Avanda Investment Management Pte Ltd (“Avanda”) takes our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We recognize the importance of the personal data you have entrusted to us and our responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, or have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:
Data Protection Officer
Avanda Investment Management Pte Ltd
Singapore telephone number: +(65) 6805-8888
1. Introduction to the PDPA
1.1 “Personal Data” is defined under the PDPA to mean 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. Common examples of personal data could include names, identification numbers, contact information, bank account numbers and other financial information; and may also include the IP address of the visitor’s personal computer, the country from which the inquiry is made, the pages visited, the time at which a visit is made, and the browser type.
1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2. Purposes for Collection, Use, Disclosure and Processing of Personal Data
2.1 Avanda may collect, use, disclose and/or process your personal data for various purposes, including but not limited to:
(a) responding to enquiries or taking instructions from you or acting upon instructions issued by you or on your behalf;
(b) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(c) complying with or as required by any request or direction or regulatory requirement of any governmental authority;
(d) sending you information about any administrative changes, updates and/or amendments to our policies, terms and conditions; and
(e) sending you marketing, advertising and promotional information and materials relating to Avanda’s products and services from time to time via email.
(collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.2 In order to conduct our business operations more smoothly, we may disclose the personal data you have provided to us to our third party service providers, agents, delegates and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
3. Specific Issues for the Disclosure of Personal Data to Third Parties
3.1 We respect the confidentiality of the personal data you have provided to us. In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which (i) the disclosure is required or authorized based on the applicable laws and/or regulations; (ii) the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way; (iii) the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual; (iv) the disclosure is necessary for any investigation or proceedings; (v) the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; (vi) the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(b) where such disclosure without your consent is permitted by the PDPA or by law.
3.2 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to [similarly] protect your personal data.
4. Request for Access and/or Correction of Personal Data
4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. If we deny your access or correction request, we will provide you with reasons for doing so.
4.2 We will also charge you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
5. Request to Withdraw Consent
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control. Your withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of your withdrawal of consent, we may not be able to continue with your existing relationship with us.
6. Administration and Management of Personal Data
6.1 We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.2 We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) all of the purposes for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
6.3 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or other applicable law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations (which may or may not be set out in a contract between the parties) to provide to the transferred personal data a standard of protection that is comparable to the protection under the PDPA.
8. Updates on Data Protection Policy
8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
8.2 We reserve the right to amend the terms of this Data Protection Policy at any time at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at http://www.avanda.sg/data-protection-policy.
Last Updated on 6 January 2017