The purpose of this Personal Data Protection Statement ("this Statement") is to inform you of how we, Lion Global Investors Limited, (where “we”, “us”, “our”, “our company” shall refer collectively to Lion Global Investors Limited and its officers, employees, representatives and agents) manage personal data, which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (the "Act"). Please take a moment to read this Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data (as the term is defined in the Act and reflected herein).
By interacting with us, submitting information to us, responding to any of our job postings or signing up for any products or services offered by us, and by our responding to you and providing you with any of our products or services, you agree and consent to us, collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our service providers and relevant third parties in the manner set forth in this Statement. Such consent shall continue to subsist until we receive written communication from you of the withdrawal of your consent.
This Statement supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
We may from time to time update this Statement to ensure that it is consistent with future developments in our business, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, by using or continuing to use our services and our continuing the provision of such services to you and/or our response to your applications or inquiries, you agree to be bound by the prevailing terms of this Statement as updated from time to time on our website: www.lionglobalinvestors.com. Please check back regularly for any updated information relating to the handling of your Personal Data.
1. Personal Data
In this Statement, "Personal Data" refers to any data, whether true or not, about an individual (being a natural personal) who can be identified (a) from that data; or (b) from that data and other information to which an entity has or is likely to have access. Examples of such Personal Data includes (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, bank account information and any other information relating to yourself or any individuals which you have provided us or authorised to be provided to us, in any forms you may have submitted to us, or via other forms of your interaction with us.
2. Collection of Personal Data
2.1 Generally, we collect your Personal Data in the following ways
a. when you submit any forms or write to us in relation to any of our products or services or job postings;
b. when you interact with any member of our staff, e.g., via telephone calls, telephone recordings, telephone voice or text messages, letters, facsimile transmissions, face-to-face meetings or emails;
c. when you use some of our services, e.g., websites;
d. through CCTV recordings within our office premises;
e. when we receive references from business partners and third parties, e.g., where you have been referred by them;
f. when we seek information from third parties about you for the fulfilment of “Know Your Client” (KYC) obligations to conduct requisite investigations, inquiries and checks for the purpose of preventing money laundering or terrorist financing activities or assessing your suitability for a job in our company that you
have applied for; and
g. when you submit your Personal Data to us for any other reasons.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.
2.3 If you provide us with any Personal Data relating to a third party (e.g., information of your spouse, children, parents, past –employers, referees, present or past colleagues), by submitting such information to us for any purpose, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for such purpose and other purposes which are reasonably related to the aforesaid.
3. Purposes for the Collection, Use and Disclosure of your Personal Data
3.1 We collect, use and disclose your Personal Data for the following purposes:
3.1.1 In connection to the provision of our products and services to you:
a. the opening, operation, administration or continuation of accounts with us and/or any service providers;
b. responding to your queries, requests and complaints, if any;
c. managing our administrative and business operations and complying with internal policies and procedures;
d. processing any corporate actions which affect your investments (which may arise in connection to any merger, acquisition or asset sale);
e. providing confirmation of any Personal Data held which relates to you for any of the purposes listed herein;
f. sending you updates and information in relation to our management of your investments, our services, products, newsletters and related investment and market information, reports or commentaries;
g. any purpose that is reasonable and incidental to our provision of our products or services to you;
h. carrying out due diligence, monitoring or other screening activities in accordance with our legal or regulatory obligations or risk management procedures;
i. implementing processes with a view to preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing commercial risks; and
j. compliance with any applicable rules, laws and regulations, industry codes of practice or guidelines and any directives or best practices issued or administered by any regulatory authorities or relevant trade bodies or to assist in law enforcement and investigations by relevant authorities.
3.1.2 In the case where you submit an application to us as a candidate for employment:
a. processing your application including the conducting of pre-recruitment checks, such as in relation to your credit standing and qualifications;
b. providing or obtaining references and for background screening/vetting from your referees, past employers, present or past colleagues and the staff of past academic institutions
c. collecting information to assess your suitability for the position applied for;
d. communicating with you as is required to comply with our policies and processes, including for business continuity purposes;
e. maintaining our records where you have not been successful in your job application to us, to inform you should a suitable position which might be of interest to you be open in the future; or where you are subsequently employed by us and thereafter leave our employment, to provide you a reference, when so requested by your future prospective employer; and
f. any other purposes relating to the aforesaid.
3.2 In relation to your interactions with us, we may also specifically notify you of other purposes for which we collect, use or disclose your Personal Data.
4. Persons to whom disclosure of Personal Data may be made
4.1 We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, to the following, to the extent that it is necessary or expedient for the provision of our services or products to you (including in relation to our internal operational requirements), the management and administration of your investments, any of our transactions and dealings with you or to comply with any laws, rules, regulations or the directives, industry codes of practice or best practices issued or administered by any regulatory authorities or relevant trade bodies:
a. Lion Global Investors’ related corporations;
b. agents, contractors or third party service providers (collectively “the Service Providers”) to us or in relation to any of our investment products which you have invested in (including but not limited to trustees, custodians, fund administrators and transfer agents);
c. our professional advisers such as our auditors and lawyers;
d. relevant government regulators, authorities or law enforcement agencies (including but not limited to the Monetary Authority of Singapore, the Central Provident Fund Board, Inland Revenue Authority, Ministry of Manpower);
e. in the case of where you have applied to us for employment, your referees, past employers, present or past colleagues, staff of past academic institutions and your future prospective employer on their request for a reference; and
f. any other party to whom you have expressly or impliedly authorised us to disclose your personal data to, including any service provider appointed or nominated by you and with whom we or the Service Providers have to interact in the course of providing our services and products to or in any of our transactions and dealings with you.
5.1 When you interact with us on our website, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
5.2 Cookies are small text files placed in the 'Cookies' folder on your computer's hard disk and allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
5.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may then not be able to enter certain part(s) of our website.
6. Data Security
6.1 We will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that, for example, no harmful code will enter our website (e.g., viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the Internet.
7.1 If you receive spam messages and want to report them to us, please email us by forwarding the message(s) you have received to:firstname.lastname@example.org.
8. Third-Party Sites
9. Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
9.1 If you:
a. have any questions or feedback relating to your Personal Data or this Statement;
b. would like to withdraw your consent to any use of your Personal Data as set out in this Statement; or
c. would like to obtain access and make corrections to your Personal Data records, please contact us as follows:
Call: +65 6417 6800
Data Protection Officer
Lion Global Investors Limited
65 Chulia Street #18-01
9.2 Please note that if your Personal Data has been provided to us by a third party (e.g., a client who has nominated you as beneficiary of a fund purchased), you should contact that individual to make such queries, complaints, and access and correction requests to us on your behalf.
9.3 If you withdraw your consent to any or all collection, use or disclosure of your Personal Data, depending on the extent of such withdrawal, we may not be in a position to continue to provide our products and/or services to you, to administer any contractual relationship we have in place with you or we may not be able to do so to an efficient or satisfactory level. We shall not be responsible for any direct or indirect damage or loss suffered or any liability, cost or expense incurred by you or on your account arising from or in connection with such withdrawal.