Privacy Policy

Maintaining confidentiality of Personal Data is of utmost importance to us. This data protection notice (the “Notice”) outlines how we collect, use, store and disclose your personal data in accordance with the Personal Data Protection Act (“PDPA”). The PDPA strives to protect personal data of individuals. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data.

This Notice supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Notice to ensure that this Notice is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Notice shall apply. For the avoidance of doubt, this Notice forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

What is Personal Data?

Personal data refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access. Personal Data may include personal particulars such as passport or other identification number, telephone number(s), mailing address, email address, an online identifier, one or more factors specific to the identity of the individual. We Keep Your Personal Data Confidential and Secure

Collection of Personal Data

Generally, we may collect Personal Data through the following ways:

  1. a) Documents containing Personal Data submitted to us (e.g. application for services, proof of identity, proof of address, source of wealth, reference letter, resumes etc.); and
  2. b) When Personal Data is provided to us for any other reason.

When you submit your personal data to us for any other reason. You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date.

You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. Where you provide us personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

Protection of Personal Data

As part of efforts to safeguard Personal Data in our possession, we have reasonable security arrangements and technology risk management policies in place to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal and/or similar risks. We also subject our employees to confidentiality obligations under their terms of employment.

Purposes for Collection, Use and Disclosure of Your Personal Data

Generally, we collect, use and/or disclose Personal Data for various purposes including but not limited to the following (depending on the relationship we have with you):

a)Evaluating your standing, resources and capabilities to enter or maintain a relationship with you as a client, employee, business partner or other;

b)Analysing your financial situation and determining financial strategies and products suitable for you as our client;

c)Assessing and processing any applications, requests and instructions for financial products and services offered by us and/or other financial institutions or product providers for you as our client;

d)Managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;

e)Reporting to you as our client on your financial situation and our performance of our services to you, processing any corporate actions which affect your investments (which may arise in connection to any merger, acquisition or asset sale);

f)Updating you in relation to our management of your investments, our services, products, newsletters and related investment and market information, reports or commentaries;

g)Responding to your queries and requests and handling complaints, if any;

h)In the course of the provision of our services, such as to our related group companies where they are directly or indirectly involved, financial institutions, external professional service providers,

i)Internal reporting and analysis related to our business operations;

j)Maintaining records of our interactions with you, through telephone recordings, documentation (hard copy and electronic);

k)Any person to whom we are obliged or otherwise required to make disclosure to under the requirements of any law binding on or applying to us, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations with which we are expected to comply;

l)Any other party to whom we have been authorised to disclose the Personal Data to;

m)Any other purposes related to the above purposes.

Subject to the provisions of the applicable laws, Personal Data may be provided, for the purposes listed above, to third party organisations (some of which may be situated outside of the jurisdiction where the Personal Data is collected).

Retention of Personal Data

We retain Personal Data only for as long as the purposes for which such data is collected or used continues, or where necessary for our legal or business purposes. Generally, we do not retain Personal Data for a period longer than necessary after the original purpose(s) for which the Personal Data was collected ceases to be applicable, unless otherwise required by law or other mandatory government authorities or for purposes of legal proceedings.

Privacy on our Websites

This Policy also applies to Personal Data we collect via our websites. “Cookies” may be used on some pages of our websites. “Cookies” are used by many websites to improve the user’s navigational experience. Most web browsers are initially set up to accept “cookies” but you may choose to “not accept” cookies by changing the settings on your web browser.  In most cases, you may refuse a “cookie” and still fully navigate our website although some functionality in the site may be impaired. You may also delete the “cookie” from your system on termination of your visit to our site.

Contact us

If you:

  • Have any concerns or queries about how your personal data is handled
  • Wish to update your personal data
  • Wish to withdraw your consent to the collection, use and/or disclosure of Personal Data by submitting a notice in writing to us. (Note: If consent relating to any or all use of Personal Data is withdrawn, we may not be in a position to continue provision of our services.)

You may send your notice or request by  email to our data protection officer at brendon.jones@adansoniafundmanager.com.sg.