Privacy Policy

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data in connection with our financial planning services, including annual financial planning, investment strategies, wealth management, retirement planning, estate planning, and risk assessment.

We process personal data in accordance with applicable privacy and data protection laws, including the Singapore Personal Data Protection Act 2012 and, where applicable, the European Union General Data Protection Regulation.

Who We Are

The financial planning practice responsible for this service is based in Singapore. For postal enquiries concerning privacy or personal data, write to:

Personal Data We Collect

Depending on the services you request, we may collect the following categories of personal data:

• Identity and contact information, such as your name, postal address, telephone number, date of birth, nationality, and residency status.
• Financial information, including income, assets, liabilities, expenses, investments, pensions, insurance, tax-related information, and financial objectives.
• Information about dependants, beneficiaries, family circumstances, estate-planning objectives, and other individuals where relevant to your instructions.
• Risk and suitability information, including your investment experience, risk tolerance, capacity for loss, and investment preferences.
• Information arising from your use of our online platform, such as technical identifiers, device information, access records, and interaction data.
• Records of enquiries, consultations, instructions, assessments, recommendations, and transactions.

How We Collect Personal Data

We may collect personal data directly from you, from authorised representatives, from financial institutions or professional advisers acting with your authority, and from publicly available or legally permitted sources. We may also collect technical information automatically when you use our online platform.

How We Use Personal Data

We use personal data only for appropriate and lawful purposes, including:

• Understanding your financial circumstances, goals, needs, and risk profile.
• Preparing and delivering annual financial plans, investment strategies, wealth management services, retirement plans, estate-planning guidance, and risk assessments.
• Assessing suitability, affordability, financial risks, and potential conflicts of interest.
• Managing client relationships, appointments, records, billing, and service administration.
• Complying with anti-money laundering, know-your-customer, tax, sanctions, regulatory, accounting, and legal obligations.
• Protecting our clients, personnel, systems, and services against fraud, misuse, security threats, and other unlawful activity.
• Improving the quality, security, accessibility, and performance of our online platform and services.

Legal Bases for Processing

Where the GDPR applies, we rely on one or more of the following legal bases: performing a contract or taking steps at your request before entering into a contract; complying with legal obligations; pursuing legitimate interests that do not override your rights; protecting vital interests where necessary; and obtaining your consent where consent is required. You may withdraw consent at any time, although this will not affect processing carried out before withdrawal.

Disclosure of Personal Data

We may disclose relevant personal data to carefully selected service providers and professional advisers who support our operations, technology, compliance, accounting, document management, security, and financial planning services. We may also disclose data to financial institutions, regulators, government authorities, courts, auditors, insurers, or other parties where required or permitted by law or where necessary to provide a service you have requested.

Service providers may process personal data only under appropriate contractual or legal safeguards and in accordance with our instructions. We do not sell personal data.

International Transfers

Some service providers or recipients may be located outside Singapore or the European Economic Area. Where personal data is transferred internationally, we use legally recognised safeguards, such as an adequacy decision, standard contractual clauses, contractual protections, or another lawful transfer mechanism.

Cookies and Similar Technologies

Our online platform may use essential cookies and similar technologies to provide security, maintain functionality, remember preferences, and understand service performance. Where required by law, non-essential technologies will be used only after obtaining your consent. You can manage cookies through your browser settings or any consent tools made available through our online platform.

Retention of Personal Data

We retain personal data only for as long as necessary for the purposes described in this Policy, to provide services, resolve disputes, enforce agreements, maintain business records, and meet legal, regulatory, tax, accounting, and professional obligations. Retention periods may vary according to the type of information and the applicable requirements. When data is no longer required, we securely delete, anonymise, or otherwise dispose of it.

Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal data against unauthorised access, loss, misuse, alteration, or disclosure. No transmission or storage system can be guaranteed to be completely secure, so you should take appropriate care when providing information and protect any account credentials in your control.

Your Rights

Subject to applicable law and certain exceptions, you may have the right to:

• Request access to personal data we hold about you.
• Request correction of inaccurate or incomplete personal data.
• Request deletion or restriction of processing in appropriate circumstances.
• Object to processing based on legitimate interests or direct marketing.
• Request portability of certain personal data processed by automated means.
• Withdraw consent where processing relies on consent.

Requests should be made in writing to our postal address above. We may need to verify your identity before responding. We will respond within the period required by applicable law and may apply lawful limits or fees where permitted.

Children’s Privacy

Our services are intended for adults and are not directed to children. We do not knowingly collect personal data from children without appropriate consent or legal authority. If you believe a child has provided personal data improperly, please write to us at the postal address above.

Complaints

If you have concerns about our handling of personal data, please write to us at Bukit Timah Road, Singapore 229862, Singapore. We will review and investigate complaints in accordance with applicable requirements. Where appropriate, you may also complain to the Personal Data Protection Commission of Singapore or another competent data protection authority.

Changes to This Policy

We may update this Privacy Policy to reflect changes in our services, legal requirements, or data practices. The updated version will be made available through our online platform, and the revised policy will apply from the time it is published unless stated otherwise.