- Information Collected:
The Company only collects information wherever it is essential and only where it is relevant to our operations so as to be able to provide You with the best experience and service. The Company shall not collect, use or disclose Your personal information unless You give consent to us for the collection, use or disclosure of Your personal information. The Company promises to only collect and use personal information as mentioned below:
- Your personal information which identifies You, including Your name, birth date, IP address, login information, browser details and settings and details regarding Your operating system;
- contact information such as e-mail addresses and telephone numbers;
- information on how You subscribe to the Company’s financial products and services;
- information if You visit our office e.g. visual images collected via closed circuit television (CCTV);
- information classified as “sensitive” personal information e.g. relating to Your health;
- Your Payment related information including Your bank account number and Your credit or debit card details; and
- Children are not able to buy products and services from the Company. However, on instruction from a parent or guardian, a child can also be named as a beneficiary on some funds and trusts. In these cases, we collect limited personal information to identify the child (such as his / her name, age, gender).
The items so collected shall constitute “Personal Data“, which is defined under the Personal Data Protection Act of Singapore (the “PDPA“) to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. Personal Data collected by the Company shall be subject to complete protection by the Company in accordance with applicable law.
- Collection of Personal Data
Generally, the Company will collect Personal Data when You:
- register on the Site;
- submit Personal Data to us voluntarily;
- make payments to us, through our Site or otherwise;
- use the Company’s services or subscribe to the Company’s products;
- establish contact with us through the Site, by telephone, post, e-mail or through any other means;
- an application form for a product or service;
- meet with one of our business development or relationship personnel;
- register for one of our events;
- participate in competitions e.g. to win tickets to a sporting event which we sponsor;
- use one of our online services such as the Site (which includes the Company’s website, social media and mobile device applications);
- provide information in the business directories and other commercially or publicly available sources;
- if you have a financial adviser, the information we collect and use will most likely have been provided by them on your behalf; or
- participate in research surveys to help us understand You better and improve our products and services.
When You browse our Site, You generally do so anonymously. You will not be required to provide any personal details while browsing the Site.
The Company collects Personal Data in two ways. The first is when You provide us with information while using the Site, including filling out forms or contacting the Company using the given contact details. The second is when You browse the Site, where technical non-identifiable data is collected. You should ensure that all Personal Data that You submit to us is complete, accurate, true and correct. Failure on Your part to submit this information accurately may result in our inability to provide You with the best possible experience while using our Site and any of our products.
III. Information Protection
Browsing the Site will not require You to provide any personal details, so no sensitive Personal Data is automatically collected. You will remain anonymous and You will remain unidentified until You choose to register an account or make an enquiry by leaving Your details on the Site. The Company will protect Your Personal Data in strict accordance with applicable laws, including in accordance with the provisions of the PDPA. Nevertheless, You acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to the Company is done so at Your own risk. The Company does not warrant or guarantee that the information You provide will not be accessed, copied, used, or disposed of in breach of its security measures, and You agree not to hold us liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, the Company will, as far as reasonably possible, promptly notify all affected persons, including You. Unless required by law or a Court order or direction, or unless as relevant for the purpose stated:
- The Company will not sell, share or trade Your Personal Data collected online with third parties, except unless strictly necessary to complete a payment or under a direction by a court of law or judicial authority; and
- Personal Data collected online will be for internal Company use only, and will be viewed by Company employees on a strict need to know basis only.
By accepting these conditions, and by continuing to use the Site, You agree and accept that all information provided by You will be true and will be kept up to date during Your continuing use of the Site.
- Your / User Undertaking
You agree to provide up to date, accurate and correct personal information details, as requested by the Company. You agree that the Company shall not be liable for the misuse of any such details unless the misuse is as a result of the Company’s actions or proven gross negligence.
- Age of Consent
By using the Site, You represent that You are at least the age of 18 years old, or You have given us Your consent to allow any of Your minor dependents to use the Site as the case may be. The Company strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Site are not intended for use by minors, the Company respects the privacy of minors who may inadvertently use the internet or the mobile application.
- Company Undertaking
The Company will endeavour to ensure that the Personal Data collected is safely stored. The Company will protect all information by:
- Implementing and maintaining security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of Your information;
- Restricting third party access to Your Personal Data unless absolutely necessary; and
- Not retaining Your Personal Data for any time period longer than required to fulfil the purpose(s) listed below.
VII. Collection and Use of Data:
The Company may use Your Personal Data for the purposes below if we deem it necessary to do so for its legitimate interests. If You are not satisfied by this, You have the right to object in certain circumstances (see the section headed “Data Protection Rights” below).
- Purposes for Collecting Personal Information
Generally, the Company may use Your information for:
- Responding to queries and questions;
- Verifying Your identity;
- Providing You with: our online portal, login authentication, age verification, remembering Your settings, processing payments and hosting back end infrastructure;
- Managing the infrastructure and the business operations of the Company;
- Protecting and enforcing the Company’s legal rights and obligations;
- Compliance with applicable rules, laws and regulations, codes of practice or guidelines;
- To maintain Your account with us;
- To verify Your particulars and payments in relation to the services we provide to You;
- To provide You with the services You have signed up for and for improving and developing the Company’s products, services and Site;
- Traffic optimization, data analytics and research, including profiling and the use of services such as Google Analytics, managing landing pages and heat mapping our Site;
- Sending You communications about our services, products and features that You have agreed to receive;
- Communicating with You, if required, to inform You of any new services or developments relating to the Company or the services we provide; or
- Any purpose relating to the above.
- Additional Purposes:
In addition, where permitted by applicable law, the Company may also collect and use data collected from You for:
- Providing services, products and benefits to You;
- Sending You details of additional products, services that may be of use to You and that may enhance the quality of the product that the Company delivers to You; and
- In relation to particular products and services or in Your interactions with the Company, we may also specifically notify You of other purposes for which we collect, use and disclose Your Personal Data for these Additional Purposes as well.
The Company is committed in its endeavour to comply with applicable law governing the protection of Personal Data. However, in exceptional circumstances, if the Company is required by law or by a court order or direction to disclose personal information, we will do so.
- Disclosure of Personal Data:
The Company will take reasonable steps to protect Your Personal Data against unauthorised disclosure. Subject to the provisions of applicable law, the Personal Data will be used only for the purposes stated in the section headed “Collection and Use of Data” above or to the following third parties, wherever located:
- Company Affiliates. The Company will share information with its affiliates, who help us to provide and support our services and other business-related functions;
- Banks, Agents, Contractors or Service Providers. The Company will share information with its third-party service providers, who help us provide and support our services and other business-related functions (including but not limited to trustees, custodians, fund administrators and transfer agents);
- Professional advisors such as lawyers or auditors;
- Relevant government regulators, authorities, law enforcement agencies, credit reference agencies or a court of law. The Company will only disclose Personal Data when we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to conduct a credit check and ID verification or (iii) to protect Your vital interest or those of any other person; and
- Any other person with Your consent. The Company will only disclose Your Personal Data with Your express consent, to any service provider appointed or nominated by You and with whom we or the service providers have to interact in the course of providing our services and products to or in any of our transactions and dealings with You.
Persons who have subscribed for our updates on the Site (“Subscribers“) Note:
This section applies to all Subscribers:
As part of the signing-up process that is available to Subscribers on the Site, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.
If You have inadvertently submitted any such information to the Company prior to reading the privacy statements set out herein, and You do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then You may access, modify and delete such information by using options provided on the Site. In addition, You can, by sending an e-mail to firstname.lastname@example.org, inquire whether the Company is in possession of Your Personal Data, and You may also require us to delete and destroy all such information.
The Company will communicate with the Subscribers through e-mail. The Subscribers can change their e-mail address by re-subscribing and sending an e-mail to email@example.com for the deletion of previous e-mail.
All of the Company’s employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.
To the extent necessary to provide Subscribers with our services, the Company may provide their Personal Data to third party contractors who work on behalf of or with us to provide Subscribers with our services, to help us communicate with Subscribers or to maintain the Site. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Site, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these services in accordance with their own privacy policies. In such circumstances, You consent to us disclosing Your personal information to contractors, solely for the intended purposes only.
Subscribers may choose to unsubscribe from marketing communications that they receive from the Company or manage their preferences via the links provided at the end of every such e-mail and/or promotional communication.
If You have voluntarily provided Your Personal Data to us for any of the purposes stated above, You hereby consent to such collection and use of such information by us.
You are responsible for maintaining the accuracy of the information You submit to us, such as Your contact information provided as part of account registration. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Your account page or by contacting us at firstname.lastname@example.org. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If You provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or we have reasonable grounds to suspect that the information provided by You is untrue, inaccurate, out of date or incomplete, we may, at our sole discretion, discontinue the provision of our services to You. There may be circumstances where we will not correct, delete or update Your Personal Data, including (i) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (ii) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
If You wish to cancel Your account or request that we no longer use Your information to provide You services, contact us through email@example.com. We will retain Your information for as long as Your account with the Services is active and as needed to provide You the services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, Your data may be anonymised and aggregated, and then may be held by us as long as necessary for us to provide our services effectively, but our use of the anonymised data will be solely for analytic purposes. Please note that Your withdrawal of consent, or cancellation of account may result in us being unable to provide You with our services or to terminate any existing relationship we may have with You.
If You wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the services, You may do so via Your e-mail and/or account.
- Third-Party Sites
We do not collect information about the visitors of the Site from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration as an User (the collection, use, storage and disclosure of which each User must agree to in order for us to effectively render the services).
We maintain a strict “No-Spam” policy, which means that we do not intend to sell, rent or otherwise give Your e-mail address to a third party without Your consent.
XIII. Data Security
XIV. Transfer & Storage of Personal Data
- Data Protection Rights
You have the following data protection rights:
- Right to Access. The right to request (i) copies of the Personal Data the Company holds about You at any time, or (ii) that the Company modify, update or delete such information. If the Company provides You with access to the Personal Data the Company holds about You, the Company will not charge for this, unless Your request is manifestly unfounded or excessive.’ In situations where the Company is legally permitted to do so, we may refuse Your request. If the Company refuses Your request, we will tell You the reasons why;
- Right to Correct. The right to have Your Personal Data rectified if it is inaccurate or incomplete;
- Right to Erasure. The right to request that the Company delete or remove Your Personal Data from its systems;
- Right to Restrict. The right to request that the Company restrict the processing of Your Personal Data;
- Right to Data Portability. The right to request that the Company move, copy or transfer Your Personal Data;
- Right to Object. The right to object to the Company’s use of Your Personal Data, including where we use it for its legitimate interests;
- Withdrawal of Consent. Similarly, if Personal Data is collected or processed on the basis of consent, You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing the Company conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent;
- Right to be protected from automated decision making (including profiling). The right not to be subjected to automated decision making (including profiling) which significantly or legally affects you; and
- Right to Complain to a data protection authority. The right to complain to a data protection authority about the collection and use of Personal Data. For Singapore residents, please contact the Personal Data Protection Commission. For residents of jurisdictions other than Singapore, please contact Your local data protection authority.
Please contact the Company at firstname.lastname@example.org if You wish to exercise any of Your rights above. Furthermore, if You believe, that Your Personal Data may have been, or may imminently be in danger of being breached, or if You have reason to believe that such data may, for some reason, soon be breached please immediately contact the Company. The Company may need to request specific information from You to help us confirm Your identity and ensure Your Right to Access Your Personal Data (or to exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. The Company will try to respond to all legitimate requests within one (1) month. Occasionally it may take longer than that if the request is particularly complex or You have made a number of requests. In this case, the Company will notify You and keep You updated.
When You interact with us on our Site, You understand and accept that the Company uses “Cookies“, where a small data file is sent to Your browser to store and track certain anonymous information such as number of users, frequency of use and the number of page views (or page impressions) that occur on the Site (“Aggregate Information“) about You when You use the Site. Your Personal Data is not at risk in any way due to the implementation of the Cookies. You can accept or delete cookies. For security reasons, You may wish to deactivate the storing of cookies or adjust Your browser to inform You before the cookies are stored on Your computer. However, please note that if You do erase or block the cookies, You may not be able to utilise some features on the Site. In such situations, we shall not be held liable for any loss or damage resulting from Your inability to use those features. The Company may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). The Company collects your IP address in order to facilitate its administration and improvement of the Platforms. The information derived from your IP address can help the Company diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Platforms.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the They include, for example, cookies that enable You to log into secure areas of the Site, using our online payment services;
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the websites when they are using it. This helps us to improve the way the Sitework, for example, by ensuring that users are able to use custom features;
- Functionality cookies. These are used to recognise You when You return to our Site. This enables us to personalise its content for You, greet You by name and remember Your preferences (for example, Your choice of language or region); and
- Targeting cookies. These cookies record Your visit to the Site, the pages You have visited and the links You have followed. We will use this information to make the Site and the advertisements targeted more relevant to Your We may also share this information with third parties for this purpose.
XVIII. Contact Information
We will use reasonable efforts to respond promptly to any requests, questions or concerns, which You may have regarding our use of Your Personal Data.