Personal Data Protection Policy

Last Updated: 4 August 2021

The Straits Trading Company Limited, its subsidiaries, related companies and affiliates (collectively referred to as "Straits Trading", "we", "us" or "our" as the context may require) recognise the importance of your privacy and Personal Data. We outline in this privacy policy how we collect, use, process and/or disclose your Personal Data in accordance with the Personal Data Protection Act 2012 (the "Act").

This privacy policy supplements but does not replace any other consents you may have previously provided to Straits Trading.

    1. "Personal Data" refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which Straits Trading has or is likely to have access. Depending on the nature and purpose of your interaction with us, examples of Personal Data which you may provide to us could include but are not limited to:
      1. general personal information such as your name, nationality, identification number, passport number, date of birth, registered address, gender, marital status and personal interests;
      2. contact information such as your phone number, mailing address and e-mail address;
      3. financial information such as bank details, accredited investor information, proof of ownership of shares in Straits Trading, and name and contact details of private bank relationship manager;
      4. current employment information, employment history and education background;
      5. photographs, video recordings or recordings on other mediums in which your likeness may appear; and
      6. technical data such as your IP address and information about your usage of Straits Trading's website and service.
    1. Generally, Straits Trading collects Personal Data from you in the following ways:
      1. when you subscribe to our email alerts or mailing lists on our website;
      2. when you make general enquiries via email;
      3. when you submit requests or enquiries to us regarding shareholder-related matters such as annual general meetings or annual reports;
      4. when you submit an application for membership of the Shareholders’ Club via the website or submission of a physical application form;
      5. when a Shareholders' Club member updates or amends his or her user profile settings, or registers his or her interest in investment products, or provides information to assess his or her eligibility for certain investment products, on the Shareholders’ Club website;
      6. when you submit career enquiries to us;
      7. when you submit a job application to us via our website or LinkedIn page, or through a third-party recruitment agency; and
      8. when you attend events or webinars organised or conducted by us where photographs, video recordings or other recordings in other mediums in which your likeness may appear are taken.
    2. We may also collect Personal Data, including but not limited to your name, contact information and other identification information, from other sources where needed and in compliance with the applicable laws. These sources include:
      1. our Share Registrar vendor; and
      2. recruitment agencies.
    1. Generally, the Personal Data which we collect from you may be used, disclosed and/or processed for the following purposes:
      1. verifying your identity and age (if necessary);
      2. providing or administering any products, services or information that have been requested by you;
      3. verifying or enabling our partners to verify your eligibility for particular investment products, promotions or rewards;
      4. managing and responding to your requests, feedback and/or enquiries;
      5. marketing our products, services, events or promotions;
      6. conducting internal and external audits, reviews and/or investigations within Straits Trading;
      7. complying with internal policies and procedures and managing the administrative and business operations of Straits Trading;
      8. carrying out due diligence or other screening activities in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by Straits Trading;
      9. investigating, detecting and preventing fraud, misconduct, any unlawful action or omission and/or improper or criminal activities;
      10. conducting research and statistical analysis;
      11. managing the safety and security of our premises (including but not limited to carrying out CCTV surveillance and conducting security clearances);
      12. processing job applications;
      13. complying with any applicable rules, law, regulations, codes of practice or guidelines;
      14. any other purposes reasonably related to the above; and
      15. any other purposes which we notify you of at the time of obtaining your consent to the collection of your Personal Data.
    2. For any other purpose(s) not set out here, we will notify you of such other purpose(s) and seek your consent in accordance with the requirements of the Act, including but not limited to at the time of collecting your Personal Data, unless processing of your Personal Data without your express consent is permitted by the Act or by law.
    1. Subject to the provisions of the Act and any other applicable law, and in order to carry out the purposes set out in Section 3 above, we may disclose your Personal Data to the following parties:
      1. our related corporations and affiliates;
      2. partners and vendors engaged by us to perform the functions set out in Section 3 above;
      3. partners and vendors engaged by us to provide or enable us to provide you with goods and services or other promotions and rewards;
      4. our service providers including our website host master, cloud storage provider, our Share Registrar vendor (for shareholder-related matters), data analytics service provider and marketing partners;
      5. banks or other financial institutions, to verify your eligibility for particular investment products or facilitate any transactions;
      6. our external company secretary;
      7. our auditors and other professional advisors (e.g. lawyers);
      8. government agencies, authorities and regulators, if required under any applicable laws, regulations, rules, codes of practice or guidelines;
      9. any actual or prospective business partner, investor, seller or buyer, to the extent that a disclosure of your Personal Data is needed to facilitate a business or asset transaction (including any merger, acquisition or asset sale); and
      10. any other third party whom you authorise us to disclose your Personal Data to.
    1. You may request a copy of your Personal Data and ask us about the ways in which your Personal Data has been or may have been used or disclosed by us within the year preceding the date of your request ("Access Request").
    2. To the extent permitted by law, we reserve the right to charge a reasonable administrative fee for processing your Access Request. We will inform you of any such fee prior to processing the Access Request.
    3. You may request us to correct an error or omission in your Personal Data ("Correction Request").
    4. You may submit your Access Request or Correction Request in writing via email at the contact details provided in paragraph 13 below.
    5. There may be exceptional circumstances where we may refuse your Access Request or Correction Request. We will generally inform you of the reasons for the refusal, except where we are not required to do so under the Act.
    6. We will respond to your Access Request or Correction Request as soon as possible. If we are not able to respond to your Access Request or Correction Request within 30 days after receiving it, we will inform you of the time by which we will respond to your Access Request.
    1. You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by submitting your request ("Withdrawal Request") in writing via email at the contact details provided in paragraph 13 below.
    2. We will process your Withdrawal Request, and inform you of the likely consequences of your Withdrawal Request, within a reasonable time.
    3. If you withdraw your consent to the collection, use or disclosure of your Personal Data for any purpose, we will cease (and cause our data intermediaries and agents to cease) such collection, use or disclosure of your Personal Data, as the case may be. However, your withdrawal of consent could result in us being unable to continue providing certain services or products to you, and may also result in you being in breach of your contractual obligations, in which event our rights are reserved.
    4. In certain situations, we may continue with the collection, use or disclosure of your Personal Data notwithstanding a Withdrawal Request, where so required or authorised under the Act or other written law.
    1. We need your assistance to ensure that your Personal Data is accurate and complete, particularly where your Personal Data is likely to be used by us to make a decision that affects you or to be disclosed by us to another organisation.
    2. In order to ensure that your Personal Data is accurate and complete, please update us of any changes in your Personal Data by informing us in writing via email at the contact details provided in paragraph 13 below.
    3. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
    1. We will put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. However, we cannot guarantee the security of your Personal Data, particularly where information is transmitted via the internet, and any such transmission is at your own risk.
    1. We may retain your Personal Data for such period as is necessary to fulfil the purpose for which it was collected or for the purposes set out here, or as required or permitted by applicable laws.
    2. We will cease to retain, or will anonymise, your Personal Data as soon as the retention of your Personal Data no longer serves the purpose for which it was collected or is no longer necessary for any other legal or business purposes.
    1. Our website uses cookies, which are pixel that load when our website is loaded in your browser. The use of cookies enables us to improve our website and provide you with a better online experience.
    2. The cookies will record user actions such clicks, gestures, screen time, and scrolling behaviour, and may collect data such as IP addresses, the type and model of your browser and the model of your device. Where any data collected qualifies as Personal Data, the terms of this privacy policy will apply.
    3. Should you wish to disable the cookies on our website, you may use a cookie blocker or change your browser settings. However, you may not be able to access certain parts of our website if you do so.
    1. We may from time to time provide you with links to other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please ensure you carefully read and review the privacy policies of these websites before you submit any Personal Data to these websites.
    1. We reserve the right to amend the terms of this privacy policy from time to time, without prior notice except by publication on our website, to ensure that it is consistent with our future developments and/or any changes in the law. You agree to be bound by the prevailing terms of the privacy policy as updated from time to time.
    2. We encourage you to check back regularly for any updates to the privacy policy.
    1. If you have any queries or comments regarding this privacy policy or your Personal Data, or if you would like to make any requests under this privacy policy, please contact our Data Protection Officer in writing at:

      The Straits Trading Company Limited:
      Data Protection Officer
      1 Wallich Street
      #15-01 Guoco Tower
      Singapore 078881
    2. When writing to us, please reference "Straits Trading Privacy Policy" in the subject header.
    1. This privacy policy shall be governed in all respects by the laws of Singapore.