The Personal Data Protection Act 2012 of Singapore (“PDPA”) came into force on 2 July 2014. The Company takes its obligations under the PDPA seriously and is committed to safeguard any Personal Data (as defined below) that has been, and will in future be, provided to it in its role as Investment Manager to its managed portfolios.

This Policy sets out the purposes for which the Company will collect, use, disclose and process Personal Data.

Collection of Personal Data

“Personal Data” is data that can be used to identify a natural person. Examples of Personal Data that the Company may collect are:

1. your personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
2. your specimen signatures;
3. your financial details;
4. your employment details (e.g. position/job title, work address, telephone number, email address);
5. your tax information;
6. information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets; 
7. your banking information;
8. your electronic communications with us; 
9. your marketing and communication preferences; 
10. your payment details and details of services we have provided to you; and 
11. your use of and interaction with the Company’s website (including your Internet Protocol address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access the Company’s website).  

Generally, the Company obtains Personal Data by virtue of its role as Investment Manager to its managed portfolios, where the relevant Fund Administrators share subscription and other account information with the Company to facilitate the management of the various portfolios, and to meet the Company’s obligations under applicable anti-money laundering and countering the financing of terrorism laws, regulations or directives. The Company may also collect Personal Data by other means, including:

(a) when you provide it to us in connection with a product or a service that the Company provides, such as a completed investment application form or otherwise contact the Company;

(b) when your authorised representatives provide us with your Personal Data;

(c) throughout the course of our relationship with you, including where you change your details, provide additional Personal Data, or where the services the Company is providing to you change;

(d) from third parties such as credit reference agencies; 

(e) when you interact with the Company’s website.

Use of Personal Data

The Company, within or outside Singapore, may use Personal Data reasonably in relation to its core business, which use includes for:

1. the provision of investment management services to its managed portfolios;
2. assessing and processing subscriptions, and other instructions or requests from investors in its managed portfolios;
3. communicating with investors in its managed portfolios, including the provision of monthly fact sheets and other investor notifications;
4. managing its business operations, and complying with internal policies and procedures;
5. responding to queries or feedback from investors in its managed portfolios, addressing or investigating any complaints, claims or disputes;
6. verification of identity for the purposes of meeting compliance obligations under applicable anti-money laundering and countering the financing of terrorism laws, regulations or directives;
7. complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities, or other agencies of competent authority;
8. managing payments, fees and charges, collecting and recovering money owed to the Company and enforcing any obligations that may be owed to the Company;
9. financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes; 
10. seeking any professional advice, including legal advice; 
11. administering, operating, providing, maintaining the Company’s website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on the Company’s website);
12. any other purposes for which you have provided the information; and
13. any other incidental business purposes related to or in connection with the above. 

The Company may also use Personal Data for the purposes set out in the various terms and conditions of the respective subscription forms of any fund in its managed portfolios.

Use of Personal Data for Marketing Purposes

The Company may use Personal Data to inform on the launch of new funds that may be of interest to the existing investors in its managed portfolios, for which such existing investors may be eligible. In doing so, the Company will comply with the PDPA and any other applicable data protection laws and regulations. Upon request by any person, the Company will cease to use that person’s Personal Data for marketing purposes.

Disclosure of Personal Data

The Company may from time to time, and in compliance with all applicable laws, disclose Personal Data to any of the managed portfolios, the relevant Fund Administrators, or to other third parties, whether located in Singapore or elsewhere, in order to carry out the purposes set out above. Where Personal Data is disclosed to such parties, the Company shall take reasonable steps ensure that any such data is kept confidential and secure.

The Company may on occasion transfer, store, process and/or disclose Personal Data to any such parties or agents or companies which may provide services to the Company, within or outside Singapore, and in doing so, will comply with the PDPA and other applicable data protection and privacy laws, including taking reasonable steps to prevent the unauthorised access, collection, use and disclosure of Personal Data.

Websites

The Company’s website may contain links to other websites which are not maintained by the Company. For the avoidance of doubt, this Policy shall only apply to the Company’s website, and shall not extend to the use of any third party website.

Cookie Notice

Please see our separate Cookie Policy.

Access, correction, cessation and erasure

Where permitted under applicable law, the Company will allow access and/or corrections to Personal Data in its possession or under its control. Upon request by any person, and subject always to any applicable laws that the Company may be required to comply with, the Company will take reasonable steps to erase and/or cease to use that person’s Personal Data.

Security

The Company takes commercially reasonable precautions to keep all Personal Data secure against unauthorised access, collection, use, disclosure, copying, modification, or disposal, or similar risks. In this regard, the Company is committed to employing reasonable security measures, regularly reviewing the Company’s security practices, and providing regular awareness training.

Retention of Personal Data

The Company will retain Personal Data as long as the purpose for which such data was collected remains, and until it is no longer necessary for any other legal or business purpose.

Contact Us

The Company has appointed a Data Protection Officer to address all queries and feedback on the Company’s data protection obligations. The Data Protection Officer may be contacted at (+65) 6323 0521 during office hours in Singapore, or at [email protected], using “Privacy Policy” in the email subject line.

Amendments and Updates

The Company may amend this Policy from time to time to ensure that consistency with any developments in the way the Company uses Personal Data, or to comply with any changes to the laws and regulations applicable to the Company. Updates to this Policy will be made available upon request. All communications and dealings with the Company shall be subject to the latest version of this Policy in force at the relevant time.