The objectives of this Policy are to:
- Provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of your personal data.
- Demonstrate our on-going commitment to protecting your privacy and addressing any privacy concerns that you might have.
- Describe the ways in which we collect, use, disclose and retain your personal data.
- Ensure that we comply with the PDPA.
- Facilitate our compliance with any further developments in the protection of personal data.
SECTION 2: TYPE OF PERSONAL DATA
Generally, some of the Services require us to know who you are so that we can best meet your needs. We may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
(a) contact data (name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, personal interests, and any other information provided us in any forms you may have submitted to us, interaction with Havenport and its agents/employees, or through opening an account with Havenport);
(b) other information that you voluntarily choose to provide to us (such as information shared by you with us through emails);
(c) financial information such as bank accounts, credit and debit card details or other payment instrument details;
(d) information received by body corporate under lawful contract or otherwise;
(e) your use of our Services, including data of investment history, volume, patterns, predictions, trends;
(f) email and telephone call data records;
(g) photographs, video and CCTV footage;
The information collected from you by Havenport may constitute Personal Data under the PDPA.
“Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.
Havenport will be free to use, collect and disclose information that is freely available in the public domain without your consent.
Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
SECTION 3: COLLECTION OF PERSONAL DATA
Personal Data may be collected by us through processes including, but not limited to the following:
(a) when you interact with any of our employees (including our fund managers, customer service officers);
(b) when customer submits an application to us to purchase our products or use our Services;
(c) when a customer asks to be included in an email or other mailing list;
(d) when an individual requests that we contact him/her;
(e) when an individual responds to our marketing initiatives; and
(f) when individual submits his/her Personal Data to Havenport for any other reason.
Information that you submit shall be deemed to be collected by us with your permission. Such information may include but is not limited to your name, contact and fax numbers, home, work and email addresses, bank account and investment details, credit card details, including the three-digit code that appears on the back of your credit card, date of birth, gender and lifestyle information and other information necessary to the provision of Services.
Data collected by automated means
Various technologies may be used in order to make it more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. These technologies include but are not limited to cookies, web beacons, tracing links, click stream data and web analytics. You may set up your web browser to block cookies. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our Websites.
SECTION 4: CONSENT TO COLLECTION OF PERSONAL DATA
Havenport shall not collect, use or disclose your personal data unless:
(a) you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or
(b) the collection, use or disclosure of your personal data without your consent is required or authorised under the PDPA or other written law.
Havenport shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or Service to you.
Havenport shall not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.
As part of our continuous effort to keep you informed on our new product and services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, seminars or other relevant information that may be of interest to you.
You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting the Data Protection Officer of Havenport directly (see Section 16 below).
Havenport may collect and use personally identifiable information that you volunteer, or other behavioural data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfil transactions and services requested by you.
Photographs, videos and CCTV footage may constitute personal data if an identifiable individual is captured. Havenport will either seek your written consent for the collection, use and disclosure of photographs, videos and/or CCTV footage of you, or state in the invitation to you of an event/launch, that photographs/videos/CCTV footage will be taken at the event/launch for publicity on Havenport’s print and electronic media. Appropriate and obvious notices shall also be put up at the reception or entrance of our event/launch to inform attendees on the event/launch day.
SECTION 5: PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL DATA
Havenport may collect, use or disclose your personal data only for purposes:
(a) that a reasonable person would consider appropriate in the circumstances; and
Havenport collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as a prospect, account holder, or as a business partner to Havenport, or others).
In general, Havenport may collect, use and/or disclose your Personal Data for the following purposes:
(a) maintaining records of Havenport’s interactions with you, through telephone recordings, documentation (hard copy and electronic), and
(b) internal reporting and analysis related to Havenport’s business operations;
(c) responding to your queries and requests and handling complaints;
(d) updating you on developments in our services and special happenings;
(e) managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;
(f) assessing and processing any applications, requests and instructions for products and services offered by Havenport;
(g) analysing your financial situation and determining financial strategies and products suitable for you as our client;
(h) evaluating your standing, resources and capabilities to enter or maintain a relationship with you as a client, business partner or other;
(i) establishment and maintenance of relationship with Havenport and/or within Havenport’s related companies or affiliates;
(j) marketing and promotion activities of Havenport;
(k) taking of photographs and/or videos (whether by our staff or third party photographers and/or videographers) during events or seminars organised by Havenport, its related companies and/or its affiliates for publicity purposes;
(l) if consented to in the application form and/or other methods of consent notification, providing marketing, advertising and promotional information via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
(m) any other purposes which Havenport may inform you of in writing from time to time, but for which Havenport will seek your separate consent; and
(n) any other purposes related to the above purposes.
Where you have specifically provided Havenport with additional consents, Havenport may also collect, use and/or disclose your Personal Data for the following purposes:
(a) providing you benefit, including without limitation sending you details of products and services, either to our customers generally, or which may be of interest to you; and
(b) matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any Havenport company, or other third parties.
If you have provided your Singapore telephone number(s) and have indicated that your consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Havenport may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about Havenport’s products and services.
SECTION 6: DISCLOSURE OF PERSONAL DATA
Havenport will only disclose Personal Data:
(a) for the primary purpose for which it was collected as outlined in Section 5 above;
(b) for purposes that a reasonable person will consider appropriate in the circumstances;
(c) where you have consented; or
(d) where permitted under the PDPA or other applicable law or if required by law.
Subject to applicable laws, Havenport may disclose your personal data for the purposes set out above to parties such as those described below:
(a) Havenport’s related companies and any of their branches and offices which may also include entities and activities overseas;
(b) banks, financial institutions, credit card companies, payment gateways and their respective service providers;
(c) companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies;
(d) agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival; and
(e) our professional advisers such as our auditors and lawyers.
When Havenport discloses your personal data to third parties, Havenport will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations (as set out in herein), 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 has to be transferred overseas, Havenport will, where legally required, inform you of the extent to which your personal data will be protected, in the foreign jurisdiction(s) to which it will be transferred.
In addition, Havenport would disclose Personal Data in the following circumstances:
(a) in response to a request from law enforcement authorities or other government officials;
(b) to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
(c) where the disclosure is necessary for investigations or legal proceedings.
SECTION 7: SHARING AND TRANSFER OF PERSONAL DATA
In general, the third-party providers used by us, such as data intermediaries and aggregators, will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
In the course of or in connection Havenport’s business operations, which includes, providing products and services to customers, Havenport may transfer Personal Data to the following parties for the following purposes:
(a) To Havenport’s related companies and/or affiliates;
(b) To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits;
(c) Financial institutions or payment gateways for purposes of payment processing and transactions related to Havenport’s provision of products and services;
(d) Other service providers who provide IT and outsourcing services such as electronic mail services, deployment of management operations for information technology and HR outsourcing services; and
(e) Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Havenport requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in Section 5 “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.
SECTION 8: CONFIDENTIALITY AND SECURITY
Havenport takes all necessary precautions to protect your personal information and implements reasonable security practices, precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Havenport’s business.
Havenport makes all Personal Data accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.
Notwithstanding the above, Havenport is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Havenport shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Havenport including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service etc.
SECTION 9: AGE OF CONSENT
By using the Website, you represent that you are at least the age of 18 years old, or you have given us your consent to allow any of your minor dependents to use this site as the case may be.
Havenport strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Website and services are not intended for use by minors, Havenport respects the privacy of minors who may inadvertently use the internet or the mobile application.
SECTION 10: ACCURACY
Havenport will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. Havenport will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.
SECTION 11: RETENTION OF PERSONAL DATA
Havenport only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
SECTION 12: ACCESS AND WITHDRAWAL OF PERSONAL DATA
You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to our Data Protection Officer. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.
We will, at your request, endeavour to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request.
There may be circumstances where Havenport will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
SECTION 13: TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE
SECTION 14: ACCURACY AND CORRECTION
You may request for information from Havenport on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one (1) year before the date of your request.
We will endeavour to ensure that your Personal Data we use is sufficiently accurate and complete in making any decision that impacts you.
To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to our Data Protection Officer. We will correct or complete your Personal Data as soon as reasonably practicable. If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at firstname.lastname@example.org.
SECTION 15: DO NOT CALL PROVISIONS
Havenport shall not, and shall ensure that its agents shall not, send a specified message to a Singapore telephone number without first checking with the Do Not Call Registry established by the Personal Data Protection Commission (“PDPC”) and receiving confirmation from the PDPC that such Singapore telephone number is not listed on the Do Not Call Register.
Havenport shall not, and shall ensure that its agents shall not, send a specified message to a Singapore telephone number, unless the specified message includes clear and accurate information identifying the person sending the specified message and/or the specific Havenport company, and such person’s and/or such Havenport company’s contact information.
The prescribed duration within which Havenport must check with the Do Not Call Registry before sending a specified message to a Singapore telephone number will be 30 days. You may continue to receive marketing messages and other product information from Havenport within the prescribed validity period.
Havenport shall not make, cause or authorise a voice call addressed to a Singapore telephone number that conceals or withholds, or that has the effect of concealing or withholding, the calling line identity from the recipient.
Havenport will not require ausers of a Singapore telephone number to consent to the sending of a specified message beyond what is reasonable for Havenport to provide its products, courses and services. Havenport will not obtain or attempt to obtain such consent by:
(a) providing false or misleading information; or
(b) using deceptive or misleading practices.
If a user of a Singapore telephone number gives notice withdrawing consent for the sending of a specified message to that number, then Havenport shall cease (and cause its agents to cease) sending specified messages to that number. Such withdrawal of consent shall be without prejudice to and does not limit or derogate from Havenport’s rights to collect, use and/or disclose the user’s personal data, in this case, pursuant to the applicable terms and conditions governing his/her relationship with Havenport and under the law.
Attention to: Data Protection Officer
Havenport Investments Pte Ltd
3 Church Street, Samsung Hub, #19-04/05, Singapore 049483
Phone: +65 6590 9090 (Ask to be connected to Data Protection Officer)
Effective date: October 1, 2016