Privacy Notice
Introduction
Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Modular Asset Management (Singapore) Pte. Ltd (the “Firm”, “we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former employees.
References to “you” in this Privacy Notice mean any current, potential or former employee, who is an individual, or any individual connected with an employee who is a legal person, as applicable.
Who to Contact About This Privacy Notice
This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). The Firm is considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that the Firm determines the purposes and the means of the processing of your personal information.
Please contact our Data Protection Officer and Chief Compliance Officer on compliance@modularam.com, +65 6721 9205 with any questions about this Privacy Notice or requests with regards to the personal data we hold.
Please note that Firm, its agents and service providers work under a range of professional, regulatory and legal obligations that require them to process personal data. In order to meet the requirements of such obligations, they, from time to time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and therefore as data controllers in their own right with respect to such processing.
The Types of Personal Data We May Hold
The categories of personal data we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches.
How We Collect Personal Data
We may collect personal data about you through: (i) information provided directly to us by you, or another person on your behalf; or (ii) information that we obtain in relation to any transactions between you and us.
We also may receive your personal information from third parties or other sources, such as our service providers, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.
How We May Use Personal Information
We may process your personal data for the purposes of administering the relationship between you and us and allowing the Firm to meet its professional, regulatory and legal obligations, including background checks and employment pass and regulatory license applications.
We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:
- we are required to comply with a legal or regulatory obligation applicable to us; or
- we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose.
How We May Share Personal Data
We may disclose information about you to our service providers, or other third parties to accept perform our contractual obligations. We may also need to share your personal information with regulatory, tax or law enforcement authorities to comply with applicable legal or regulatory requirements, respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations. We will also release information about you if you direct us to do so.
Retention Periods and Security Measures
We will not retain personal data for longer than is necessary in relation to the purpose for which it is collected, subject to the applicable Data Protection Laws. Personal data will be retained for the duration of your employment with the Firm and for a minimum of five years following termination of your employment with the Firm. We may retain personal data for a longer period including compliance with applicable law. From time to time, we will review the purpose for which personal data has been collected and decide whether to retain it or to delete if it no longer serves any purpose to us.
To protect your personal information from unauthorised access and use, we apply organisational and technical security measures in accordance with applicable Data Protection Laws. These measures include computer safeguards and secured files and buildings.
We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.
Firm Data Privacy Policy
All personal data concerning you (whether provided by you or any other person, and whether provided before or after the date of the employment application) may be used by the Firm and/or any affiliates (any entity controlling, controlled by or under common control with the Firm) and/or any person authorised by the Firm, when carrying out the business of the Firm or its affiliates.
All personal data concerning you (whether provided by or any other person, and whether provided before or after the date of the employment application) may be used for the following purposes:
(a) all matters relating to or in connection with your employment including background check, licensing applications, payroll, benefit, administration, transfer and other career related matters;
(b) all matters relating to or in connection with the business of the Company or its affiliates including marketing and promotional activities;
(c) transfer of such data to any place outside Singapore; and
(d) any purpose relating to or in connection with compliance with any law, regulation, court order or order of a regulatory body.
In general, and subject to certain exemptions, you are entitled to:-
(a) request access to your personal data, which must be provided within a reasonable time;
(b) request the correction of your personal data;
(c) be given reasons if a request for access or correction is refused; and
(d) any other right provided under the laws of a relevant jurisdiction.
Any request for access to and/or correction of personal data should be addressed to the Chief Operating Officer.