COLLECTION OF PERSONAL DATA
Personal data that Nikko Asset Management Asia Limited (“NAM Asia”) may collect include:
- email address;
- country of residence;
- investment profile and information regarding your investments; and
- any other relevant information in order for NAM Asia and/or its related corporations to provide products and/or services to you and to share information that may be of interest with you.
NAM Asia may also collect personal data through various forms of technology such as cookies. For more information on how your personal data is collected through cookies, please visit https://www.nikkoam.sg/global-cookie-policy.
PURPOSES OF COLLECTION, USE OR DISCLOSURE OF PERSONAL DATA
NAM Asia may collect, use, process and/or disclose your personal data for one or more of the following purposes:
- updating and maintaining the register(s) of the relevant scheme(s) that you have subscribed to;
- processing instructions from you or persons acting on your behalf or processing your trades or those of persons acting on your behalf;
- complying with any applicable rules, laws or regulations, regulatory policies, guidelines or industry codes, orders, directions or requests issued by any court, legal or regulatory bodies (whether in Singapore or otherwise) including rules and regulations relating to anti-money laundering and countering the financing of terrorism and the carrying out of audit checks, surveillance and investigation;
- preventing, detecting and investigating crime, offence or unlawful activity including but not limited to fraud, money-laundering, terrorist financing and bribery, and analysing and managing commercial risks;
- complying with any applicable treaty or agreement with or between Singapore and a foreign jurisdiction;
- fulfilling a judgment or order of court or of any other tribunal within Singapore and in an applicable foreign jurisdiction;
- providing client-related services, including providing customer support, responding to queries or feedback given by you or persons acting on your behalf, and generating, communicating with and disseminating notices, reports, correspondence, statements, invoices, confirmations and advices to you or persons acting on your behalf;
- verifying your identity or the identity of persons acting on your behalf;
- reviewing and approving your account(s), and the conduct of initial and anticipatory credit checks and assessments, relevant checks, ongoing assessment and verification of ongoing credit worthiness and standing;
- legal claims, actions or proceedings including but not limited to drafting and reviewing documents, obtaining legal advice and facilitating dispute resolution or exercising or enforcing the rights of NAM Asia and/or its related corporations under contract or pursuant to applicable laws and regulations;
- administering, operating, processing or managing units, any scheme or the umbrella structure of any sub-fund;
- meeting or complying with NAM Asia’s and/or its related corporations’ internal policies and procedures;
- handling feedback, queries or complaints;
- maintaining the security of premises including but not limited to the use of forms of surveillance such as security cameras;
- facilitating any proposed or actual business assignment, transfer, participation or sub-participation in any of NAM Asia’s and/or its related corporations’ rights or obligations in respect of your relationship with such entit(ies);
- for marketing activities such as providing you with, email alerts, event registrations, social media activity, and other notices concerning NAM Asia’s and/or its related corporations’ products or services, or events or news that may be of interest to you, including through targeted messages and advertisements on or through our websites and apps and through third-party websites and apps;
- improving our website and present its contents to you in a tailored and personalised manner;
- for market analysis and product development;
- all purposes reasonably related to one or more of the foregoing; and
- conducting general administration in relation to the foregoing;
Where you provide personal data relating to third party individuals to NAM Asia (e.g. where you are an institutional investor), you warrant that the prior consent of such third party individual, which will allow NAM Asia to collect, use and disclose that personal data in the manner and for the purposes described above, has been obtained, and you consent to and acknowledge all such collection, use and disclosure on behalf of that third party individual. You shall, upon request from NAM Asia, promptly provide a copy of the document(s) containing or evidencing such prior consent obtained from such third party individual.
THIRD PARTIES WHO MAY BE PROVIDED WITH PERSONAL DATA
You consent and acknowledge that personal data may be disclosed and transferred to the following parties, in Singapore or in a foreign jurisdiction, for the purposes set out under the section “Purposes of Collection, Use or Disclosure of Personal Data”:
- any related corporations of NAM Asia;
- any person or entity including government authorities, regulatory bodies, courts and tribunals to whom NAM Asia and/or its related corporations are under an obligation to make disclosure pursuant to any domestic or foreign legal process, legal obligation or regulatory obligation; and
- any agent, contractor or third party service provider who provides administrative, mailing, data processing, business process, human resource, information technology or other services to NAM Asia and/or its related corporations in connection with the operation of the business of NAM Asia and/or its related corporations or the administration and operation of any scheme and/or the umbrella structure of any sub-fund.
You may, after consenting to the collection, use and disclosure of your personal data, withdraw your consent by giving notice in writing to NAM Asia’s Data Protection Officer at the contact details set out below (under the section “Data Protection Officer Details”). You should note that a notice of withdrawal of consent submitted by you, or by any third party individuals whose personal data you have provided to NAM Asia (e.g. your beneficial owners, directors or authorised signatories, if you are not an individual), may, among other things: (i) deemed to be a request for redemption of all units held by you; and/or (ii) result in you no longer being a part of our mailing list.
ACCURACY OF PERSONAL DATA
You undertake to ensure that all information provided to NAM Asia is true, accurate and complete and that changes to any such information shall be notified to NAM Asia in a timely manner.
DATA PROTECTION OFFICER DETAILS
If you have any queries or comments on the use of your personal data, or if you wish to lodge a privacy-related complaint, please contact NAM Asia’s Data Protection Officer at:
Data Protection Officer
Email address: firstname.lastname@example.org
NAM Asia will investigate your queries, comments or complaint, and will use reasonable endeavours to respond, in accordance with applicable laws.