DATA PRIVACY POLICY
Q INVESTMENT PARTNERS PTE. LIMITED
In accordance with the Personal Data Protection Act in Singapore (“PDPA”),
Q Investment Partners Pte. Limited and all of its affiliates (collectively referred to as “Q.I.P.”, “we” or “us”)
are committed to safeguarding the personal data of all current, former and prospective clients
(collectively referred to as “clients” or “you”) of Q.I.P.. This Data Privacy Policy (the “Data Privacy Policy”)
sets out the type of personal data we may collect, the purposes for which we use the information, the circumstances
in which we may share the information, the security measures we take to protect the security of your personal data
and to keep them accurate and current, and includes how the PDPA regulates our collection, use, retention, disclosure
and processing of personal data as well as our obligations under the PDPA.
You agree and consent to Q.I.P., its authorised service providers and relevant third parties collecting,
using, retaining, disclosing and/or sharing your personal data in the manner set forth in this Data Privacy Policy.
This Data Privacy Policy supplements, but does not supersede or replace, any other consent that you may have previously provided to us.
It also does not affect any lawful rights that we may have in connection with the collection, use, retention and/or disclosure of
your personal data. This Data Privacy Policy may be updated from time to time to ensure that it is consistent with our business
purpose and/or any changes in legal or regulatory requirements.
For the avoidance of doubt, this Data Privacy 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.
1. 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 Q.I.P. has or is likely to have access to.
Personal data that we collect from you includes but is not limited to:
- full name;
- NRIC, passport or other identification number;
- contact details (including address, telephone number, e-mail address);
- employment, education, assets and income details;
- information about your transactions with Q.I.P. and others (including balances, parties to the transactions, and account usage); and.
- other information relating to you which you have provided to us in any forms submitted to us, or through other forms of interaction with you.
Personal data does not extend to personal information that is provided as business contact information (“BCI”). The PDPA defines BCI as “an individual's name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes”.
2. Purposes for the collection and use of your personal data
We may collect your personal data and use it in the following ways:
We may collect your personal data from applications or forms you complete, agreements you enter into with us
or in the course of your establishing or maintaining a client relationship with us regarding an investment product
or vehicle including your name, postal and email address and other related information.
This is to allow us to complete your transaction and also to provide confirmation of the transaction to you.
When you browse the website we will store information as to how you use the website in order to improve the quality of service provided to you.
We may also use the information we collect in order to inform you about changes to the website and, subject to any applicable local laws,
other information that we think may be of interest and/or useful to you.
We may collect, use, retain and/or disclose your personal data including any additional information you may subsequently provide
to us for the following purposes:
(1.1.A) to process and complete your applications and transactions;
(1.1.B) to complete the information on the register of holders;
(1.1.C) to prepare your account statements and send statements/notices relating to your account;
(1.1.D) to carry out your instructions or respond to any enquiry from you;
(1.1.E) to deal with any other matters relating to your account and holdings;
(1.1.F)other information relating to you which you have provided to us in any forms submitted to us, or through other forms of interaction with you.
(1.1.G) to keep you informed of changes and updates to our policies, terms and conditions and new offers that may be of interest to you;
(1.1.H) to identify you in order to protect against fraud and guard against unauthorized access to your accounts;
(1.1.I) 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;
(1.1.J) to satisfy Q.I.P.’s responsibility relating to ‘Know Your Client’ (KYC) requirements; and
(1.1.K) other purposes, directly or indirectly relating to any of the above and Q.I.P.’s activities,
and in terms of the administration of current, former and prospective personnel including (where applicable)
self-employed or contract personnel, secondees, temporary staff for the following purposes:
recruitment, promotion, redeployment, secondment and/or career development;
administration and payment of wages, salaries, pensions and other benefits with deductions
(including maternity, parental and dependant leave, maternity and paternity pay, and insured benefits);
personnel assessment and training;
compliance with Q.I.P.’s policy and/or legislation in relation to health, safety and other employment matters;
management of absence (including maternity, parental and dependant leave, holidays and sickness absence); and
the provision of financial services by us, including advising and acting on behalf of clients, or the development or promotion of such services,
(collectively referred to as the “Purposes”).
Our employees have limited access to your personal data based on their responsibilities.
This access enables them to assist you in completing transactions, offer you additional financial services,
resolve any client service issues that may arise and/or fulfil the above Purposes. Our employees are instructed
to use due care when handling your personal data.
Where you have specifically provided us with consent, Q.I.P. may also collect, use, retain and/or
disclose your personal data for the following purposes: (i) sending you marketing updates that may be of interest to you;
(ii) promoting and administering events, contests and competitions; and (iii) developing marketing programmes.
It is not compulsory for you to supply any of the personal data that we may request. However, failure to do
so may result in us not being able to provide services offered by Q.I.P. to you.
3. Disclosure of your personal data
We may share your personal data with Q.I.P.’s affiliates, including but not limited to Q.I.P.’s holding company, subsidiaries,
related and/or associated company, delegates, trustee(s), business partners, and/or service providers,
or any third party and/or agents (including outsourcing agents and data processors), any 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 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.
Except as described in this Data Privacy Policy (including this Clause), Q.I.P. will not disclose or sell your personal data to third parties.
Third party disclosures may include sharing such information with non-affiliated companies who perform support services on our behalf including those that provide professional, legal or accounting advice to Q.I.P.. These companies are required to ensure appropriate security measures are in place and maintain the confidentiality of such information to the extent they receive it,
and to use your personal data only in the course of providing such services to Q.I.P. and only for the purposes that Q.I.P. dictates.
These non-affiliated companies, however, may be based in countries where privacy laws do not exist or provide less protection
than the laws your home jurisdiction.
We may also disclose your personal data to fulfil your instructions or pursuant to your express consent.
Under limited circumstances, your personal data may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to proceedings of a court of law or similar legal process,
to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities.
4. 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.
Under the PDPA, you have the right to access your personal data at any time to check whether it is accurate and up-to-date
and make any necessary corrections. If you wish to do so, or have any enquiries in respect of your personal data, please contact
our Data Protection Officer.
Q.I.P. may charge an administrative fee for responding to access requests. This fee shall be based on a cost recovery basis
and be reasonable. A written estimate of the fee shall be provided to you before such fee is charged. If in doubt as
to whether any administrative fee is applicable, please contact our Data Protection Officer.
Q.I.P. reserves its right to refuse to comply with your request for access or correction to your personal data under the PDPA.
If Q.I.P. refuses to comply with such request, you will be informed of such refusal and the reason for the same.
5. Retention of your personal data
Q.I.P. will cease to retain documents containing personal data or remove the means by which the personal data
can be associated with you as soon as it is reasonable to assume that the personal
data no longer serves the Purposes and is no longer required for business or legal purposes.
We will retain your personal data in accordance with applicable laws for so long as it is necessary.
Q.I.P.’s recordkeeping and document retention policy is to retain such documents for at least six years after the termination
of our relationship with you.
In the event the documents are (i) related to any actual, potential or threatened litigation or regulatory
request or investigation, or (ii) related to an ongoing internal or external audit. Again, if in doubt, please contact our Data Protection Officer.
6. Security measures
For forms containing sensitive personal data, such as payment or bank details, we will only transmit
them after we authenticate your details to the web server
using a ‘secure form’ in which your details are encrypted.
We will use the most secure encryption level available.
You should notify us immediately if you have any reason to suspect that someone else may be using your details.
An encryption certificate can be viewed by double clicking on the padlock icon
displayed within the web browser window when you are on a secure page.
6.1 Securing your personal data
For forms containing sensitive personal data, such as payment or bank details, we will only transmit them after
we authenticate your details to the web
server using a ‘secure form’ in which your details are encrypted. We will use the most secure encryption level available.
You should notify us immediately if you have any reason to suspect that someone else may be using your details.
An encryption certificate can be viewed by double clicking on the padlock icon displayed within the web browser window when you are on a secure page.
6.2 Storing your personal data
In most cases your personal data is passed immediately to our customer service centre without any personal
data being stored on the web server at all.
If we need to store personal data temporarily, any sensitive personal data is securely encrypted and stored away
from publicly-accessible areas of our web server.
6.3 Transmitting your personal data
Once we have received your personal data, the web server, located in a secure area of the network,
immediately passes your personal data through an additional firewall into an application server and onto
a server to allow us to execute your order within the customer service centre. Only authorised staff can access the personal data.
7. Personal data for marketing purposes
If you do not wish to receive marketing material or not want Q.I.P. to use or continue using your personal data for
marketing purposes, please contact our Data Protection Officer.
8. 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 Privacy Policy,
you may contact our Data Protection Officer at info@q-investmentpartners.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),
Q.I.P. may not be able to process your personal data for any or all of the Purposes.
9. Changes to the Policy
Please be aware that this Data Privacy Policy may be updated from time to time.
As such, please ensure that you regularly read the latest version of this page.
We may also circulate separate guidance to appropriate personnel on specific issues from time to time.
10. Questions
If you have any questions or complaints relating to this Data Privacy Policy or how we use your personal data or
if you would like to correct any of your personal data previously provided to us,
please contact our Data Protection Officer at info@q-investmentpartners.com who will endeavour to respond to you.