Privacy Policy​

This Privacy Policy (“Policy”) describes how we collect, use, disclose and otherwise process your Personal Data through this website (“Website”).

By accessing, using or continuing to access or use the Website and/or our products and services, you confirm, represent and warrant to us, that: 

(a) you have read and understood this Policy; 
(b) you agree to be legally bound by the terms of this Policy; 
(c) you consent to the collection, processing, use and disclosure of Personal Data provided by you as set out in this Policy; and 
(d) any information provided by you to us (including Personal Data) is correct, accurate, up to date and complete.  

For the purposes of this Policy, the term “Personal Data” shall carry the definition assigned to it under the Personal Data Protection Act (No. 26 of 2012) (as amended or re-enacted from time to time) (the “PDPA”).

From time to time, we may revise this Policy to reflect changes in the applicable laws, regulations, voluntary codes, updates in technology etc. or for any other reason. Any revised version of this Policy will be posted on the Website and will be effective immediately upon such posting. We are under no obligation to separately inform you of any revision, and it shall be your responsibility to review this Policy upon each access or use of this Website and/or our products and services. You should review this Policy periodically so that you are up to date on our most current policies and practices. 

Your continued access or use of the Website and/or our products and services after the revised Policy has taken effect will constitute your unconditional acceptance of such revised Policy. All communications, transactions and dealings with us will be subject to the latest version of this Policy in force at the relevant time. If you do not agree with this Policy or any changes, please do not continue accessing or using the Website, and inform us accordingly. The provision of our products and/or services may be affected if you do not agree with this Policy.

Collection, usage and disclosure of Personal Data

We collect Personal Data from you that you provide to us directly or automatically when accessing or using the Website, or when communicating with us via emails or other mediums, or in the course of the provision of products and/or services offered by us, or upon request by us. We may also use cookies to collect, use or disclose Personal Data. Please see the section on our use of cookies below. We will only collect, use or disclose your Personal Data as necessary for the purposes outlined in this Policy and in compliance with the applicable laws.

We may request that you provide the following Personal Data (including, but not limited to, your name, address, phone number, email address, identify proof, bank account information, etc.), which is collected, and which may be used or disclosed, by us for the following purposes:

  1. considering and processing your applications for financial and investment products and services offered by us;
  2. providing our products and services to you, and giving effect to your instructions in relation to other specific transactions or otherwise that involve you;
  3. notifying you about changes to our products and services;
  4. deciding whether or not to provide credit to you or assessing your credit worthiness and good standing. This may include but is not limited to conducting credit checks upon a pending application for consumer credit or to review whether changes need to be made to an existing credit facility;
  5. marketing financial, investment and other products and services to you, as described in the Direct Marketing Section below;
  6. enforcing our rights under contracts, including but not limited to, collecting amounts outstanding;
  7. meeting our obligations, requirements or arrangements, to comply with or in connection with the applicable laws, notices, guidelines, guidance or requests given or issued by any local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents;
  8. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of crime, money-laundering, terrorist financing or other unlawful activities;
  9. enabling an actual or proposed assignee of Assured Asset Management (including without limitation any person, business or entity with whom it is proposed Assured Asset Management will merge or to whom Assured Asset Management proposes to dispose of all or any part of its business), or participant or sub-participant of Assured Asset Management’s rights in respect of the customers to evaluate the transaction intended to be the subject of the assignment, merger, disposal, participation or sub-participation; and 
  10. any other incidental business purposes related to or in connection with the above. 

On or before collection of the Personal Data that you give us, we will inform you whether it is obligatory or voluntary to supply such Personal Data. Failure to supply Personal Data that is marked as obligatory may result in us being unable to provide the relevant products and services fully or at all. 

Other data that we collect

When you visit the Website, we may also automatically collect data such as your IP address, geographic data, the browser you are using, information about your computer’s operating system, application version, language settings, website interaction, etc.), which is collected, and which may be used or disclosed, by us for the following purposes: 

  1. to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, and statistical purposes;
  2. to improve the Website to ensure that content is presented in the most effective manner for our users;
  3. to allow you to participate in interactive features of our services, when you choose to do so;
  4. as part of our efforts to keep the Website safe and secure;
  5. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
  6. to make suggestions and recommendations about products or services that may be of interest.

Transfer or disclosure of Personal Data

Personal Data held by us will be kept confidential. We may however provide such Personal Data to other parties (whether local or overseas) for the purposes set out above. These include (without limitation):

  1. any agent, contractor or third party service provider (including third party payment providers) of Assured Asset Management who provide services in connection with the operation or maintenance of our business, including their employees, officers, agents, contractors, service providers and professional advisers;
  2. credit reference agencies and, in the event of default, to debt collection agencies;
  3. any financial institution, securities and investment services providers with which you have or propose to have dealings;
  4. any persons, businesses or entities giving or proposing to give a guarantee or security to guarantee or secure your obligations to us;
  5. legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents;
  6. any person, business or entity to whom Assured Asset Management is under an obligation to make disclosure for the purposes set out above;
  7. any person, business or entity wishing to provide funds to Assured Asset Management for the purposes of financing its business;
  8. any person, business or entity to whom you have given consent as to the transfer of Personal Data for direct marketing;
  9. any actual or proposed assignee of Assured Asset Management or any assignee of Assured Asset Management’s rights;
  10. analytics and search engine providers that assist us in the improvement and optimisation of the Website; and 
  11. any other person, business or entity to whom transfer of Personal Data has consented to expressly or impliedly by you.

Direct marketing

We may use your Personal Data to provide you with information about our financial and investment products and services. Your name, contact details, information relating to your interest in our products and services, transaction pattern and behaviour, financial background and demographic data held by us from time to time may be used by us for such direct marketing. Direct marketing communications will be through electronic means (e.g. email or SMS) and may be conducted by us or our service providers.

We will only use your Personal Data for direct marketing as outlined above if we have obtained your consent to do so. You can indicate whether you consent to us using your Personal Data for direct marketing, for instance, by ticking the relevant boxes on the forms on which we collect your Personal Data. 

If you do not wish for us to use or transfer to third parties your Personal Data for use in direct marketing as described above, you can unsubscribe anytime free of charge. Please reach out to our data protection officer at the contact details provided below.

Direct marketing

We may use your personal data to provide you with information about financial and investment products and services. Your name, contact details, information relating to your interest in our products and services, transaction pattern and behavior, financial background and demographic data held by us from time to time may be used by us for such direct marketing. Direct marketing communications will be through electronic means (e.g. email or SMS) and may be conducted by us or our service providers.

We will only use your personal data for direct marketing as outlined above if we have obtained your consent to do so. You can indicate whether you consent to us using your personal data for direct marketing, for instance by ticking the relevant boxes on the forms on which we collect your data.

If you do not wish for us to use or transfer to third parties your personal data for use in direct marketing as described above, you can unsubscribe anytime free of charge. Please reach out to us using the contract details provided below.

Protecting your Personal Data

We will use all reasonable endeavours to secure the Personal Data and prevent it from abuse, misuse, interference, loss and against unauthorised access, alteration or disclosure. All Personal Data you provide to us is stored on our secure servers. All payment transactions will be encrypted. 

Where we have given you (or where you have chosen) log-in credentials such as a username, password or any other piece of information as part of our security procedures, you will be solely responsible for keeping these log-in credentials confidential and not sharing these with anyone.

Transmission of data via the Internet or other media is not completely secure. Although we will do our best to enhance the security of such transmission, we cannot guarantee the security of your data transmitted to us. While we are committed to protecting your data, you agree and acknowledge that the Website or its contents may not be free of errors, computer viruses and/or other harmful or corrupting code, program, macros and such other unauthorised software. You agree that you will not hold us liable for any disclosure of data provided by you resulting from events and circumstances beyond our control.

Data that we collect from you will be retained by us for so long as it is necessary for us to carry out the purposes set out in this Policy, or as required or permitted by applicable laws and regulations.

In the event of the occurrence of a data breach of your Personal Data that (i) is, or is likely to be of a significant scale (ii) or results in, or is likely to result in, significant harm to you (as assessed by us), we shall, as soon as practicable, notify you of such a breach as well as our response taken or to be taken to limit or mitigate any potential harm in relation to such a breach unless we are prevented by law from doing so, or we are permitted by law to not do so. Upon being notified, you are expected to take the necessary steps to protect yourself against such a breach. 

Cookies

Our Website may use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website. A cookie is a small piece of data that is sent to your computer from our Website and stored on your computer. You may disable the use of cookies by configuring your cookies settings on your browser, which may allow you to accept or reject all or some cookies. However, if you do so, you may not be able to enjoy the full user experience with our Website. 

Withdrawal of consent

Your consent provided to us for the collection, use and disclosure of Personal Data will remain valid until such time you have notified us in writing of your withdrawal of consent. You may withdraw consent and request us to stop collecting, using or disclosing the Personal Data provided by you for any or all of the purposes permitted under this Policy by submitting your request to our data protection officer at the contact details below.  

We may require reasonable time to process a withdrawal request, and you acknowledge that such withdrawal of consent may affect the products and services which we are able to provide to you.

Please note that withdrawing consent does not affect our right to continue to collect, use or disclose any Personal Data where such collection, use or disclosure without consent is permitted or required under any applicable laws.

Data access and correction requests

Your right of access and correction of Personal Data held by us shall be exercised in accordance with the applicable laws.

Subject to applicable laws, you may make a request (an “Access Request”) to us to:

  • confirm whether we hold your Personal Data;
  • be supplied with a copy of such data; and
  • inform you about the ways in which your Personal Data held by us has been used or disclosed by us within a year from the date of such request. 

We reserve the right to charge a reasonable fee (as determined by us) deemed appropriate to enable us to respond to an Access Request. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment of the fee is received. 

Further, you may additionally make a request for the correction of your Personal Data held with us that is inaccurate, or to update your Personal Data. 

Any of the above requests are to be directed to our data protection officer at: 

Data Protection Officer:

Robert Cheung 

Assured Asset Management

Address:

Room 1301, 13/F, Sun House, 181 Des Voeux Road Central, Hong Kong

Email:

[email protected]

Third-party links

Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates, which may not be maintained or operated by us, or which may be maintained or operated under the laws of other applicable jurisdictions. 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 or in relation to these policies or the content of these external websites. Please check such policies before you submit any Personal Data to these websites.

Language

This Policy is drafted in the English language and may be translated into various languages. In the case of any discrepancies or inconsistencies between versions of different languages, the English version will prevail.

Governing Law

This Policy shall be governed by the laws of Singapore.