Privacy Policy of PAMPL
1.1 This data protection notice outlines how we use, collect, retain and/or disclose your personal data in accordance with the Personal Data Protection Act (“PDPA”). The PDPA serve to protect individuals’ personal data. Please read about the purposes and how we use, collect, and/or disclose your personal data.
1.2 This Notice supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the use, collect, retain and/or disclosure of your personal data. We may update this Notice periodically to ensure that this Notice is consistent with our future developments, industry trends and/or any 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?
1.3 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 and/or likely have an access. Depending on your relationship with us (e.g. business partner or current client, employee), the personal data about you that we may use, collect, retain and/or disclose include:
1. your contact details include your name, passport, identification numbers, contact numbers, address, email and etc;
2. your personal details enabling us to evaluate and manage your client, employment or business relationship with us, e.g. your working experience, education level, bank details and etc;
3. your personal details enabling us to analyse your situation, determine suitable strategies and execute respective action, e.g. family status, financial status, transaction history;
4. photos and videos of you from our office surveillances; and
5. information when your use of our services and website, including cookies and IP address.
We Keep Your Personal Data Confidential and Secure.
1.4 At each stage of data usage, collection, storage and/or disclosure, we implement physical, electronical, administrative and procedural safeguards to protect your personal data against misuse, loss, damage for unauthorized access, modifications or disclosures.
Purposes for Usage, Collection, Retention and Disclosure of Your Personal Data
1.5 We use, collect, retain and/or disclose your personal data to improve, enhanced and modify asset management services and/or family office services, including operations for purposes that include the following:
1. any other purposes related to the above purposes.
2. updating you our latest services and special event happenings;
3. internal reporting and analysis related to our business operations;
4. responding to your queries and requests and handling complaints;
5. evaluating your performance as our employee or business partner;
6. reporting to you as our client on your financial situation and our performance of our services to you;
7. analysing your financial situation and determining financial strategies and products suitable for you as our client;
8. Maintaining the records for interact with you, through telephone recordings, documentation (hard copy and electronic), and
9. managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;
10. approaching and processing any applications, requests and instructions for financial products and services offered by us and/or other financial institutions or product providers for you as our client;
11. evaluating your standing, resources and capabilities to enter to maintain a relationship with you as a client, employee, business partner or other;
12. for detecting, conducting any form of investigation and preventing fraudulent, prohibited or illegal activities and analysing and managing commercial risks, including those relating to disputes, billing, fraud, offences, prosecutions etc;
1.6 If we wish to use, collect, retain and/or disclose your personal data for any other purposes, we shall seek for your consent.
How We May Collect Your Personal Data
1.7. Generally, we may collect your personal data ourselves or through third parties in ways including the following:
1. when you submit your personal data to us for any other reason.
2. when you access to our website;
3. when you communicate with us by email or telephone, your emails will be retained
4. when you respond to our requests include any additional personal data; or
5. when voice or video call by any device between us, we shall monitor and/or record;
6. during our preliminary discussions with you to establish a new client relationship, enter into employment or for any other business relationship;
7. when you interact with our employees may include with your Relationship Manager, operation staff for not limited to services and financial related;
1.8 Without prejudice to the generality of the foregoing clauses, we may collect information from the device that includes computer, mobile device, smart device and etc. that you use to access our websites.
1.9 Where you provide us personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.
1.10 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. You shall take the responsibility in any circumstance that results of failure of delivering the services due to your inaccurate, incomplete and misleading data that provide to us.
1.11 You shall visit or access our website as anonymous, however, your activities may be monitored by Cookies. “Cookies” are small data files sent to your browser to retain and track information about you and your activities when you enter our websites. The cookie is used to track information such as the number of users and frequency of use, profiles of users and their preferred sites. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. Otherwise, we shall treat it as you are accepting this.
Who We May Disclose Your Personal Data To
1.12 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. If we wish to use, collect, retain and/or disclose your personal data for any other purposes, we shall seek for your consent.
1.13 However, subject to applicable laws, we may disclose your personal data for the purposes set out above to parties such as those described below:
1. to regulators and authorities.
2. our affiliates, associated entities and any of their branches and offices which may also include entities and activities overseas;
3. banks and other financial institutions that partner, support and/or collaborate with us;
4. companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies;
5. agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival;
6. our professional advisers such as our auditors and lawyers; and
1.14 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.
1.15 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?
1.16 We shall retain your personal data for as long as necessary to fulfil 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.
1.17 If you have queries about our data protection processes and practices; wish to withdraw your consent to our use, collection, retention or disclosure of your personal data; or wish to request access to and/or make corrections to your personal data in our possession or under our control, please submit a written request (with supporting documents, if any) to our general email at info@pharos.com.sg.
1.18 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 position to maintain the products or services providing to you or administer. Such withdrawal may also result in the termination of any agreement you may have with us. In the circumstance whereas in the contract, agreement was terminated, you shall take the responsibility to the termination. Our legal rights and remedies are expressly reserved in such event.
If You Have A Complaint
1.19 We are committed to protecting your personal data. If, however, you should be dissatisfied with our handling of your personal data, please submit a written complaint to info@pharos.com.sg, containing details of your dissatisfaction to our Chief Operating Officer.
