Please note that this document is not intended to be legal advice and is provided to you for information purpose only.
Fullerton Fund Management Company Ltd.
This Privacy Notice (the "Notice") sets out how we, Fullerton Fund Management Company Ltd. (“Fullerton”) manage the collection, use and disclosure of personal data, pursuant to the Singapore Personal Data Protection Act (the "PDPA").
For the avoidance of doubt, this Notice supplements but does not supersede nor replace any other consent which you may have previously provided to us. It is in addition to any other rights which we may have at law to collect, use or disclose personal data.
In this Notice, the term “personal data” refers to any data or information, whether true or not, about you from which you can be identified either (a) from that data; or (b) from that data and other information to which Fullerton has or is likely to have access.
Personal data that we may collect from you include but is not limited to:
- full name;
- Government issued unique identifiers such as identification card, passport, tax identification number;
- contact details (including address, telephone number, e-mail address);
- date of birth, place of birth and other information for the verification of identity;
- employment, education, and income details;
- specimen signature(s);
- recordings of our conversations and meetings;
- personal opinions made known to us (such as your responses to surveys);
- browsing history, patterns or other unique information;
- your internet protocol address and information associated with such address; and
- other information relating to you which you have provided to us in any forms you may have submitted to us, or in other forms of interaction with you.
We will take reasonable steps to ensure that your personal data is protected in accordance with the requirements of PDPA and are committed to maintaining the confidentiality and integrity of your personal data.
Collection of Personal Data
Depending on the nature of interaction and the activities performed, we may generally collect your personal data ourselves or through third parties in the following manner :
- Through information provided by you in account opening/transaction forms, agreements entered into with us, when using our products or services;
- When you speak or write to us in relation to our products or services;
- When you interact with our staff, for example, via telephone calls, telephone recordings, electronic mail or face-to-face meetings, online meetings, virtual meeting rooms or social media platforms;
- When you access our website or any online platform/mobile application operated by us;
- When you respond to our job postings;
- When you respond to surveys administered by Fullerton or our third party service providers;
- Through third parties connected with you, such as the organisations that you represent or your financial advisers, subject to your prior consent;
- Information and data collected such as images, photographs, CCTV footage, voice or video recordings collected when you are within our premises or when you participate in events organised by Fullerton, such as functions, seminars or contests; and/or
- When you submit your personal data to us for any other reason.
Purposes for use and disclosure of personal data collected
We shall ensure that the use of personal data is restricted to the purposes for which it had been collected. Depending on the nature of your relationship with us, the purposes will vary in connection with the products and/or services which you have applied for.
Examples of purposes include but is not limited to the following;
- to process your transactions in relation to your investment(s) in any of our products or services;
- to contact you and to send statement/notices to you relating to your account and holdings therein or to provide you with updates on changes to our products or services;
- to carry out your instructions or respond to any enquiry from you;
- to deal with any other matters relating to your account and holdings therein;
- to form part of your records as to the business relationship that you have with us;
- to observe any legal, government or regulatory requirements of Singapore or other relevant jurisdiction including any disclosure or notification requirements to which any recipient of the data is subject;
- to satisfy Fullerton’s responsibilities relating to 'Know Your Customer' (KYC) requirements;
- to obtain feedback or conduct market research, surveys and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
- taking photographs and/or video or voice recordings of you for (i) internal dissemination within Fullerton; (ii) sharing with event sponsors and other business partners; and (iii) generating publicity materials for our events; and
- other purposes, directly or indirectly relating to any of the above and Fullerton’s activities. (hereinafter collectively referred to as the “Purposes”).
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 various parties, to the extent that it is necessary for any of the above Purposes or any other purpose related to any of the above Purposes. Further, your personal data may be transferred to locations outside Singapore and will be protected in accordance with the local practices and laws, rules and regulations (including any governmental acts and orders) in such countries which may not necessarily provide an equivalent or adequate level of protection for personal data as Singapore.
Your personal data may be disclosed to the following parties, including but not limited to:
- Fullerton’s directors, officers, employees, representatives, agents or delegates;
- Fullerton’s related or associated companies;
- Any relevant regulatory authorities, government bodies or law enforcement agencies;
- Companies and/or organisations that act as our agents and/or professional advisors;
- Service providers who are involved in the management and administration of your investments (including but not limited to trustees, custodians, fund administrators and transfer agents);
- Distributors of Fullerton’s products and services;
- Event sponsors and third-party service providers of events organised by Fullerton;
- Any entity which takes over all or part of our rights or obligations under any agreement we have with you; and
- Any other parties to whom you have expressly or impliedly made consent for us to disclose your personal data to,
subject at all time to any laws (including regulations, guidelines and/or obligations) applicable to Fullerton.
Retention of personal data
We will retain your personal data for the duration of your relationship with us and for such period as may be necessary for any legal or business purposes.
Access and correcting personal data provided
Subject to exceptions under the PDPA, you may request for access to your personal data that is in our possession. We reserve the right to charge a reasonable fee for the processing of any data access request.
You are responsible for ensuring that the information you provide is accurate, complete, and not misleading and that such information is kept up to date. Should the personal information that is held by us be inaccurate, incomplete or outdated, you may request for us to correct the data that has been provided.
Fullerton reserves its rights to refuse to comply with your request for access or correction to your personal data under PDPA and if Fullerton refuses to comply with such request, you will be informed of such refusal and the reason for the same.
When you interact with us and submit information to us, whether via responding to job postings or the use or purchase of products and services offered by us or by visiting our website or otherwise, you are deemed to have agreed and consented to our collection, use and disclosure of personal data as set out in this Notice. This consent shall be effective until we receive a written communication from you on the withdrawal of your consent.
Please refer to our separate Cookie notice.
If you have any questions or feedback relating to your personal data or this Notice or you would like to withdraw your consent to any use of your personal data or would like to obtain access and make corrections to your personal data records, you may reach us at:
- Call +65 6808 4688; or
- Email DPO@fullerton.com.sg
This Notice may be subject to changes from time to time and may be updated without prior notice. Please check back regularly for any updated information to ensure you are aware of how your personal data is being handled. If you continue to use our products and services, maintain any account with us, access our website and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such change without reservation.
This Notice shall be governed by, and construed in accordance with, the laws of Singapore. Any dispute arising out of or in connection with this Notice shall be referred to and finally resolved by the Courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Singapore.
Last Updated January 2022