At the sub-fund, we are committed to safeguarding your privacy. We will collect, use, store and disclose your personal data in accordance with the provisions of Personal Data Protection Act 2012 (“PDPA”).
YOU AGREE AND CONSENT to the sub-fund as well as our respective agents, authorised service providers and relevant third parties collecting, using, storing, disclosing and/or sharing your personal data.
YOU HEREBY REPRESENT AND WARRANT that all Personal Data you have submitted or will submit to us is complete, accurate, true and correct and you are responsible for keeping your personal data 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 under the Investment Management Agreement entered into between yourself and the sub-fund. To update your personal data, please contact the Managers appointed Data Protection Officer or your Relationship Manager.
Where you provide to us personal data concerning individuals other than yourself, YOU HEREBY REPRESENT AND WARRANT that you have obtained all 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.
Any material changes to our personal data protection practices shall be notified to you.
What is Personal Data?
Personal data refers to any data or information about you from which you can be identified either (a) directly from the information provided or (b) from information to which we have or are likely to have access. This includes but is not limited to:
- personal details like your name, passport or other identification numbers, contact numbers, address, email, date of birth, occupation and education.
- Financial information such as income levels, bank account information and assets, transaction-related information like your investment instructions,
- Photos and videos of you from our events or office surveillances
- When navigating the Platform/Website: information may include usage details, IP addresses, device information including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website, and information collected through cookies, web beacons, and other tracking technologies .
- Information We Get from Others. We may get information about you from other sources as required or permitted by applicable law, including public databases, credit bureaus & ID verification partners. We may combine the information collected from these sources with the information we get from this Site in order to comply with our legal obligations and limit the use of our Services in connection with fraudulent or other illicit activities.
We Keep Your Personal Data Confidential and Secure
Your privacy is of utmost importance to us. At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and procedural safeguards to protect your personal data against loss, misuse, damage and unauthorised access, modifications or disclosures. We regularly review and enhance our security policies and measures to consistently maintain a high level of security.
The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website/Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot totally guarantee the security of your personal information transmitted to our Website/Platform. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website/Platform except otherwise agreed in written with us.
Purposes for Collection, Use and Disclosure of Your Personal Data
We collect, use and/or disclose your personal data to provide enhanced asset management services and/or family office services to you, including (a) analysing your financial situation and determining financial strategies and products suitable for you; (b) assessing and processing your applications and instructions for financial products and services offered by us and/or other financial institutions or product providers; (c) analysing and managing financial and commercial risks including preventing, detecting and investigating crime; (d) updating you on your financial situation, our performance of our services to you, developments in our services and special happenings; (e) responding to your queries and instructions and handling complaints; (f) internal reporting and analysis related to our business operations; (g) maintaining records of your instructions and our interactions with you; (h) any other purposes related to the above purposes; and (i) The Management of your Platform Account which includes the verification of your account and the maintenance of its functionalities to provide proper access and use. If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will seek your consent.
How We May Collect Your Personal Data
We may collect your personal data ourselves or through third parties . We collect information when you deposit and withdraw digital assets or make transaction on the platform.
On top of this we collect personal information during the (a) creation of the platform account; (b) when you communicate with us by email or telephone, your emails will be retained and we may monitor and/or record your voice calls to us; (c) when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance; (d) when you access our website; (e) when you respond to our requests for additional personal data; and (f) when you submit your personal data to us for any other reason.
When you access our website you generally do so anonymously. Your activity may however be monitored by cookies (small data files sent to your browser to track information about your usage of our website) or other navigational data. Should you wish to disable such cookies, you may do so by changing your browser settings. However, you may not be able to access certain part(s) of our website.
To Whom We May Disclose Your Personal Data
Generally, we shall protect and keep confidential your personal data. We will disclose your personal data only with your consent and for purposes that you have been informed about. We need to share your personal information in order to operate our platform and business. We share users’ personal information for our everyday business purposes, such as to process and match your orders and respond to court orders and legal investigations. You cannot limit our sharing of this information.
In performing our services we may disclose your personal data for the purposes set out above to parties such as (a) our group companies; (b) banks, financial institutions, credit card companies and their respective service providers; (c) companies providing services relating to insurance and/or reinsurance, and associations of insurance companies; (d) our agents, contractors or operational third party service providers; (e) our professional advisers such as our auditors and lawyers; and (f) regulators and authorities.
When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available or where use/disclosure of your personal data is otherwise legally mandated and exempted. If your personal data is transferred overseas, we will inform you of the extent to which your personal data will be protected in the foreign jurisdiction(s) to which it will be transferred and
seek your consent.
Duration of Retention of Your Personal Data
We shall store your personal data for as long as necessary to fulfil the purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required. In general, your transactional personal data is kept for 5 years following transactions and your other personal data 5 years after the closing of the business relationship.
Cookies Policy
Our websites uses cookies for some purposes. “Cookies” are information our web server sends to a visitor’s browser. The term refers to the technology that’s used to send and store small amounts of information on a visitor’s computer when someone accesses a company’s website. The information stored in the cookie is restricted to information that does not identify the individual, such as the session ID. If you do not wish to accept the cookie, you can change the settings on your browser. In some cases, however, this may prevent you from receiving certain services.
We currently use, or may use the following types of cookies:
- Strictly necessary cookies: These cookies are required for our website to operate, and include cookies that enable you to visit certain areas of our website.
- Analytical/performance cookies: These cookies enable us to recognise and count how many people visit our website, and what pages they view during their visits. They help us improve how our website functions and provides information to visitors.
- Functionality cookies: These are cookies that recognise when you return to our website. They enable us to personalise our content and set preferences such as your choice of language or region.
- Targeting cookies: These cookies record your visit to our website, the pages you have visited, and the links you have followed. We use this information to ensure advertising displayed on our website is more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
If you do not wish to have cookies placed on your computer you should set your browsers to refuse cookies before using our website. However, the drawback is that certain features of our website may not function properly without the aid of cookies.
Queries, Access/ Correction Requests and Withdrawal of Consent
If you have any queries, or you wish to access and/or correct your personal data, or you wish to withdraw your consent to our collection, use or disclosure of your personal data, please contact to our Data Protection Officer at [email protected].
Our Data Protection Officer shall strive to respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in the position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may result in the termination of any agreement you may have with us. All our rights are reserved in such event.
If You Have a Complaint
If you should be dissatisfied with our handling of your personal data, please submit a written complaint to our Data Protection Officer. For full details on our complaint handling timeline and process, please contact our Data Protection Officer at the email address stated above.