The Personal Data Protection Act
The Personal Data Protection Act (“PDPA”) establishes a data protection law that governs the collection, use, disclosure and care of personal data, consisting of the DP Obligations. The PDPA also provides for the establishment of a national Do Not Call (DNC) Registry and alongside the DNC Obligations.
The DNC Obligations and DP Obligations came into force on 2 January 2014 and 2 July 2014 respectively.
You may like to refer to the below useful links for more information;
PDPC website
DNC Registry website
GEM views data protection seriously and has taken measures to protect your personal data. When you apply for services from GEM, update us of your new particulars or attend our events and seminars, GEM may need to collect your personal data. You may be required to complete a relevant application, update or consent form which contains a section on Personal Data Consent (“Form”). This Personal Data Notice and Policy (“Policy”) contains the details of how GEM will process, collect, use and disclose your personal data. You should read this Policy carefully before providing any consent to GEM to process, collect, use and disclose your personal data.
Purposes for Processing, Collection, Use and Disclosure of Personal Data
Purposes
To process, administer and/or manage your services with GEM, GEM will necessarily need to process, collect, use and/or disclose your personal data or personal information about you. Such personal data includes information set out in any Forms and any other personal information provided by you from time to time or possessed by GEM for the following purposes:
- administering, servicing, or dealing with the services provided by GEM (including processing your applications for any financial products);
- managing the financial products that you have purchased pursuant to the services provided by GEM;
- processing or carrying out your instructions or responding to any enquiry purporting to be given by you or on your behalf and dealing in any matters relating to the services which you are entitled to receive (including sending you information on and invitations to seminars and events organised by GEM, the mailing of correspondence or any other relevant document(s), to you, which could involve disclosure to certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages);
- Interacting with you, e.g. via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
- forming part of GEM’s records as to the business carried on by GEM;
- observing any legal, governmental or regulatory requirements of any relevant jurisdiction (including any disclosure or notification requirements to which GEM is subject to);
- complying with GEM and GEM’s related companies’ policies and procedures (including without limitation any reporting and disclosure policies and procedures);
- carrying out due diligence, monitoring or other screening activities in accordance with GEM’s legal or regulatory obligations or risk management procedures;
- carrying out, processing and analysis of satisfaction surveys regarding GEM’s services. And
- If consented by you, providing you with marketing/ promotional information on new and/or other financial products and services which in the opinion of GEM may be of interest or benefit to you, by way of telephone calls, SMS/MMS and facsimile to you to any telephone number provided by you to GEM from time to time.
(collectively, the “Purposes“)
GEM may also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter, using, disclosing and/or processing such personal data for one or more of the above Purposes.
Disclosure
The personal data provided by you to GEM may be disclosed by GEM to the following parties (whether such parties are located or resident within or outside Singapore) for one or more of the above Purposes:
- financial institutions who may have a need for such personal data in order to provide the financial products that you have purchased pursuant to the services provided by GEM (including without limitation any brokers and lawyers);
- employees, officers, directors and agents of GEM;
- GEM’s related companies (to comply with GEM and GEM’s related companies’ policies and procedures);
- GEM’s lawyers and auditors;
- any third party vendors employed or engaged to provide administrative, computer or other services or facilities to GEM; and
- any regulatory authority, government, dispute resolution or statutory body in Singapore and/ or other jurisdiction/s.
(collectively the “Permitted Parties“).
Any such disclosure and transfer of personal data shall not be treated as a breach of any restriction upon the disclosure of personal data imposed on GEM by law or otherwise.
Consent
By providing your consent to GEM by signing on a Form, you hereby:
- Consent to GEM processing, collecting, using and/or disclosing your personal data for the Purposes as described above;
- Consent to GEM collecting personal data about you from sources other than yourself and processing, using and/or disclosing such personal data, for the Purposes as described above; and
- Consent to GEM disclosing your personal data to the Permitted Parties, for the Purposes as described above.
By providing your personal data on the online form, you hereby consent GEMto collect and use the personal data to contact you, by way of telephone calls, SMS/MMS and emails for the purpose of attending to your enquiries. Please ensure that you are the user and/or subscriber of the telephone number(s) and/or email address(es) provided by you to GEM.
This publication is for general circulation only. It does not form part of any offer or recommendation, or have any regard to the investment objective, financial situation or needs of any specific person. You may wish to see advice from a financial adviser representative before making a commitment to purchase these products. In the event that you choose not to seek advice from a financial adviser representative, you should consider carefully whether the products are suitable for you. This advertisement has not been reviewed by the Monetary Authority of Singapore.
Request for access and/ or correction of Personal Data
You may request to access and/or correct the personal data currently in our possession by contacting us at jacqueline-chow@pfp-fa.com.
- For a request to access personal data, we will provide you with the relevant personal data 30 calendar days from such a request being made.
- For a request to correct personal data, we will :
2.1 correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
2.2 subject to paragraph [3], we will send the corrected personal data to every other organisation to which the personal data was disclosed by GEM within a year before the date the correction was made unless that other organisation does not need the corrected personal data for any legal or business purpose. - Notwithstanding paragraph [2.2], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
- We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data.
GEM may amend this Personal Data Notice and Consent Policy from time to time by posting an amended version of this Personal Data Notice and Consent Policy on our website, and you agree to be bound by such amended Personal Data Notice and Consent Policy.
If you have any queries as to this Personal Data Notice and Consent Policy or how GEM processes, collects, uses and discloses your personal data, please contact the Data Protection Officer at jacqueline-chow@pfp-fa.com.
Request to withdraw consent
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us at jacqueline-chow@pfp-fa.com.
If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent, and will thereafter cease to use and/or disclose your personal data for marketing purposes within 30 calendar days of your request.