SGMC-Capital pte ltd (hereafter referred to as “The Company”) is dedicated to protecting your personal data in accordance with the requirements of all applicable data privacy laws. We recognize the importance of protecting your personal information when you visit one of our websites (“Website”) and this Privacy Statement, is designed to help you better understand the information collection practices utilized by our various Websites, as required by Regulation (EU) 2016/679 of 27 April 2016, which is commonly referred to as the General Data Protection Regulation (or “GDPR”).
When you visit our Website, certain information may be gathered for a variety of different reasons, as described below. This information could potentially include personal data about you as an individual (“Personal Data”). As a result, we strongly encourage you to carefully review this Privacy Statement, and to contact us directly at the details provided below should you have any questions or concerns.
Unless specifically noted under the “Exceptions/Modifications” section below, the information contained in this Privacy Statement is globally applicable.
The Company is a RFMC entity licenced by MAS. Our registered address is:
Marina Bay Financial Centre Tower 1, #11-67. Singapore 018981
Notice of Privacy Policies and Practices
Types of Information Gathered
We collect personal information regarding our investors on applications, forms, transaction histories, and correspondence (electronic, written, and telephonic). Personal information may also be gathered through complaints, issue resolution events, data inputs to the Company website, issuance of required mailings, regulatory monitoring and retention. Personal information collected includes: identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers; telephone number; financial information, such as investor account name and number; and information regarding protected characteristics.
We also collect personal information about our business contacts through surveys, data inputs to the Company websites, interactions with electronic marketing material and employer platforms, conversations, and sales reports. Personal information collected includes: identifiers such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers; signature; telephone number; geolocation; internet or electronic network activity; information regarding protected characteristics; professional or employment information; education information; financial information; commercial information, including trading history, sales activity, and preferred products; and inferences drawn from any of the information identified above to create a profile reflecting preferences, characteristics, predispositions, behavior, or attitudes. A portion of the data collected is statistical in nature and is not generally attributable to any specific individual.
How We Use the Information
We use the information gathered to service your account and to provide you with additional information about products and services. Accordingly, your personal information may be used for auditing, regulatory reporting and retention, compliance testing, customer relationship management, portal functionality, research, data verification and analytics, problem resolution, statement fulfilment, and debugging purposes. The information we collect, as described above, may be shared (a) with our corporate affiliates in the financial services industry to enhance and improve customer communications, services, and products designed to meet our customers’ needs; (b) with local regulators and self-regulatory organizations pursuant to applicable law; and (c) with third-party service providers and vendors that perform specialized services on our behalf and/or support our account maintenance and service capabilities by preparing and mailing prospectuses, reports, and account statements, conducting research on client satisfaction, gathering votes for shareholder proxies, and providing marketing, analytic, and processing services.
Policies and Practices to Protect Personal Information
Only employees that have a business need for personal information are given access to that information. We maintain physical, electronic, and procedural safeguards that comply with standards to protect your non-public personal information.
The Company processes Personal Data only where we have a lawful basis to do so. The amount and type of Personal Data collected and/or processed, as well as the processing activity itself, will vary depending upon the status of our current relationship with you and the Personal Data you choose to provide to us. It may also include information about your selected country of residence. We also require you to provide us with your name and email address in order to send us a message through our ‘contact us’ form located within each Website. However, we recommend that you do not include any sensitive personal data or other confidential information within the ‘message’ section of this form, as these types of public electronic communication channels are generally not secure.
Your IP address
Collecting and Processing Personal Data
Personal Data supplied by you, including information gathered on our Websites, are processed for the legitimate interests of the Company and to comply with our legal and regulatory obligations. This information is used for the purposes set out in this Privacy Statement and directly related purposes. In particular, we use the information gathered on our Websites for the following purposes:
The legitimate interests mentioned above include meeting and complying with our accountability requirements and regulatory obligations globally, and the processing purposes described in the bullet points above in order to conduct our ongoing business activities in accordance with reasonable market standards.
Not Providing us with Information via a Website
You can, at your discretion, refuse to provide us with your Personal Data or refuse to submit your Personal Data to collection through the cookies. In this event however, it is possible that your ability to access certain parts of a Website, or to view certain content on our Website, may be restricted. It also means you will not be able to contact us directly through our Website using information in the “Contact Us” section (in which case, please note that we provide you with numerous other ways of contacting us).
We intend to use Personal Data gathered via our Website for direct marketing of relevant financial and investment products and services, as described above. However we first need to obtain your explicit consent in order to do so. We will therefore obtain your consent before using your Personal Data for direct marketing of these products and services. Once we have obtained your consent, you may request us to cease using your Personal Data for direct marketing at any time, without charge. This will not negatively impact your ability to access our Website. You may ‘opt out’ of receiving direct marketing communications from us at any time using the contact details as provided in this Privacy Statement.
We do not provide your Personal Data to third parties for their own direct marketing purposes.
Duration of Storage
How long we hold your Personal Data for will vary. The retention period will be determined by the following criteria:
Your Personal Data will not be retained for a period longer than necessary or permitted in light of the purpose(s) for which it was obtained (as described above), subject to the statutory limitation periods and our recordkeeping obligations set out under applicable laws and regulations.
Other Recipients of Your Personal Data
We do not sell your Personal Data to anyone for our own commercial gain. We do not disclose any of your Personal Data to any third party except:
In some cases, we may rely on our third party service providers in order to conduct our ongoing business, and in particular, to help us gather and store this information from our Websites, and for the purposes set out above. As a result, the Company may need to provide your Personal Data to certain of its third party service providers. The Company ensures that any such data transfers are made in accordance with the requirements of applicable laws and regulations on the protection of personal data and privacy – in particular, GDPR. In this case we ensure such third parties are contractually obligated to respect the privacy and security of any Personal Data they may have access to as a result of providing us with their services in accordance with all laws and regulations applicable to such Personal Data.
We also maintain physical, electronic and procedural safeguards that comply with the appropriate local laws to protect your Personal Data. For example, we take precautions to help keep our information systems secure, including the use of firewalls for our Internet-based systems. We also use encryption technologies, user authentication systems and access control mechanisms.
You have a number of rights in relation to your Personal Data, which are set out in the table below. In particular these rights include the right to object to the processing of your Personal Data where that processing is carried out for our legitimate business interests (as outlined above). Note that in certain circumstances these rights might not be absolute.
|Right of Access||You have the right to request a copy of your Personal Data held (either directly or indirectly) by the Company and to access the information that the Company holds about you (either directly or indirectly), free of any charges. However, if such request is unreasonable or excessive, the Company reserves the right to charge you for making such an access request.|
|Right to Object||You have a right to object at any time to the processing of your Personal Data where the Company processes your Personal Data on the legal basis.|
|Right to Rectification||You have the right to have any inaccurate Personal Data which the Company holds about you updated or corrected.|
|Right to Erasure||In certain circumstances, you may also have your Personal Data deleted, for example if you exercise your right to object (see above) and the Company does not have an overriding reason to process your Personal Data or if the Company no longer requires your Personal Data for the purposes as set out in this Notice.|
|Right to Restriction of Processing||You have the right to ask the Company to restrict processing your Personal Data in certain cases, including if you believe that the Personal Data the Company holds about you is inaccurate or that the Company’s use of your information is unlawful. If you validly exercise this right, the Company will not carry out any other processing activities with respect to your Personal Data unless and until the issue is resolved.|
|Right to Data Portability||You may request the Company to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request the Company to transmit your Personal Data directly to another data controller where this is technically feasible. This right only arises where: (1) the Company processes your Personal Data with your consent or where it is necessary to perform a contract with you; and (2) the processing is carried out by automated means.|
As noted above, you also have the right to withdraw your consent to our use of your Personal Data for direct marketing purposes, at any time.
It is possible that we may seek to charge you a reasonable fee in connection with a request to provide you with a copy of your Personal Data if such requests are deemed excessive or unreasonable (and only to the extent such charge is permissible under local laws and regulations).