PRIVACY POLICY

CW ASSET MANAGEMENT PTE. LTD.. (“CWAMSG”, “we” or “us”) takes the privacy of your information seriously. This Privacy Policy governs our collection, processing and usage of personal data of individuals in compliance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”). By using this website, you consent to the data practices described in this statement.

You agree and consent to CWAMSG and affiliates as well as our authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your personal data in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data.

For the avoidance of doubt, this Privacy Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

If you are a resident of the European Union (“EU”), please see the below Appendix A for additional information regarding our use of your personal data.

Use of Cookies

This website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. Cookies on this website may be used to ensure a smooth user experience, perform analytics, and for showing relevant advertisements. Please note that third parties (such as analytics software) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. This website uses Google Analytics. Please refer to www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.

Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of our website or to fully experience the interactive features of the CWAMSG services or websites you visit.

Personal Data

In this Privacy Policy, the term “personal data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which CWAMSG has or is likely to have access.

Personal data that we collect from you includes but is not limited to:

full name;

NRIC, passport or other identification number;
contact details (including address, telephone number, e-mail address);
employment, education, and income details; 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.

Purposes for the Collection, Use and Disclosure of Personal Data

Pangaea collects, uses and/or discloses your personal data, including any additional information you may subsequently provide, for the following purposes (hereinafter collectively referred to as the “Purposes”):

processing of your application to open an account with us;
to contact you and to send statements/notices to you relating to your account and holdings therein;
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 the records of the recipient as to the business carried out by it;
communicating with you to inform you of changes and updates to our policies, terms and conditions and other administrative information;
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 our responsibility relating to 'Know Your Customer' (KYC) requirements; and
other purposes, directly or indirectly relating to any of the above and our activities

Where you have specifically provided us with consents, we may also collect, use and/or disclose for the following purposes: (i) sending you marketing updates on our services and products; (ii) promoting and administering events, contests and competitions; and (iii) developing marketing programmes.

Non-disclosure

CWAMSG does not sell, rent, lease, or release your personal data to third parties. CWAMSG may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personal data is not transferred to the third party without your explicit consent. In addition, CWAMSG may share personal data with trusted partners to help us perform statistical analysis, send you email or provide customer support. All such third parties are prohibited from using your personal data except to provide these services to CWAMSG, and they are required to maintain the confidentiality of your personal data.

Disclosure of Personal Data

Your personal data may be disclosed to our related or associated companies, affiliates, delegates, trustee(s), business partners, and/or service providers, or any third party and/or agents (including outsourcing agents and data processors), any and all governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, any court and/or officer of the court for any of the above Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes.

We may also disclose your personal data to third parties: (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and (b) if CWAMSG or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets.

Withdrawal of Consent

If you wish to withdraw your consent to any use or disclosure of your personal data as set out in this Privacy Policy, you may contact the Personal Data Protection Officer by sending an email to: info@cwamsg.com.

Please note that if you withdraw your consent to any or all use or disclosure of your personal data (other than for purposes of direct marketing), we may not be able to process your personal data for all of the Purposes.

Access and correction of your personal data

You are responsible for ensuring that the personal data you provide is accurate, complete, and not misleading and that such personal data is kept up to date.

You may access and request for correction of your personal data by contacting the Personal Data Protection Officer, at our office with any enquiries in respect of your personal data via email at: info@cwamsg.com. We reserve the right to refuse to comply with your request for access or correction to your personal data under the PDPA and if we refuse to comply with such request, you will be informed of such refusal and the reason for the same.

Links to Other Websites

Our website may contain links to other websites. This Privacy Policy only applies to this website so when you link to other websites you should read their own privacy policies.

Changes to This Statement

CWAMSG will occasionally update this Privacy Policy to be consistent with our business purposes and/or to reflect changes in legal or regulatory requirements. CWAMSG encourages you to periodically review this Privacy Policy to be informed of how CWAMSG is protecting your personal data.

Appendix A: Additional Provisions Applicable to Processing of Personal Data of EU residents

These provisions apply to you if you are a resident of the EU and they are pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data (commonly referred to as the “General Data Protection Regulation” (“GDPR”).

1. Rights of Individuals

Access, Correction and Erasure Requests

You have the right to:

ask us to confirm whether we are processing your personal data
receive information on how your personal data is being processed
obtain a copy of your personal data
request that we update or correct your personal data
request that we delete personal data in certain circumstances

Right to Object to Processing

You have the right to request us to cease processing your personal data:

for marketing activities, including profiling
for statistical purposes
where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal data to establish, exercise or defend a legal claim.

Right to Restrict Processing

You have the right to request that we limit the processing of your personal data:

while we are evaluating or in the process of responding to a request by you to update or correct your personal data
where such processing is unlawful but you do not want us to delete your personal data and would like us simply to store your personal data instead
where we no longer require such data, but you want us to retain the personal data to establish, exercise or defend a legal claim
where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request

Data Portability Requests

You have the right to request that we provide you or a third party that you designate with certain of your personal data in a commonly used, machine-readable format. Please note that data portability rights only apply to personal data that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.

We will only release personal data to your designated third party where it is technically feasible and you agree that we are not responsible for the security of such personal data or its processing once released to such third party.

Submitting Requests

You may submit your requests as provided for under Clause 9 (Customer Service and Enquiries) of the main Privacy Policy. We will endeavor to respond to all such requests within one month of receiving your request but may require up to two months to respond where there are extenuating circumstances. Please note, however, that certain personal data may be exempt from such rights pursuant to applicable local laws. We will verify your identity before responding to your request and may also charge you a reasonable fee for copies of personal data that you request.

Right to Withdraw Consent

You may withdraw your consent to (i) any processing that we conduct solely based on your consent (such as sending direct marketing materials to your personal email account); or (ii) marketing activities by following the instructions on any marketing emails or contacting us in the manner provided for in the main Privacy Policy.

2. Segmentation (also known as profiling) and Automated Decision Making

We may from time to time use personal data to segment our visitors and customers based on share characteristics such as geography, behavior or demographics. With your consent, we make from time to time make automated decisions based on such segmentation or your specific personal data to offer you certain benefits based on your characteristics. You may withdraw your consent to such automated decision-making at any time following the withdrawal of consent procedure described above.

If there is any conflict between the provisions of this Appendix and the provisions of the main body of the Privacy Policy, the provisions of this Appendix will prevail.