At CGS International Securities Singapore Pte. Ltd. (“CGS SG”, “we”, “our”, “us”), we value your privacy and strive to protect your personal data (as defined below) in compliance with the laws of Singapore.
The type of personal data we collect and how we collect it
How we use your personal data
The parties that we disclose the personal data to
The choices we offer, including how to access and update your personal data
“Affiliate” means a related corporation (as defined in the Singapore’s Companies Act 1967) of CGS SG; “personal data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which CGS SG has or is likely to have access.
Type of Personal Data We Collect and How We Collect It
To process, administer and/or manage your relationship and/or account with CGS SG, and to provide you with the services and products of CGS SG, CGS SG will necessarily need to collect, use, disclose and/or process the personal data about you or your personnel, including but not limited to: –
(a) personal data including your images or biometrics data for verification or other purposes;
(b) personal data to establish your financial standing, creditworthiness and/or suitability for any of our products/services applied for (if required); and/or
(c) personal data in any forms that you provide to us when you apply for or use any of our products and services or when you interact with us.
We may obtain this data from yourself and from a variety of sources, including but not limited to:
(a) through your relationship with us, for example information provided by you in application forms, when using our products or services (including but not limited to websites, application(s) and any online accounts established with us), when taking part in customer surveys, competitions and promotions, and during financial reviews;
(b) through your verbal and written communications with us and/or our authorised agents;
(c) from information or files submitted or uploaded by you or collected from you when you use our mobile application(s);
(d) from an analysis of the way you use and manage your account(s)/facility(ies) with us, from the transactions you make and from the payments which are made to/from your account(s)/facility(ies);
(e) from third parties connected with you, such as employers, joint account holders, security providers, guarantors and indemnitors, subject to your prior consent;
(f) from such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted;
(g) from any relevant governmental authorities and/or law enforcement agencies to ascertain inter alia your current and past financial standing; and/or
(h) from any information that is supplied and/or collected when you visit our websites which include your mobile device or computer’s IP address or from any information that is collected via cookies in some of our websites.
How We Use Your Personal Data
Such personal data will be collected, used, disclosed and/or processed by CGS SG for one or more of the following purposes: –
(a) processing your enquiries and application for account opening, services and products by CGS SG;
(b) providing you with the services and products of CGS SG and CGS SG’s Affiliates, business partners and related companies;
(c) administering and/or managing your relationship with CGS SG;
(d) carrying out your instructions or responding to any enquiries or request by you;
(e) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or risk management procedures (including but not limited to those designed to combat financial crime, “know-your-customer”, anti-money laundering, counter-terrorist financing or anti-bribery), that may be required by law or that may have been put in place by CGS SG;
(f) dealing in any matters relating to the services and/or products which you are entitled to (including the printing and mailing of correspondence, statements, invoices, confirmations, advice, information, reports or notices to you, which could involve disclosure of certain personal data about you or your personnel to bring about delivery of the same as well as on the external cover of envelopes/ mail packages);
(g) the recovery of any and all amounts owed to CGS SG;
(h) the process of reviewing and approving your accounts with CGS SG and the conduct of initial and anticipatory credit checks and assessments, relevant checks, ongoing assessment and verification of ongoing credit worthiness and standing;
(i) preventing, detecting and investigating fraud, misconduct, any unlawful action or omission, whether relating to the application or any other matter relating your account(s) with CGS SG and whether or not there is any suspicion of the aforementioned;
(j) managing CGS SG’s infrastructure and business operations, and complying with policies and procedures that may be required by law or that may have been put in place by CGS SG, including those relating to auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing, business continuity, and records, document and print management;
(k) security, surveillance and/or identity verification purposes and managing the security of our premises including but not limited to carrying out CCTV surveillance, audio recordings of your instructions or conversations over the telephone or during face-to-face communications with CGS SG’s staff;
(l) if consented by you or your personnel (as may be applicable) via your registration or participation in any contest, lucky draw, campaign, promotion, event, survey or questionnaire, to administer and provide you with such activities. Some of these activities have additional terms and conditions, which could contain additional information about how CGS SG uses and discloses your personal data or that of your personnel (where applicable), so you should read these carefully;
(m) complying with applicable law in administering and managing your relationship with CGS SG; and/or
(n) if consented to by you in the application form(s), account opening document(s) and/or other methods of consent notification, provide for the dispatch of marketing information relating to financial or investment services or products offered by CGS SG and CGS SG’s Affiliates, business partners and related companies (whether by CGS SG, CGS SG’s Affiliates, business partners or related companies) which CGS SG thinks is of benefit or interest to you via your consented method(s) of communication;
(collectively, the “Purposes”).
Disclosure and Sharing of Your Personal Data
You hereby acknowledge and agree that such personal data will/may be disclosed by CGS SG to the following third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently process such personal data for one or more of the above Purposes: –
(a) CGS SG’s Affiliates and between each of them;
(b) CGS SG’s (or CGS SG’s Affiliates’) third party service providers or agents including but not limited to those who provide administrative, telecommunications, computer, payment or securities clearing or other services to CGS SG in connection with the operation of its business, mailing houses, telecommunication companies, marketing agents, call centers, data processing companies and information technology companies;
(c) any credit reference agency, rating agency, business partner, insurer or insurance broker, direct or indirect provider of credit protection, bank or financial institution, and, in the event of default, to debt collection agencies;
(d) any fund management companies, private equity companies and managers, other financial companies (e.g. for structuring/ provision of services), external asset managers, service providers (e.g. alternative investment service providers) and financial service providers;
(e) any credit bureau and/or its compliance committee and for such credit bureau and/or its compliance committee to disclose the personal data to third party or parties, including but not limited to its member banks or financial institutions;
(f) CGS SG’s auditors and professional advisors including its solicitors;
(g) any person to whom CGS SG is under an obligation to make disclosure under the requirements of any law binding on CGS SG or any of CGS SG’s Affiliates or branches or under and for the purposes of any guidelines issued by regulatory or other authorities with which CGS SG or any of CGS SG’s Affiliates or branches are expected to comply with;
(h) any person to whom disclosure is permitted or required by any statutory provision or law;
(i) any permitted assigns;
(j) CGS SG’s successors in title; and/or(k) any local or foreign regulatory body, government agency, statutory board, ministry, departments or other government bodies and/or its officials.
If you (or where applicable, any of your personnel) do not wish for CGS SG to use the submitted personal data or disclose the submitted personal data for any of the above Purposes, you may withdraw the consent at any time by prior written notice to CGS SG, however, depending on the circumstances and the nature/extent of the withdrawal, the withdrawal of consent may result in CGS SG’s inability to provide you with the services and products and hence may result in the termination of your relationship and/or account(s) with CGS SG or other consequences of a legal nature which may arise by virtue of your legal relationship with CGS SG.
Your latest written instructions to us will prevail. In certain instances where marketing communications from us are sent via browser push to your mobile device, you will have to follow certain prescribed steps to discontinue the receipt of marketing communications from us. Please take note that certain communications such as statements of account and our websites contain standard information regarding our other products and services that cannot be removed without affecting the delivery/provision of our services and/or products, the operation of your account(s) and/or facility(ies) with us, and/or additional costs to you.
For the avoidance of doubt, in the event that Singapore personal data protection law permits an organization such as CGS SG to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.
You agree that where your written permission is required by law or otherwise for any such disclosure by CGS SG, the signing of the application form(s), account opening document(s), and/or any other methods of consent notification, as well as in any other manner permitted by law shall constitute and be deemed to be sufficient written permission for such disclosure.
Cookies and Related Technologies
“Cookies” are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the website or mobile application and allow a website or mobile application to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising. Cookies are not programs that come onto a user’s system and damage files. Generally, cookies work by assigning a unique number to the user that has no meaning outside the assigning site.
Third Party Web Sites
Our website or mobile applications may contain links to other websites which are not maintained by CGS SG. We are not responsible for the privacy practices of such websites operated by third parties that are linked to our websites or mobile applications. When visiting these third-party websites, you should read their privacy policies which will apply to your use of such third-party websites to determine how they will handle any information they collect from you.
Contacting CGS SG About Your Privacy And How We Handle Your Personal Data
If you: –
(c) would like to obtain access and make corrections to your personal data records, kindly contact us at the following contact point: –
• E-mail: email@example.com