Privacy Policy

PRIVACY NOTICE

In Singapore, the data protection provisions of the Personal Data Protection Act 2012 (the “PDPA”) became effective on 2 July 2014. With effect from 1 February 2018, this Privacy Notice (“Notice”) will form part of the terms and conditions (the “Terms and Conditions”) that govern your relationship with Soochow Securities CSSD (Singapore) Pte. Ltd. and its subsidiaries.

1. In this Notice, “Personal Data” refers to any data about an individual who can be identified (a) from the data or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time or data we collect from third party sources. Examples of Personal Data include an individual’s name, NRIC, passport or other identification number, telephone number, address, email address, images, CCTV footage and any other information relating to any individual which you have provided us in any forms you may have submitted to us or via any other form of interaction with you.

2. To the extent applicable SSCS Group collects, uses, discloses and/or processes Personal Data belonging to you, your shareholders, beneficial owners, directors, authorized signatories, traders, managers, employees and representatives (“Relevant Personnel(s)”) for the following purposes in connection with the services provided to you:

i. account opening and operations relating to an account, including closing the account;

ii. providing services and facilities from time to time including for the effective execution of any transactions;

iii. administration and/or managing the relationship between us and you;

iv. carrying out due diligence or other screening activities (including identity, reference and background checks) in accordance with legal or regulatory obligations or our internal risk management procedures (including but not limited to those designed to combat financial crime, fraud, “know-your-customer”, anti-money laundering, counter-terrorist financing or

v. risk management, capital management, financial accounting and management reporting purposes;

vi. handling customer enquiries, requests, feedback or complaints;

vii. facilitating proposed or actual assignment, transfer of any of our rights or obligations in respect of your relationship with us;

viii. meeting or complying with any of our internal policies and procedures and any applicable rules, laws, regulations, codes of practice or guidelines, orders or requests issued by any court, legal, government agencies statutory boards, revenue authorities, supervisory or regulatory bodies (both local and foreign) (including but not limited to audit checks, surveillance and investigation);

ix. legal purposes (including but not limited to enforcing our legal and/or contractual rights, obtaining legal advice and engaging debt collection agencies); and

x. purposes which are reasonably related to the aforesaid.

3. By providing Personal Data relating to your Relevant Personnel(s) to us, you represent and warrant that you have notified each such individual of the purposes for which we require such individual’s personal data and obtained his/her consent for our collection from you and our use and disclosure of his/her personal data for such purposes; or you are duly authorized by each such individual to consent on his/her behalf to our collection, use and disclosure of his/her personal data, and you do so consent on his/her behalf.

4. Personal Data of the Relevant Personnel(s) held by us shall be kept confidential. However, in order to carry out the purposes listed above, where we consider it necessary, we may share such Personal Data with our related corporations and third parties whether in Singapore or elsewhere.

5. As SSCS Group relies on the Personal Data of the Relevant Personnel(s) to provide the services to you, you shall ensure that at all times the information of the Relevant Personnel(s) provided by you to us is correct, accurate and complete. You shall update us in a timely manner of all changes to the information provided to us.

6. If a Relevant Personnel shall at any time wish to withdraw his/her consent, you agree to inform us in writing immediately. SSCS Group may as a result of such withdrawal be unable to continue to provide our services to you. SSCS Group shall inform you of the likely consequences of such withdrawal.

7. SSCS Group may need to maintain records containing personal data for a significant period of time, as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

8. If you wish to withdraw your consent to any use of your Personal Data as set out in this Privacy Notice, or if you have any questions, complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data Records, please contact the Data Protection Officer via email to compliancesg@sscs.sg.

9. This Notice does not derogate from the Terms and Conditions. SSCS Group’s rights under this Notice shall be without prejudice to other rights of collection, use and disclosure available pursuant to the Terms and Conditions or under the law and nothing herein is to be construed as limiting any of these other rights.

10. Our policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us at compliancesg@sscs.sg