PRIVACY POLICY

1. General

1.1: This Policy statement provides information on the obligations and policies of Solomon Alliance Management Pte Ltd (“SAM”) in respect of an individual customer’s Personal Data. SAM undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations. Please take a moment to read this Privacy Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

1.2: SAM’s officers, management, members of staff and independent contractors shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of SAM. SAM shall use reasonable endeavours to ensure all collection and/or storage and/or disclosure and/or usage of Personal Data by SAM and by anyone acting on its behalf shall be done in an appropriate manner and in accordance to the Act and this Policy.

1.3: By interacting with us, submitting information to use, or signing up for any products or services offered by us, you agree and consent to SAM as well as to its respective representatives and/or contractors (“Representatives”) (collectively referred to herein as “SAM”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to SAM’s authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.

1.4: This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5: For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified- from that data; or from that data and other information to which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of SAM or that which shall be collected by SAM in the future.

2. Contacting the Data Protection Officer

2.1: Where you: (i) legitimately request access to Personal Data relating to you which is in the possession and control of SAM; (ii) have any questions or feedback relating to your Personal Data or this Policy; or (iii) or wish to correct Personal Data relating to you which is in the possession and control of SAM, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated hereinafter. We shall attain to your request a reasonable time and manner.

2.2: In accordance with the Act, SAM has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that SAM receives your complaints and enquiries, please send the same via email to the DPO at the following email address: DPO@SolomonAllianceManagement.com

2.3: Please note that if your personal data has been provided to us by a third party (e.g. a policyholder who has nominated you as beneficiary or the life assured), you should contact that individual to make such queries, complaints, and access and correction requests to SAM on your behalf.

2.4: Your request shall be processed within a reasonable time. However, please note that if you do not wish SAM to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from SAM, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. In an event that this results in a situation wherein we may not be in a position to continue to provide our products or services to you, administer any contractual relationship in place; this may also result in the termination of any agreements with us, and you being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.

3. Statement of Practices

Types of Personal Data Collected:

3.1: As part of its day to day activities, SAM may collect from you, through various means including:

  • when you submit an Expression of Interest Form or other forms relating to any of our products or services;
  • when you interact with our representatives, e.g. via telephone calls, letters, face-to-face meetings and email;
  • when you use some of our services e.g. websites including establishing any online mailing list with us;
  • when you take up an a product for your benefit;
  • when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
  • when you are contacted by, and respond to, our representatives for marketing and servicing purposes
  • when you submit a job application;
  • when we receive references from business partners and third parties, for example, where you have been referred by them;
  • when we seek information from third parties about you in connection with your investment, investment applications or job applications, for example your ex-employer and the relevant authorities; and
  • when you submit your Personal Data to us for any other reasons.

3.2: The type of your Personal Data that we collect may include your:

  • Name (first and surname);
  • Address
  • Postal Code
  • NRIC/FIN Number
  • Phone Number
  • Email Address
  • Passport Number
  • Data of Birth/Age
  • Gender
  • Household/Personal Income
  • Race
  • Banking Information
  • Purchase History
  • Product/Service Preferences
  • Health/Medical Information
  • Video or Audio Security tapes Photos/Images (where individual is included)
  • Salary
  • Employment history
  • Educational/technical qualifications
  • Spouse information
  • Parents information (mother’s maiden surname)
  • Scanned cheque
  • Fingerprint
  • Any other Personal Data that we may think is required in order to provide you with our services.

3.3: If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), including where you have named them as beneficiaries, or where you refer a third party to us for the purposes of us offering our products and/or services to that third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

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Purpose of Collection of Personal Data

3.4: The above Personal Data mentioned in Clause 3.2 is collected for the purpose of:

  • Ensuring clients are eligible for privileges or benefits or other related purposes;
  • to conduct market research and analysis;
  • for direct marketing through voice calls, text messages, email, direct mail and facsimile messages;
  • to complete a sale/transaction;
  • for payment and/or credit control purposes;
  • for customer services and relationship management;
  • for office access control;
  • to respond to complaints, queries and feedback;
  • to notify clients of any changes of SAM’s policies or services which may affect the client; and
  • to inform SAM’s clients of new developments, services, promotions of SAM and other third parties which we are associated with and as required by law

3.5: In addition, SAM, collects your Personal Data for the following purposes depending on the nature of our relationship:

If you are a prospective client, for:

  • providing recommendations to you as the type of products and services suited to your needs;
  • assessing and processing any applications or requests made by you for products and services offered by SAM;
  • communicating with you in relation to products and services, product updates, updates to terms and conditions and providing administrative information, including for the purposes of servicing you in relation to products and services offered to you;
  • requesting feedback or participation in surveys, and/or conducting market research and analysis for statistical, profiling or other purposes for us to understand customer behaviour, preference and market trends so as to review, develop and improve the quality of our products and services;
  • administering, maintaining, managing and operating the products and services offered to you, including products by other companies;
  • notifying clients of SAM’s products whether new or updated; and
  • any other purpose relating to any of the above.

If you submit an application to us as a candidate for an employment or representative position

  • processing your application including pre-recruitment checks, such as in relation to your credit standing and qualifications;
  • providing or obtaining employee references and for background screening/vetting;
  • collecting information about your suitability for the position applied for;
  • communicating with you as required by SAM to comply with its policies and processes, including for business continuity purposes; and
  • any other purposes relating to the aforesaid.

3.6: In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use of disclosure your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

  • communicating with you in relation to your investment and informing you of development updates, updates to terms and conditions and providing administrative information, including for the purposes of servicing you in relation to products you have purchased;
  • acknowledgment by Public Notary and submission to government bodies both local and overseas to perform contractual obligations of products purchased;
  • collecting payment and disburse of investment payout(s); and
  • any other purposes relating to the aforesaid.

Disclosure of Personal Data

3.7: Without derogating from any of the above, we may also disclose your Personal Data to the following third parties:

  • Partners;
  • Investment developers/Partners;
  • Pay-roll Processing Services;
  • Banks;
  • Regulators and law enforcement officials;
  • Lawyers;
  • Auditors;
  • Third party service providers and consultants;
  • other entities processing payment;
  • Potential buyers or investors of SAM or any of SAM’s companies; and
  • Any representative or subcontractor acting on SAM’s behalf for the provision of SAM’s services.

3.8: SAM may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:

  • To the extent that we are required to do so by the law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise or defend our legal rights
  • To the purchaser (or prospective purchaser) of any business or asset which we are (or we are contemplating) selling;
  • To any person and/or entity for the purpose of processing such information on our behalf;
  • To third parties who provide service to us or on our behalf;
  • To any third party that purchase our business or any part of our business;
  • With your consent; and
  • For the purposes of disaster recovery.

Optional Provision of Personal Data

3.9: In some instances, you may also be requested to provide certain Personal Data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:

  • Hobbies and leisure activities
  • Other related products and services subscribed to;
  • Family and household demographics; and
  • any other purposes relating to the aforesaid.

3.10: Under certain circumstances, telephone calls made to us to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.

4. Transfer of Personal Data Overseas

Your Personal Data may be processed by SAM, its affiliates, representatives and third parties providing services to SAM, in jurisdictions outside of Singapore. In this event, SAM will comply with the terms of the Act.

  • Partners;
  • Investment Developers/Partners
  • Banks;
  • Regulators and law enforcement officials;
  • Lawyers;
  • Auditors;
  • Foreign Government body(s) overseas involved in the issuance of land title pertaining to our product;
  • Third party service providers and consultants;
  • other entities processing payment;
  • Any representative or subcontractor acting on SAM’s behalf for the provision of SAM’s services.

5. Accuracy of Personal Data

 5.1: Where possible, we will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers. In some instances, SAM is able to validate the data provided against pre-existing data held by us. In some cases, SAM is required to see original documentation before we may use the Personal Data such as Personal identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in our possession so as to allow SAM to remain in compliance with the Act, you are required to inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.

5.2: SAM shall not be liable for any damage, claim and/or harm suffered by you as a result of your failure to update us of any changes of your Personal Data.

5.3: Should you fail to inform us of your new home address, any correspondence sent by us to your last home address shall be deemed to have duly received by you.

6. Protection of Personal Data

SAM uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside SAM, other than to you or as described in this Policy. However, we cannot ensure or warrant the security of any information you transmit to us and you do so entirely at your own risk. In particular, SAM does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any SAM’s physical, technical, or managerial safeguards.

7. Access and Correction of Personal Data

7.1: In accordance with Clause 2.1 of this policy, you have the right to:

a) check whether SAM holds any Personal Data relating to you and, if so obtain copies of such data; and

b) require SAM to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.

7.2: SAM reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.

7.3: If you wish to verify the details you have submitted to SAM or if you wish to check on the manner in which SAM uses and processes your personal data, our security procedures mean that we may request proof of identity before we reveal information. This proof identity will take the form of full details of name, NRIC or Passport of Fin number. You must therefore keep this information safe as you will be responsible for any action which SAM takes in response to a request from someone using your personal details. You may send a clearly worded email to the DPO via the email address provided in Clause 2.2

7.4: SAM reserves the right to decline to provide access to personal information in several circumstances. These include, but are not limited to, circumstances where the information requested:

  • would disclose personal information, including opinions, about another individual;
  • would disclose SAM’s trade secrets or other confidential business information;
  • is subject to lawyer-client privilege;
  • is not readily retrievable and the burden or cost of providing it would be disproportionate to the value of the information; and
  • does not exist or cannot be found;
  • could result in serious harm to the individual requesting it, serious harm to the life, safety or health of another person, or serious emotional harm or embarrassment to another individual; and
  • may be or is required to be withheld by other legislation.

Where information requested will not or cannot be disclosed, SAM will provide the reasons for non-disclosure.

8. Storage and Retention of Personal Data

SAM will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of SAM and where the Personal Data is deleted from SAM’s electronic, manual, and other filing systems in accordance with our internal procedures and/or other agreements.

9. Contacting you

To the extent that any of the communication means which you have provided us with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry, by agreeing to this Policy, by any means of indication, you hereby grant SAM your clear and unambiguous consent to contact you using all of your communication means you have provided to us including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communication applications or methods, for the purpose as stated above in Paragraphs 3.4 and 3.5. This will ensure your continued updates of our products, events and services.

10. Change Policy

SAM reserves the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by us. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

11. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.

12. Miscellaneous

12.1: This Policy only applies to the collection and use of Personal Data by SAM. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. SAM does not share your Personal Data with third party websites. SAM is not for the privacy and conduct practices of these third party practices, so you should read their own privacy policies before disclosure of any Personal Data to these websites.

12.2: SAM will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked to or been directed from SAM’s website.

12.3: SAM’s website do not target and is not intended to attract children under the age of 18 years old. SAM does not knowingly solicit personal information from children under the age of 18 years or send them requests for personal data.

Solomon Alliance Management
Compliance Department
Updated July 2014
Version 2.1 (SAM/TS/07/2014)

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