Privacy Notice
At Namara Wealth Advisors, we are committed to safeguarding your privacy. We will collect, use, store and disclose your personal data in accordance with the provisions of Personal DataProtection Act 2012 (“PDPA”). Please take a moment to read this Privacy Notice so that you know and understand the purposes for which we may collect, use, and/or disclose your personal data.
YOU AGREE AND CONSENT to Namara Wealth Advisors Pte Ltd (“Manager”) as well as our respective agents, authorised service providers and relevant third parties collecting, using, storing, disclosing and/or sharing your personal data in the manner set forth in this Privacy Notice.
This Privacy Notice 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. We may from time to time update this Privacy Notice to ensure that this Privacy Notice is consistent with our business purpose and/or any changes in legal or regulatory requirements. Please check back regularly for any updated information to ensure you are aware of how your personal data is being handled. If you continue to use our products and services, maintain any account with us, access our website and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such change without reservation.
For the avoidance of doubt, this Privacy Notice forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.
WHat is Personal Data?
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 we have or are likely to have access. This includes personal details like your name, passport or other identification numbers, contact numbers, address, email, date of birth, occupation, education, income levels, bank account information and assets, transaction-related information like your investment instructions, photos and videos of you from our events or office surveillances, and information about your use of our services and website, including cookies and IP addresses.
We Keep Your Personal Data Confidential and Secure
Your privacy is of utmost importance to us. At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and procedural safeguards to protect your personal data against loss, misuse, damage and unauthorised access, modifications or disclosures. We regularly review and enhance our security policies and measures to consistently maintain a high level of security.
Purposes for Collection, Use and Disclosure of Your Personal Data
We collect, use and/or disclose your personal data to provide enhanced asset management services and/or family office services to you, including but not limited to:
(a) analysing our financial situation and determining financial strategies and products suitable for you;
(b) assessing and processing your applications and instructions for financial products and services offered by us and/or other financial institutions or product providers;
(c) satisfying our responsibility relating to ‘Know Your Customer’ (KYC) requirements;
(d) analysing and managing financial and commercial risks including preventing, detecting and investigating crime;
(e) updating you on your financial situation, our performance of our services to you, developments in our services and special happenings;
(f) responding to your queries and instructions and handling complaints;
(g) internal reporting and analysis related to our business operations;
(h) observing 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
(i) Maintaining records of your instructions and our interactions with you; and
(j) any other purposes, directly or indirectly relating to any of the above and our activities. (hereinafter collectively referred to as the “Purposes”). If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will seek your consent.
How We May Collect Your Personal Data
We may collect your personal data ourselves or through third parties
(a) during our preliminary discussions with you and when establishing our relationship with you;
(b) when you interact with our employees, in particular with your Relationship Manager;
(c) when you communicate with us by email or telephone, your emails will be retained and we may monitor and/or record your voice calls to us;
(d) when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;
(e) when you access our website;
(f) when you respond to our requests for additional personal data; and
(g) when you submit your personal data to us for any other reason. When you access our website you generally do so anonymously. Your activity may however be monitored by cookies (small data files sent to your browser to track information about your usage of our website) or other navigational data. Should you wish to disable such cookies, you may do so by changing your browser settings. However, you may not be able to access certain part(s) of our website. Please refer to our Cookie Policy.
To Whom We May Disclose Your Personal Data
Generally, we shall protect and keep confidential your personal data. We will disclose your personal data only with your consent and for purposes that you have been informed about. In performing our services we may disclose your personal data for the purposes set out above to parties such as
(a) our group companies;
(b) banks, financial institutions, credit card companies and their respective service providers;
(c) companies providing services relating to insurance and/or reinsurance, and associations of insurance companies;
(d) our agents, contractors or operational third party service providers;
(e) our professional advisers such as our auditors and lawyers; and
(f) regulators and authorities.
When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available or where use/disclosure of your personal data is otherwise legally mandated and exempted. If your personal data is transferred overseas, we will inform you of the extent to which your personal data will be protected in the foreign jurisdiction(s) to which it will be transferred and seek your consent.
Duration of Retention of Your Personal Data
We shall store your personal data for as long as necessary to fulfil the purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required. In general, your transactional personal data is kept for 5 years following transactions and your other personal data 5 years after the closing of the business relationship.
Queries, Feedback, Access/Correction Requests and Withdrawal of Consent
You are responsible for ensuring that the information you provide is accurate, complete, and not misleading, and that such information is kept up to date. If you have any questions or feedback or wish to access and/or correct your personal data, or you wish to withdraw your consent to our collection, use or disclosure of your personal data, please contact your Relationship Manager or submit a written request (with supporting documents, if any) to our Data Protection Officer at admin@namarawealth.com.
Our Data Protection Officer shall strive to respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in the position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may result in the termination of any agreement you may have with us. All our rights are reserved in such event. This Privacy Notice shall be governed by, and construed in accordance with, the laws of Singapore. Any dispute arising out of or in connection with this Privacy Notice shall be referred to and finally resolved by the Courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Singapore.
