Data Protection Policy
(For Corporate, Institutional and Individual Customers)
1. Introduction
The objective of this Data Protection Policy is to inform you of how the CLSA entity which provides or will provide services and/or products to you, as well as its representatives, affiliates and/or agents, (collectively referred to herein as “CLSA”, “us”, “we” or “our”) manages Personal Data (as defined below) which is subject to the privacy or personal data protection laws of the relevant jurisdictions, including the Singapore Personal Data Protection Act (No. 26 of 2012) (“PDPA”). We ask that you read this Data Protection Policy carefully as it contains important information about what to expect when we collect Personal Data about you or from you and how we will use and/or disclose such Personal Data.
In addition, this Data Protection Policy is intended to provide you with sufficient information to enable you to notify, and obtain consent from, any natural person (a “Relevant Person”) in respect of whom Personal Data may have been provided or may be provided by you or your agent to CLSA from time to time.
This Data Protection Policy supplements but does not supersede or replace any other consents you may have previously provided to CLSA in respect of your Personal Data, and your consents herein are additional to any rights to which CLSA may have at law to collect, use or disclose your Personal Data.
2. Personal Data
In this Data Protection Policy, “Personal Data” refers to any data about you or a Relevant Person, whether true or not, such that you or such natural person (as the case may be) 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 us include your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any Relevant Person which you have provided us in any forms you may have submitted to us, or via any other form of interaction with you.
Apart from Personal Data, we may collect other types of information which is not linked to a natural person and which is anonymous. For example, the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our customer services.
3. Purposes for the Collection, Use and Disclosure of Personal Data
Generally, CLSA collects, uses and discloses Personal Data for the following purposes:
a) processing applications for account opening, account maintenance and operations relating to your account(s), including without limitation, processing your applications or requests for services and/or products, processing your transactions, operating and closing your account(s);
b) providing services and/or products to you (including the services and products of external providers) from time to time and dealing with all matters relating to the services and products;
c) managing your relationship with us and/or administration of your account with us including (where you act as agent for another party) those of your underlying principals;
d) carrying out your instructions or responding to your enquiries or feedback;
e) conducting identity and/or credit checks, and carrying out customer due diligence and other checks and screenings and ongoing monitoring that may be required under any applicable law, regulation or directive or internal policies and procedures of CLSA (including but not limited to to those designed to combat bribery and corrupt practices, money laundering, terrorist financing and financial crime);
f) preventing, detecting and investigating fraud, misconduct or any unlawful activities, whether or not requested by any relevant governmental or regulatory authority, and analysing and managing commercial risks;
g) complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any governmental, tax, law enforcement or other authorities (whether local or foreign);
h) managing CLSA’s infrastructure and business operations and complying with CLSA’s policies and procedures that may be required by applicable laws and regulations including those relating to risk control, security, audit, finance and accounting, systems and business continuity;
i) addressing or investigating any complaints, claims or disputes;
j) developing new services and/or products and updating you on our products and services from time to time;
k) unless you have indicated your preference to opt out, providing you with marketing, advertising and promotional information, materials and/or documents relating to banking, investment, credit and/or financial products and/or services that CLSA may be selling, marketing, offering or promoting, whether such products or services exist now or are created in the future;
l) carrying out research, planning and statistical analysis;
m) organizing promotional events; and
n) enforcing our legal and/or contractual rights against you including, but not limited to, recovering any and all amounts owed to us,
(collectively, the “Purposes”)
4. Consent
By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to:
a) CLSA collecting, using, disclosing and sharing Personal Data for the Purposes; and
b) disclosing and sharing such Personal Data to CLSA’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
If you do not wish for us to continue to use your Personal Data or the Personal Data provided by you to us for any of the Purposes at any time in the future, you must notify us in writing to withdraw your consent (see Section 12). Depending on the circumstances, your withdrawal of consent may result in CLSA’s inability to provide you with the services and/or products that we have been offering to you, and consequently, may result in the termination of your relationship and/or accounts with us.
Where the personal data protection laws of the relevant jurisdictions permit us to collect, use or disclose the Personal Data without your or the Relevant Person’s consent, such permission granted by law will continue to apply.
5. Disclosure, Sharing and Transfer of Personal Data Overseas
Subject to the provisions of any applicable law, Personal Data may be disclosed or transferred to, shared with or kept by the following entities, wherever located, for any of the Purposes or for processing for any of the Purposes:
a) other members of the CLSA group of companies;
b) any third party service providers, including archival management service providers;
c) our professional advisers (including lawyers) and agents (including our executing brokers, clearing houses and settlement agents);
d) our auditors;
e) any person to whom disclosure is permitted or required by law or any court order;
f) any local or foreign government agencies, regulatory authorities and statutory bodies having jurisdiction over us; and
g) any of their respective successors and assigns.
To the extent that we may need to transfer personal data outside the relevant jurisdiction, we shall do so in accordance with the personal data protection law of that jurisdiction to ensure that we provide a standard of protection to the Personal Data so transferred that is comparable to the protection under that jurisdiction.
6. Access And Correction
If you would like to obtain access and make corrections to your Personal Data, you may contact us in writing at the address set out in Section 12 below referencing ‘Data Protection Policy’. We may charge a reasonable administrative fee for this service. In exceptional circumstances, we reserve the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws.
7. Retention
Personal Data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain Personal Data, or remove the means by which the Personal Data can be associated with particular individuals, as soon as it is reasonable to conclude that the purpose for which that Personal Data was collected is no longer being served by retention of the Personal Data and retention is no longer necessary for legal or business purposes.
8. Data Security
CLSA has taken and will continue to take reasonable efforts to protect Personal Data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
While we strive to protect your Personal Data, we cannot ensure the security of any Personal Data which you may have transmitted to us, via the Internet, and we urge you to take every precaution to protect your Personal Data and use a secure browser.
9. Updates To The Data Protection Policy
CLSA may from time to time update this Data Protection Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Such changes will be posted on our website.
Such changes to our Data Protection Policy shall apply from the time that we post the same on this website. Your continued use of our service will be taken as acceptance of the updated Data Protection Policy.
10. Cookies
A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you.
The information is used to track visitor use of the website and to compile statistical reports on website activity. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier.
For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. If you wish to reject our cookie, you can configure your browser to do so. However, in a few cases some of our website features may not function if you remove cookies from your browser.
11. Third Party Websites
Our website may contain links to other websites. Please note that we are not responsible for the privacy practices of such other websites and you are advised to read the privacy statement of each website you visit which may collect your Personal Data.
12. Contacting Us
If you have any comments or questions about the collection, use or disclosure of your Personal Data or this Data Protection Policy, please contact us in writing at the address below referencing ‘Data Protection Policy’:
Data Protection Officer
CLSA
80 Raffles Place #18-01
UOB Plaza 1
Singapore 048624
Email: dpo-sg@clsa.com
Telephone: +65 6416 7888