded or excessive.
8. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, or alteration, including encryption, access controls, and secure servers. In the event of a data breach, we will notify you and relevant authorities as required by GDPR.
9. Cookies and Tracking
Currently, the Website does not use cookies or tracking technologies beyond basic server logs. If we introduce cookies in the future, we will provide a cookie notice and obtain consent where required under ePrivacy rules.
10. Contact Us
For any questions, requests, or concerns about this Privacy Policy or your personal data, please contact:
Oliver Sung
Sung Partnership ApS
Email: oliver@sungcap.com
Address: Smallegade 24, 2. th, 2000 Frederiksberg, Denmark
11. Additional Information
This policy does not apply to third-party websites linked from our Website (if any). We recommend reviewing their privacy policies.
Sung Capital ApS and Oliver Sung do not provide financial advice or solicit investments from non-qualified investors. This Website is for informational purposes only. Please refer to our disclaimer for more details.