Data Protection

The purpose of this policy ("Data Protection Policy") is to inform you how Seraya Investment Pte. Ltd. (“Seraya”) manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act 2012 (the “Act"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Seraya (including their related corporations) (collectively, the "Group"), as well as their respective representatives and/or agents ("Representatives") (the Group and Representatives collectively referred to herein as "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Group' authorised service providers and relevant third-parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any of the Group may have at law to collect, use or disclose your Personal Data.

Seraya may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on this website. Please check back regularly for updated information on the handling of your Personal Data.

Personal Data

In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

Collection of Personal Data

Generally, we collect Personal Data in the following ways:
1. when you submit any form, including but not limited to application forms or other forms relating to any of our products or services or any investments which you purchase through the Group;
1. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
1. when you interact with our staff, including relationship managers and their assistants, for example via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
1. when your images are captured by us via closed-circuit television cameras ("CCTVs"), if any, while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
1. when you use some of our services provided through online and other technology platforms, such as websites, including when you establish any accounts with us;
1. when you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
1. when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
1. when we seek information about you and receive your Personal Data from third-parties in connection with your relationship with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
1. through physical access, internet and information technology monitoring processes; and/or
1. when you submit your Personal Data to us for any other reason.
We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information.
If you provide us with any Personal Data relating to a third-party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of that third-party to you providing us with his/her Personal Data for the respective purposes.

"Connected Person" may include but is not limited to any beneficial owner, authorised signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, power of attorney holder, surety, third-party security provider, provider of funds, founder and/or employee, payee of designated payment, representatives, agents or nominees.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested. You agree to inform Seraya immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as Seraya may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, Seraya collects, uses and discloses your Personal Data for the following purposes:
1. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
2. verifying your identity and customer due diligence;
3. managing the administrative and business operations of the Group and complying with internal policies and procedures (including but not limited to facilitating business continuity planning);
4. audit purposes;
5. verifying or confirming trade orders or instructions from you or for your account (including but not limited to instructions on fund transfers or remittances);
6. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Group;
7. matching any Personal Data held which relates to you for any of the purposes listed herein;
8. resolving complaints and handling requests and enquiries;
9. preventing, detecting and investigating crime, including fraud and money laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of Seraya’s proprietary and sensitive information);
10. project management;
11. providing media announcements and responses, for example in relation to complaints or law suits;
12. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
13. managing the safety and security of our premise and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
14. managing and preparing reports on incidents and accidents;
15. organising events, seminars or trainings;
16. complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that applies to Seraya or that it is expected to comply, according to:
  
  - any law binding or applying to it within or outside Singapore existing currently and in the future;
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  - 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 of financial services providers within or outside Singapore existing currently and in the future;
  
  - any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on Seraya by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
17. to assist in law enforcement and investigations by relevant authorities;
18. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
19. archival management (including but not limited to warehouse storage and retrievals); and/or
20. any other purpose ancillary to any of the above.
These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s) or business relations with us.
In addition, Seraya collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
1. If you are a prospective customer:
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  - evaluating your eligibility to open an account with us and your financial and investment needs and providing recommendations to you as to the type of products and services suited to your needs;
  
  - assessing and processing any applications or requests made by you for products and services offered by Seraya; and/or
  
  - any other purpose relating to any of the above.
2. If you are a customer holding an account with Seraya or a Connected Person or an administrator, executor, liquidator, official assignee, receiver, judicial manager or other similar official who has been so appointed pursuant to bankruptcy or insolvency proceedings instituted in Singapore or elsewhere in respect of a Seraya customer or any security provider:
  
  - opening, maintaining or closing of accounts and our establishing or providing fund management services to you;
  - processing fund transfers or any other instructions provided in relation to the account of a Seraya customer;
  - where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and / or in accordance with the terms and conditions of our agreement with you;
  - processing applications for and facilitating the daily operation of services and credit facilities provided to you or other persons or corporations for whom you act as surety or third-party service provider;
  - conducting credit checks at the time of application for credit and at the time of regular or special credit reviews;
  - facilitating or processing your application for insurance products and/or trust services offered by Seraya and its business partners;
  - carrying out client reviews, for example, annual reviews of your portfolio;
  - to establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;
  - networking to maintain customer relationship;
  - providing client servicing (including but not limited to responding to individual requests by customers, mailing services, reconciliation services and providing customer satisfaction);
  - facilitating the transfer of funds within Seraya banking accounts or from Seraya accounts to external banking accounts and vice versa;
  - administering exceptional approvals, fee adjustments or waivers;
  - dealing with and designing investment products (for example, bonds, derivatives, equities or funds);
  - registering the pledge or charge that you or the surety or the third-party security provider has granted in favour of Seraya as security for the credit facilities granted by Seraya to you;
  - determining and collecting amounts owed by you or the borrower for whom you act as surety or third-party security provider or those providing security or acting as surety for your liabilities and obligations;
  - enabling any Group or third-party to perform the functions that Seraya may have outsourced to it in relation to the management of your account or transactions;
  - enabling an actual or proposed assignee of Seraya, or participant or sub-participant or transferee of Seraya’s rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer; and/or
  - any other purpose relating to any of the above.
3. If you are an employee or agent of a referrer or other intermediary:
  
  - marketing services and products;
  - processing commission remuneration;
  - performing due diligence and reference checks; and/or
  - any other purpose ancillary to any of the above.
4. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Seraya;
  
  - managing project tenders or the supply of goods and services;
  - processing and payment of vendor invoices;
  - complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or
  - any other purpose ancillary to any of the above.
5. If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):
  
  - providing cash, payment and transactional services (including but not limited to the execution, settlement, reporting and/or clearing of the relevant transaction); and/or
  - any other purpose ancillary to any of the above.
6. If you sit on the Seraya’s Board of Directors:
  
  - facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);
  - complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);
  - administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee); and/or
  - any other purpose ancillary to any of the above.
In addition, where you may have provided your consent and/or permitted under applicable law, Seraya may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):
1. providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
2. matching Personal Data with other data collected for other purposes and from other sources (including third-parties) in connection with the customisation, provision or offering of products and services, marketing or promotions, whether by Seraya or other third-parties;
3. sending you details of products, services, special offers and rewards, investment or research reports or guides, either to our customers generally, or which we have identified may be of interest to you; and/or
4. conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Seraya may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).
In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

Disclosure of Personal Data

Generally, Seraya collects, uses and discloses your Personal Data for the following purposes:
1. Seraya’s related corporations;
2. counterparties and their respective banks in relation to transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of cheques;
3. third-party recipients of reference letters;
4. trustees, attorneys and asset managers appointed by you to manage your account held with Seraya;
5. referrers who have referred you to Seraya;
6. any person (1) who provides security or acts as surety for your liabilities and obligations to Seraya or (2) for whom you act as surety or third-party security provider;
7. agents, contractors, vendors, installers, or third-party service providers who provide administrative or operational services to Seraya, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to Seraya;
8. agents, contractors, vendors or other third-party service providers in connection with marketing, products and services offered by Seraya;
9. analytics, search engine providers or third-party service providers that assist us in delivering our products, services, websites and platforms as well as improving and optimising the same;
10. your employers which are financial institution, for their internal surveillance or monitoring purposes;
11. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Group;
12. translators;
13. our professional advisers such as our tax advisors, auditors and lawyers;
14. third-parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with Seraya;
15. relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over Seraya or any Company or over any transaction entered into by you, such as the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority and the Inland Revenue Authority of Singapore and/or any other relevant securities exchange;
16. any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar official who has been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in Singapore or elsewhere, in respect of you or your assets;
17. third-parties who carry out registration of charge or pledge over the assets that you have pledged or charged to Seraya;
18. corporate service providers or lawyers, who are appointed by you;
19. surveyors or valuers or other third-parties in relation to assets which you will be charging or mortgaging to Seraya;
20. the Central Provident Fund (“CPF”) Board in relation to CPF investment products;
21. financial institutions, brokerage houses, clearing houses, depository, depository agents, managers, administrators, fund houses, registrars, custodians, external banks, the Central Depository, nominee banks and investment vehicles in relation to asset management and investment product settlement processing;
22. collection and repossession agencies in relation to the enforcement of repayment obligations for loans;
23. third-parties who organise promotional or marketing events, seminars or trainings;
24. any actual or proposed assignee of Seraya or participant or sub-participant or transferee of Seraya’s rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer;
25. any person to whom Seraya or any of the Group is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to Seraya or any of the Group, 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 of financial services providers with which Seraya or any of the Group are expected to comply, or any disclosure pursuant to any contractual or other commitment of Seraya or any of the Group with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside Singapore and may be existing currently and in the future; and/or
26. any other party to whom you authorise us to disclose your Personal Data to.
We will not sell your Personal Data.

Retention of Personal Data

We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

Data Security

Seraya will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, transfer, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and take any necessary precautions.
While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

Third-Party Sites

Our website may contain links to other websites operated by third-parties. We are not responsible for the privacy practices of websites operated by third-parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

If you:
1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
3. would like to obtain access and make corrections to your Personal Data records, please contact our Data Protection Officer.
Please note that if your Personal Data has been provided to us by a third-party (for example, The Central Depository Pte Ltd), you should contact that such party directly to make any queries, feedback and access and correction requests to Seraya on your behalf.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Seraya or any of the Group may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements you have entered into with Seraya or any of the Group, and your being in breach of your contractual obligations or undertakings, and Seraya’s or the Group’s legal rights and remedies in such event are expressly reserved.

Governing Law

This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.