Privacy Policy

Data Protection Notice

This Data Protection Notice (“Notice”) sets out the basis which Whitefield Capital Management Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Singapore Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

Personal Data

1. As used in this Notice:

   “customer” means an individual who (a) has contacted us through any means to find out more about investment services we provide, or (b) may, or has, entered into a contract with us for the supply of investment services by us; and

   “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, photograph, employment information and financial information.
3. Other terms used in this Notice shall have the meanings given to them in the Singapore PDPA (where the context so permits).

Collection, Use and Disclosure of Personal Data

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
   1. performing obligations in the course of or in connection with our provision of the investment services requested by you;
   2. verifying your identity;
   3. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
   4. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
6. We may disclose your personal data:
   1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the investment services requested by you; or
   2. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

RELIANCE ON LEGITIMATE INTERESTS EXCEPTION

7. In compliance with the Singapore PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Whitefield Capital Management Pte Ltd or another person. In relying on the legitimate interests exception of the PDPA, Whitefield Capital Management Pte Ltd will assess the likely adverse effects on you and determine that the legitimate interests outweigh any adverse effect.
8. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
   1. Fraud detection and prevention.
   2. Detection and prevention of misuse of services.
   3. Network analysis to prevent fraud and financial crime.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

PROTECTION OF PERSONAL DATA

9. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures. 
10. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information to be extent practicable.

ACCURACY OF PERSONAL DATA

11. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate. Please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

12. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
13. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

DATA PROTECTION OFFICER

14. You may contact our Data Protection Officer at the contact details below, if you have any enquiries or feedback on our personal data protection policies and procedures:

    Contact No. :  (65) 6534 1978

    Email Address :  admin@whitefield.com.sg

    This Notice shall be governed by, and construed in accordance with, the laws of Singapore. Any dispute arising out of or in connection with this Notice shall be referred to and resolved by the Courts of Singapore. Both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Singapore.