Singapore Data Protection Notice
Your privacy is of the utmost importance to SYFE Pte. Ltd. In this policy, “we”, “us”, “our” or “SYFE” means SYFE Pte. Ltd., and “you”, “your” or “yours” means the persons to whom this policy applies.
This data protection notice (the “Notice”) outlines how we collect, use, store and disclose your personal data in accordance with the Personal Data Protection Act (“PDPA”). The PDPA strives to protect personal data of individuals. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data.
This Notice supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this to ensure that this Notice is consistent with our future developments, industry trends and/or any Notice changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Notice shall apply. For the avoidance of doubt, this Notice forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.
What is Personal Data?
Personal data refers to any data or information about you from which you can be identified either
(a) from that data or
(b) from that data and other information to which we have or are likely to have access.
Depending on your relationship with us (e.g. prospective or current client, employee or business partner), the personal data about you that we may collect, use, store and disclose include:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity
card/passport details, and/or education details);
- specimen signature(s);
- financial details (e.g. income, expenses, and/or credit history);
- images and voice recordings of our conversations with you;
- employment details (e.g. occupation, directorships and other positions held, employment
history, salary, and/or benefits);
- tax and insurance information;
- information about your risk profile, investments, investment objectives, knowledge and
experience and/or business interests and assets; and/or
- banking information (e.g. account numbers and banking transactions);
We Keep Your Personal Data Confidential and Secure
At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and procedural safeguards to protect your personal data against loss, misuse, damage and unauthorized access, modifications or disclosures.
Purposes for Collection, Use, and Disclosure of Your Personal Data
We collect, use and/or disclose your personal data to provide enhanced asset management services, including operations for these purposes. This may include the following (non-exhaustive) as applicable to the relationship we have with you:
(a) evaluating your standing, resources, and capabilities to enter or maintain a relationship
with you as a client, employee, business partner or other;
(b) evaluating your performance as our employee or business partner;
(c) conducting credit checks, screenings or due diligence checks as may be required under
applicable law, regulation or directive;
(d) addressing or investigating any complaints, claims or disputes;
(e) verifying your identity for the purposes of providing services to you as our client;
(f) analysing your financial situation and determining financial strategies and products
suitable for you as our client;
(g) assessing and processing any applications, requests, and instructions for financial
products and services offered by other financial institutions for you as our client;
(h) managing our infrastructure and business operations and complying with internal policies
(i) responding to queries or feedback;
(j) complying with all applicable laws, regulations, rules, directives, orders, instructions and
requests from any local or foreign authorities, including regulatory, governmental, tax and
law enforcement authorities or other authorities;
(k) financial reporting, regulatory reporting, management reporting, risk management, audit
and record keeping purposes;
(l) enforcing obligations owed to us; and/or
(m) seeking professional advice, including legal advice.
We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customers. If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will adequately seek your consent.
How We May Collect Your Personal Data
Generally, we may collect your personal data ourselves or through third parties in ways including the following:
(a) during our preliminary discussions with you to enter into employment or for any other
(b) when you interact with our customer service staff;
(c) when you communicate with us by email or telephone, your emails will be retained and
we may monitor and/or record your voice calls to us;
(d) when you access our website;
(e) when you respond to our requests for additional personal data; or
(f) when you submit your personal data to us for any other reason.
You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please reach out to your Customer Service Officer or our Compliance Officer.
Where you provide us with your personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain the proof of such consent(s), such proof to be provided to us upon our request.
Who We May Disclose Your Personal Data to
Generally, we shall protect and keep confidential your personal data. We will disclose your personal data only with your consent and for purposes that you have been informed about. However, subject to applicable laws, we may disclose your personal data for the purposes set out above to parties such as those described below:
(a) banks, financial institutions, and their respective service providers;
(b) companies providing services relating to insurance to us, and associations of insurance
(c) agents, contractors or third party service providers who provide services to us such as
telecommunications, information technology, payment, data processing, storage and
(d) our professional advisers such as our compliance advisors, auditors and lawyers; and
(e) regulators and authorities.
When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, 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, we 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.
How Long We Keep Your Personal Data For
We shall store your personal data for as long as necessary to fulfill the purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required.
Queries, Access/Correction Requests, and Withdrawal of Consent
(a) have queries about our data protection processes and practices;
(b) wish to request access to and/or make corrections to your personal data in our
possession or under our control; or
(c) wish to withdraw your consent to our collection, use or disclosure of your personal data;
please submit an email request (with supporting documents, if any) to our
Compliance Officer at the following address below:
Compliance | Email: firstname.lastname@example.org
Our Compliance Officer shall strive to respond to you within 30 days of your submission.
Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such an event.