Your privacy is important to us. This Data Protection Policy outlines how your personal data will be managed in accordance with the Personal Data Protection Act 2012 (the “Act”) which strives to protect personal data of individuals. Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we may collect, use and/or disclose your personal data.
You agree and consent to Aberdeen Asset Management Asia Limited (the “Manager”) and affiliates as well as our authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your personal data in the manner set forth in this Data Protection Policy.
This Data Protection Policy 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 collection, use and/or disclosure of your personal data. We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our business purpose and/or any changes in legal or regulatory requirements.
For the avoidance of doubt, this Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.
The Manager processes your personal data which you had previously provided through contact with the Manager. The Manager may also have obtained your personal information from third parties such as the Manager’s distributors when you submit an application for units in the sub-fund.
In this Data Protection Policy, the terms “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 the Manager has or is likely to have access.
Personal data that we collect from you includes but it’s not limited to:
- full name;
- NRIC, passport or other identification number;
- contact details (including address, telephone number, e-mail address);
- employment, education, and income details; and
- other information relating to you which you have provided to us in any forms you may have submitted to us, or in other forms of interaction with you.
Purposes for the collection, use and disclosure
The Manager collects, uses and/or discloses your personal data, including any additional information you may subsequently provide, for the following purposes:
(a) processing of your application for units in the sub-fund;
(b) to complete the information on the register of unitholders of the sub-fund;
(c) to contact you and to send statements/notices to you relating to your account and holdings therein;
(d) to carry out your instructions or respond to any enquiry from you;
(e) to deal with any other matters relating to your account and holdings therein;
(f) to form part of the records of the recipient as to the business carried out by it;
(g) communicating with you to inform you of changes and updates to our policies, terms and conditions and other administrative information;
(h) to observe any legal, government or regulatory requirements of Singapore or other relevant jurisdiction including any disclosure or notification requirements to which any recipient of the data is subject;
(i) to satisfy the Manager’s responsibility relating to 'Know Your Customer' (KYC) requirements; and
(j) other purposes, directly or indirectly relating to any of the above and the Manager’s activities.
(hereinafter collectively referred to as the “Purposes”).
Where you have specifically provided us with consents, the Manager may also collect, use and/or disclose for the following purposes: (i) sending you marketing updates on our funds; (ii) promoting and administering events, contests and competitions; and (iii) developing marketing programmes.
Disclosure of personal data
Your personal data may be disclosed to the Manager’s holding company, subsidiaries, related and/or associated company, affiliates, delegates, trustee(s), business partners, and/or service providers, or any third party and/or agents (including outsourcing agents and data processors), any and all governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, any court and/or officer of the court for any of the above Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes. Further, your personal data may be transferred to locations outside Singapore.
Withdrawal of consent
If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Data Protection Policy, you may contact the Personal Data Protection Officer by sending an email to: DataProtection.Singapore@aberdeen-asset.com
Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data (other than for purposes of direct marketing), the Manager may not be able to process your personal data for all of the Purposes.
Access and correction of your personal data
You are responsible for ensuring that the information you provide is accurate, complete, and not misleading and that such information is kept up to date.
You may access and request for correction of your personal data by contacting the Personal Data Protection Officer, at the Manager’s office with any enquiries in respect of your personal data via email at: DataProtection.Singapore@aberdeen-asset.com
The Manager reserves its rights to refuse to comply with your request for access or correction to your personal data under the Act and if the Manager refuses to comply with such request, you will be informed of such refusal and the reason for the same.