1. As used in this Notice:

 

“Personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

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1. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:

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• your contact details like your name, passport or other identification numbers, contact numbers, address, email

• your personal details enabling us to evaluate and manage your client, employment or business relationship with us, e.g. your work experience, education, date of birth, bank details

• your personal details enabling us to analyse your situation, determine suitable strategies and execute respective action, e.g. family status, financial information, transaction history, risk profile, investment objectives, tax information

• photos and videos of you from our events or office surveillances; and

• information about your use of our services and website, including cookies and IP address.

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COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

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3. We use the personal data above for different purposes relating to the management of our business and our relationship with you. These purposes include, but are not limited to the following:

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• Establishing, maintaining and managing a business relationship with you so that we may provide you with services or products that you have requested

• Enabling us to comply with your requests such as preferred method of communication

• Enabling us to review the services that we provide to you so that we may understand your requirements for our services and improve on them

• Evaluating your performance as our employee or business partner

• Analyzing your financial situation and determining financial strategies and products suitable for you as our client

• Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/ or regulatory authority

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If we wish to collect, use, retain and/or disclose your personal data for any other purposes other than those mentioned above, we will adequately seek your consent.

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4. Generally, we shall protect and keep your personal data confidential. We will disclose your personal data only with your consent and for purposes that you have been informed about.  

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However, subject to applicable laws, we may disclose your personal data for the purposes set out above to parties (non-exhaustive) such as those described below:

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• banks, financial institutions, credit card companies and their respective service providers;

• companies providing services relating to insurance to us, and associations of insurance companies;

• our professional advisers such as our auditors and lawyers; and

• regulators and authorities.

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WITHDRAWING YOUR CONSENT

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1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 5 above.

4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

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WITHDRAWING YOUR CONSENT

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1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

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PROTECTION OF PERSONAL DATA

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1. We have introduced appropriate administrative, physical and technical measures to safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

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ACCURACY OF PERSONAL DATA

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1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

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RETENTION OF PERSONAL DATA

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1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

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TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

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1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

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DATA PROTECTION OFFICER

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1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

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Contact No.: 6540 9398

Email Address: brc@lbridgecap.com

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EFFECT OF POLICY AND CHANGES TO NOTICE

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1. This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

2. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

3. This Policy is effective from 01 March 2020.