A. Personal data we collect
As a provider of financial advisory services, we may collect the following personal data from you:
- General identification and contact information (name, address, telephone number, age, date of birth, gender, marital status, occupation, etc.);
- Identification numbers issued by government agencies (NRIC number, passport number, foreign identification number, birth certificate number, etc.);
- Financial information and account details (salary, assets, liabilities, credit card numbers, bank account numbers, etc.);
- Information about your investment knowledge and risk tolerance; and
- Information from cookies, or similar technologies, in order to enable or enhance the functionality of our websites, or to analyze visitor traffic for marketing or other purposes;
- Images, photographs, videos, CCTV footage, voice recordings and electronic communications;
- Other information relevant to the provision of financial advisory services on collective investment schemes and life insurance
B. How we use personal data
The purposes for which personal data of our clients may be collected or used will vary depending on the nature of your relationship with us. For example, we may use your personal data to:
- confirm your identity and uniquely identify you;
- confirm the accuracy of the information collected;
- provide advice on collective investment schemes and life insurance;
- assess your financial health and needs;
- determine and verify your ability to afford the financial and insurance products you apply for;
- communicate with you, especially with respect to your policy, updates and changes;
- provide you with ongoing services and respond to your queries or instructions;
- make or obtain payments;
- recover any debts owed to us;
- detect, investigate and prevent fraud, or other unlawful or improper activities;
- coach employees and monitor for quality assurance;
- comply with all legal and regulatory requirements within and outside Singapore including disclosures to judicial, regulatory, government, statutory authorities and industry entities;
- resolve complaints, and handle requests for data access or correction;
- conduct compliance monitoring and audit reviews;
- compile statistics to design and improve products and services, or participate in industry exercises and studies;
- assist us to understand the current and future needs of our clients, for example, to conduct surveys and other forms of market research and analysis;
- perform any functions and activities related to products or services including but not limited to marketing, audit, reporting, research, analysis, general servicing and maintenance of online and other services;
- design, promote, improve and further the provision of our financial advisory services;
- conduct checks with the National Do Not Call Registry and our internal Do Not Call Registry;
- comply with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognized bodies (whether within or outside Singapore) that is assumed by or imposed on us or any member of our group of companies by reason of its financial, commercial, business or other activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognized bodies;
- for operational purposes, credit assessment, credit scoring models or statistical analysis (including in each case, behavior analysis and evaluation of the overall relationship with our group of companies which includes using such data to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within our group of companies and/or other use of data and information in accordance with any group-wide programmes for compliance with extra-territorial enforcement of tax, sanctions or prevention or detection of money laundering, terrorism financing or other unlawful activities), whether on our clients or otherwise;
- exercise any rights we may have in connection with the provision of advisory services on collective investment schemes and life insurance to you;
- enable an actual or proposed assignee, transferee, participant or sub-participant of our rights or business to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;
- market collective investment schemes and life insurance where specifically or deemed consented to or where permissible under applicable laws or regulations; or
- for any other purposes specifically provided for in any particular financial advisory service offered by us or permitted or required by law or the relevant authorities.
C. To whom we disclose personal data
Personal data held by us will be kept confidential, but we may disclose or transfer such personal data to the following persons and/or entities (whether within or outside Singapore) for any of the purposes set out in paragraph above:
- any companies providing collective investment scheme or life insurance;
- any agent, contractor or third party service provider who provides administrative, consultative, telecommunications, computer, information technology, payment, data processing or storage, or any member of our group of companies in connection with the operation of our business;
- any credit reference agencies or, in the event of default, any debt collection agencies;
- employers of our clients;
- any person which has undertaken to us or any member of our group of companies to keep such personal data confidential;
- any member of our group of companies, where such a disclosure is required for the provision of financial advisory services to you;
- any person to whom we or any member of our group of companies is under an obligation or otherwise required to make disclosure under the requirements of any laws, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to us or any member of our group of companies including but not limited to any local or foreign regulators, governmental bodies, or industry recognized bodies; or
- any person to whom we or any member of our group of companies is under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognized bodies that is assumed by or imposed on us or any member of our group of companies by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognized bodies.