Farosson is committed to processing personal data (“PD”), including personal information, in line with all applicable privacy and data protection laws. Our offices are or will be in countries with laws governing the processing of PD. “Farosson”, “we”, “us” or “our” means Farosson Pte. Ltd., Farosson Capital Pte. Ltd., and each of the related companies of Farosson (collectively, the “Farosson Group”). Farosson, Farosson Group functions and the entity you contract with are the controllers of your PD. If your contract with the Farosson Group is in connection with an investment in a Farosson managed vehicle, the management company of the fund, together with the fund entity and, in circumstances where the
investment manager is part of the Farosson Group, the said investment manager, will be the controller.
References to “you” or “your” refers to individual whose PD is processed by Farosson, including clients with direct or indirect relationships (for instances those who invest through an intermediary), employees, officers, agents (collectively, the “Representatives”), and the beneficial owners of a person, corporation or organisation in connection with:
- the provision of services to potential and actual clients;
- transactions to which Farosson is a party (including those which we will act on behalf of the clients);
- services provided to us by a third-party vendor.
This privacy notice (“Privacy Notice”) sets out the purposes for which we collect, use and disclose (collectively “processing”) PD and how it is protected. This Privacy Notice also sets out individuals’ rights in relation to the processing of their PD.
Kindly note that there may be addition or amendment to the terms, conditions and commitments that govern how we process your PD, which should be read in conjunction with this Privacy Notice.
Collection of PD
PD is information relating to an individual which can be used either alone or with other sources of information to identify that individual. PD does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous. The type of information that we collect will depend on the services we provide and our relationship with you. Farosson may collect or process PD as follows (the list of which is non-exhaustive):
- Identification data – Full name, title, gender, marital status, date of birth, passport number, driving licence number, national identification number, signature
- Contact data – Personal address, telephone number, email address
- Electronic data – To the extent permitted by applicable law, we may record your electronic communications with us
- Financial data – Bank account number, credit card number
- Marketing and Communication data – Marketing and communication preferences, tracking data relating to whether you have read marketing communications from us
- Professional Information data – Position/ job title, work address, telephone number, email address
- Profile data – Username and password for our online services that you have access to, investments made by you, services requested, marketing communications responded to, survey responses
- Services data – Payment details to and from you, details of services you have provided to us or we have provided to you
- Premises security data – Records of visits to our premises, CCTV recordings
- Technical data – Your use of and interaction with our online services, your IP address, browser type and version, browser plug in types and versions, operating systemYour PD may be collected in the following manners, including :
- when you provide it to us in connection with a Farosson product or service, such as a completed investment application form
- if you are a Representative of a person, corporation or organisation that is a client or vendor of Farosson and that person, corporation or organisation provides us with your PD
- throughout the course of our relationship with you, which include where you change your details, provide additional PD, or where the services we provide change
- from public sources where you have manifestly opted to make your PD public, including via public registries or profiles, publications through websites or social media
- from third parties such as credit references agencies or government department or agencies
- from visits to our websites or through logging into any of our online services
Where you provide us with any PD of third parties, you confirm that you have obtained all necessary consents to do so and that we may collect, use and disclose such PD for the purposes as set out below.
In addition to PD provided to us, certain information related to you that is not considered PD under relevant laws may also be collected. We collect this information to improve our website and other online services. Such non-PD may include information such as your IP address, the internet browser you use, details of your interaction with our website and other types of non-PD.
Purpose and use of your PD
To the best of our knowledge and belief, we set out below the purposes which we process PD.
In connection with the ordinary course of Farosson’s business, the purposes of processing PD include but not limited :
- to communicate with you
- to verify your identity
- to process your employment applications
- to consider opening an account, or entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks
- to deliver the services you have requested, including liaising with third parties (e.g. brokers for the purposes of executing transactions) and to provide access to our technology solutions services
- to manage payments, fees and charges and to collect and recover money owed to us
- to manage our relationship with you which will include notifying you about changes to our terms of business or this Privacy Notice
- to interact with governmental or regulatory bodies or other competent national authorities
- to detect or prevent fraud and/or other criminal activity and to protect our employees and assets
- to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities
- to invite you to take part in market insight or other events, or client seminars or similar events, and
- to manage your participation in them
- to send you marketing (including by paper and electronic channels) communications and service updatesIn addition to the above, the business of Farosson requires us to process PD in relation to vendor service purposes, which include but not limited to :
- to engage you or the person, corporation or organisation you work for as a new supplier, including performing anti-money laundering, anti-terrorism, sanctions, fraud and other background checks
- to manage payments, fees and charges and to collect and recover money owed to us
- to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, and data hosting where we provide you access to our systems.
Disclosure of your PD
In connection with one or more of the purposes as set out in the section “Purpose and use of your PD” above, we may disclose PD in any jurisdiction to :
- any person directed by or consented to by you;
- other member of the Farosson Group;
- our subsidiaries, partners, related companies and/or affiliates;
- professional advisors, third parties, agents or independent contractors that provide services to any member of the Farosson Group (such as IT systems providers, platform providers, financial advisors, brokers, consultants (including lawyers and accountants);
- goods and services providers (such as providers of marketing services where we are permitted to disclose your personal information to them); intermediaries, brokers, and other individuals and entities that partner with us;
- competent authorities (including any national and/or international regulatory or enforcement body, agency, court or other form of tribunal or tax authority) or their agents where Farosson is required or allowed to do so under applicable law or regulation;
- credit reference agencies or other organizations that help us to conduct anti-money laundering and anti-terrorism financing checks and to detect fraud and other potential criminal activity; or
- any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument.
Such parties may either be in Singapore or abroad. We have taken steps to ensure that appropriate level of protection necessary to maintain the security and integrity of your PD are in place and that any transferred PD is processed only in accordance with the applicable law.
Withdrawal of consent
Upon reasonable written notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of the processing of his PD, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) processing the PD unless it is required or authorised under applicable laws.
Marketing and exercising your right to opt-out of marketing
We will not process your PD for marketing purposes if you have informed us in writing that you do not wish to receive marketing materials. You can request that we stop processing your PD for marketing purposes at any time by clicking on marketing opt-out links in any electronic marketing materials we send you, by making a written request to your usual Farosson contact or by using the contact details set out in the “Contact Us” section of this Privacy Notice.
We do not seek to obtain nor do we wish to receive personally identifiable information directly from minors. If a minor provides us with personally identifiable information, we encourage a parent or guardian of that child to contact us to have this information removed from our records and to unsubscribe the minor from future communication with us.
We will process your PD for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.
We will protect your PD using industry standard precautions. While the transference of electronic data over the internet has inherent risks, we will use reasonable precautions to ensure your PD is not subject to unnecessary risks. Some of the means through which such protection is rendered include:
- physical security around the premises of our offices where your PD may be stored;
- access to your PD is only available to the staff who require it to perform their duties; and
- installing and maintaining industry standard technology to protect our networks and data storage systems from third party interference.
However, you will appreciate that it is not for us to perfectly secure your PD from cyber-attacks, such as spyware or viruses and you will not hold us liable for any unauthorized disclosure of your personal data arising from such risks.
Access and correction of PD
Upon request, we will provide you with access to your PD or other appropriate information on your PD in accordance with the requirements of the applicable law. An administrative charge may be imposed for any access requests.
Upon request, we will update, correct an error or omission in the individual’s PD or withdraw consent to the individual’s PD that is in our possession or control in accordance with the requirements of the applicable law.
We will make all reasonable and practicable efforts to comply with your request, so long as it is consistent with the requirements of the applicable law.
- If you want to access the PD we hold on you;
- If you want to request that we amend or correct your PD;
- If you want to withdraw consent to use or disclose your PD; or
- If you have comments or queries about our Privacy Notice or other related issues;
Please contact our Data Protection Officer ("DPO") at:
Data Protection Officer
Farosson Capital Pte. Ltd.
3 Church Street
#09-02 Samsung Hub
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Rights to amend this Privacy Notice
We reserve the right to amend this Privacy Notice at any time. If material changes are made to this Privacy Notice, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.
Your continued use of this website constitutes your consent to any such changes, to the extent such
consent is not otherwise provided.