Our practices
This Privacy Notice (the “Notice”) sets out the practices that we, Euro Asia Asset Management Pte. Ltd. (where “we”, “us” “our” and “EAAM” shall refer collectively to Euro Asia Asset Management Pte. Ltd. and its affiliates, officers, representatives and agents) adopt in respect of our collection, use and disclosure of personal data pursuant to the Personal Data Protection Act 2012 of Singapore.

EAAM is committed to the protection of your privacy and personal data, and we will take reasonable steps to protect your personal data against unauthorised disclosure.

You may visit and browse our website without having to provide any personal data.

Collection, use and disclosure of your personal data
In this Notice , “personal data” refers to any data or information, whether true or not, about an individual who can be identified, whether from that data or information alone, or from that data or information and any other information to which an organisation has or is likely to have access to.

Examples of such personal data may include your name, government-issued unique identifiers such as NRIC and passport numbers, contact details (e.g. email addresses and telephone numbers), bank account details, signatures, employment, education, and income details, date/place of birth and any other information relating to yourself or other individuals that you have provided us or authorised to be provided to us in any form of your interaction with us.

EAAM generally collects your personal data in the following ways:

(a)             when you submit any form or contact us in relation to our products, services or job  postings;

(b)            when you interact with our staff (for example, through emails, telephone calls, voice or text messages, letters, in-person meetings, or video conferencing);

(c)             through CCTV recordings within our premises;

(d)            when you have been referred by our partners and other third parties;

(e)             when we seek information from third parties about you in the course of our KYC procedures to fulfil our AML/CFT obligations; and

(f)               when you submit any personal data to us for any other reasons.

Purposes for collection, use and disclosure of personal data
EAAM ensures that the use of personal data is restricted to the purpose(s) for which such data has been collected. Depending on the nature of your relationship with us, such purposes include:

(a)             processing transactions for and on your behalf in relation to our products or services;

(b)            opening, administering and maintaining any accounts with us and/or any service providers in relation to our products and services;

(c)             providing you with updates relating to our products or services;

(d)            responding to any enquiries, requests, feedback and/or instructions from you;

(e)             to obtain feedback or conduct market research, surveys and/or analysis for us to review, develop and improve existing/future products and services;

(f)               managing our safety and security (including conducting CCTV surveillance at our premises);

(g)             compliance with applicable laws, rules, regulations, regulations, guidelines, industry codes, judgments, orders, requests, notices or directions issued by any court, legal or regulatory bodies or relevant exchanges, whether in Singapore or otherwise;

(h)            assisting with law enforcement and investigations conducted by governmental authorities;

(i)                to process any job applications submitted to us;

(j)                other purposes related to any of the aforementioned purposes.

EAAM may, from time to time, specifically notify you in the course of your interactions with us regarding other purposes for which we collect, use or disclose your personal data.

Disclosures of your personal data
Subject to applicable law, we may disclose your personal data to the following third parties:

(a)             third party service providers supporting our provision of products and services (including custodians and fund administrators); 

(b)            our professional advisers (including our auditors and legal counsel);

(c)             governmental authorities or law enforcement agencies (including the Monetary Authority of Singapore and the Inland Revenue Authority of Singapore);

(d)            (where you have applied for a role with us) your employers and referees;

(e)             distributors of our products and services; and

(f)               any other party to whom you have expressly/impliedly consented for us to disclose your personal data to.

EAAM shall ensure that disclosure of your personal data to such third parties is made only to the extent that it is necessary or expedient for the provision of our services or products to you, the management/administration of your investments, any transactions and dealings with you, or for the purposes set out in this Notice.

Retention of personal data
We will generally retain your personal data for the duration of your relationship with us and for such period as may be necessary for any legal and/or business purpose, and delete your personal data where no legal or business purpose continues to apply.

Your consent
By interacting with us, submitting information to us, responding to any of our job postings or signing up for our products or services, you agree and consent to us, collecting, using, disclosing and sharing your personal data, and disclosing such personal data to our service providers and relevant third parties in the manner described in this Notice. Such consent shall continue to subsist until we receive written communication from you of the withdrawal of your consent.

This Notice supplements, but does not supersede nor replace any other consent you may have previously provided to EAAM in respect of your personal data, and your consent herein are additional to any rights which we may have under law to collect, use or disclose your personal data.

If you provide us with any personal data relating to a third party (e.g., for individuals: information on your spouse, parents, employers or and/or referees, and for legal entities: information on your officers, authorised signatories and/or shareholders), by submitting such information to us for any purpose, you represent to us that you have obtained the consent of such third parties to provide us with their personal data for such purpose and all other reasonably related purposes.

Accessing, updating or making enquiries about your personal data
Please contact the Data Protection Officer of EAAM by email at contact@euroasia-am.com if you: (a) have any enquiries, comments or suggestions about the collection, use and/or disclosure of your personal data or this Notice; or (b) would like to obtain access to and/or update the personal data we have in relation to you, or to withdraw any consent you have provided to us previously.

Changes to this Notice
As we review and update our security measures regularly in compliance with changing regulatory developments and in light of current and emerging technologies, this Notice may be subject to changes from time to time without prior notice.

Please check back regularly for any updated information to ensure you are aware of how your personal data is being handled.

By continuing 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 fully agreed to such changes.

Governing law
This Notice shall be governed by and construed in accordance with Singapore law. Any dispute arising out of or in connection with this 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.