Privacy – SINGAPORE CONSORTIUM INVESTMENT MANAGEMENT LIMITED

This Privacy Statement sets out SICIM’s policy in relation to its collection, use and disclosure of personal data which is governed by the Personal Data Protection Act 2012, Act 26 of 2012 (“PDPA“).

DEFINITION OF PERSONAL DATA
1. 1.1 “Personal data” refers to data, whether true or not, about an individual who can be identified:
  1. 1.1.1 from that data; or
  2. 1.1.2 from that data and other information to which SICIM has or is likely to have access.
2. 1.2 Exception: The PDPA does not apply to business contact information, which refers to “an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes”.
Collection, Use and Disclosure of Personal Data
SICIM only collects personal data that it requires for its business and/or as may be required by laws, regulations and/or authorities (in and outside of Singapore). Personal data may be collected by SICIM or by a third party and may be collected from an individual or entity or from a third party.
The purposes for which personal data may be collected, used and disclosed by SICIM (“Purposes”) includes:-
1. conducting customer due diligence checks (e.g. for the purposes of meeting anti-money laundering / countering the financing of terrorism requirements);
2. providing services to customers/clients and other individuals;
3. responding to your enquiries or requests pursuant to emails, telephone calls, faxes and/or completion of forms;
4. responding to and taking follow up action on complaints;
5. performing office and operational administrative matters;
6. designing and marketing financial services or related products;
7. complying with applicable laws, rules and regulations, as may be amended from time to time; and
8. for any other purpose that is incidental or ancillary or in furtherance to any or all of the above.
Consent
You are deemed to have provided consent to the collection, use and disclosure of your personal data in instances where you have provided such personal data for the Purposes and to the disclosure to SICIM and its agents and other third parties as SICIM may think fit for the Purposes.
Withdrawal of Consent
You may withdraw your consent (for all or any purpose) to SICIM for the collection, use and disclosure of your personal data by giving SICIM reasonable notice in writing to SICIM’s Data Protection Officer. You are aware there may be implications arising from the withdrawal of such consent.
Access to Personal Data
You may request for access to your personal data in the possession or under the control of SICIM with a fee. SICIM reserves its right to refuse such access in accordance with the PDPA.
Correction of Data
You may request SICIM to correct an error or omission in your personal data in the possession or under the control of SICIM as soon as practicable. SICIM reserves its right to refuse any correction if it is satisfied on reasonable grounds that a correction should not be made, and in accordance with the PDPA.
Third Party Information
When you provide SICIM information about a third party, you confirm that you have obtained the consent of such third party for the disclosure of their personal data to SICIM, and the subsequent use, processing and disclosure by SICIM of such personal data.
Transfer of Information Overseas
By submitting your personal data, you acknowledge and agree that your personal data may be transferred to, processed and stored at a destination outside Singapore. SICIM will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement and the PDPA. This may include, but not limited to, entering into appropriate contract with the foreign transferee for the transfer of information, or without such a contract if the PDPA and/or the law permits.
Retention
SICIM will retain your personal data in accordance with the PDPA and other applicable laws, and only for as long as it believes it is necessary to do so.
Security safeguards
SICIM has in place a system to protect your personal data. As a matter of principle, SICIM endeavours to collect personal data only where necessary and to disclose such personal data on a need-to-know basis only. While SICIM will take utmost care to protect the data collected, SICIM cannot be held responsible for any compromise as a result of unforeseen circumstances.
Cookies / IP Addresses
When you use this website, SICIM may collect and store information about your computer (including your IP address, operating system and browser type) for system administration. This is statistical data about browsing actions and patterns of users of this website. While this could possibly lead to your identification, SICIM do not use such data to do so. This website uses cookies that help to remember information about your visit. These can make your next visit easier and this website more useful to you. Most web browsers can be configured not to accept cookies, or to notify you if a cookie is sent to you.
Other Matters
1. Links to other Websites as stated under the Terms and Conditions of Use, this website contains hyperlinks to websites which are not maintained by SICIM. SICIM cannot control the policies of other websites this website may link to, or the use of any personal data you may share with them. Please note that this Privacy Statement does not cover these other websites, and SICIM recommends that you apprise yourself of their specific policies.
2. Withdrawal of consent and request of access to and correction of personal data. You may write to our Data Protection Officer (see Section 12(c) below)
  1. Withdraw your consent to the collection, use and disclosure of your personal data in accordance with the PDPA. As a consequence of withdrawal of consent, SICIM may not be able to carry out the Purposes for which you have provided the personal data.
  2. Request to have access to your personal data or to correct an error or omission in the personal data. SICIM may charge a reasonable administrative fee for such service. In exceptional circumstances, SICIM reserves the right to deny your request and may provide an explanation as required by applicable laws. Such exceptional circumstances include where an investigating authority or government institution objects to SICIM complying with such request.
3. Contact Us
  If you have any questions, feedback and requests relating to this Privacy Statement, please contact our Data Protection Officer at
  Email – DPO@sicim.com.sg
  Write to
  Data Protection Officer
  Singapore Consortium Investment Management Limited
  250 Tanjong Pagar Road, #09-01 St Andrew’s Centre
  Singapore 088541
4. Changes to this Privacy Statement
  We may update this Privacy Statement from time to time by posting the updated version on this website.