Privacy Notice | EFA Group

THIS NOTICE APPLIES TO YOU ONLY IF YOU ARE LOCATED OR RESIDING IN THE EUROPEAN UNION.

Eurofin Investments Pte Ltd, EuroFin Asia Group Pte Ltd and on behalf of funds and investment products managed or advised by Eurofin Investments Pte Ltd.(collectively “EFA GROUP”)

Effective Date: from 25 May 2018

This Privacy Notice explains how particular companies in EFA Group collect, use and disclose your personal data, and your rights in relation to the personal data it holds.

EFA Group (in this Privacy Notice, “us”, “we” and “our”) is the data controller of your personal data and is subject to the EU General Data Protection Regulation 2016/679 (the “GDPR”).

Our Privacy and Data Compliance Officer is contactable by email at compliance@efa-group.net.

This Privacy Notice supersedes any previous Privacy Notice or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

Your rights

Under the GDPR you have the following rights:

To obtain access to, and copies of, the personal data that we hold about you;
To require that we cease processing your personal data if the processing is causing you damage or distress;
To require us not to send you marketing communications;
To require us to erase your personal data;
To require us to restrict our data processing activities;
To receive from us the personal data we hold about you which you have provided to us, in a reasonable format specified by you, including for the purpose of you transmitting that personal data to another data controller; and
To require us to correct the personal data we hold about you if it is incorrect.

Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.

If you have any questions about how we use your personal data, or you wish to exercise any of the rights set out above, please contact us using the following:

By post – Attention: Data Protection Officer, Eurofin Investments Pte Ltd, 6 Raffles Quay #11-05 Singapore 048580
By email – compliance@efa-group.net
By telephone – +65 63250150

If you are not satisfied with how we are processing your personal data, you can make a complaint to https://www.eugdpr.org/.

How we collect your data

We collect your personal data in a number of ways, for example:

From the information you provide to us when you meet us;
From information about you provided to us by your company or an intermediary;
When you communicate with us by telephone, fax, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
When you complete (or we complete on your behalf) client on-boarding or application or other forms;
From other companies in EFA Group;
From your agents, representatives, advisers, intermediaries, and custodians of your assets;
From publicly available sources or from third parties, most commonly where we need to conduct background checks about you.

The basis for processing your personal data (other than with your consent), how we use that personal data and whom we share it with

( I ) Performance of a contract with you

We process your personal data because it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

In this respect, we use your personal data for the following:

To provide you with the services as set out in our specific agreement with you or as otherwise agreed with you from time to time;
To deal with any complaints or feedback you may have;
For any other purpose for which you provide us with your personal data.

In this respect, we may share your personal data with or transfer it to the following:

Your agents, advisers, intermediaries, and custodians of your assets who you tell us about;
Third parties whom we engage to assist in delivering the services to you, including other companies in EFA Group;
Our professional advisers where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, IT or public relations advisers;
Other third parties such as intermediaries who we introduce to you. We will wherever possible tell you who they are before we introduce you;
Our data storage providers.

( II ) Legitimate interests

We also process your personal data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your personal data for the following:

For marketing to you. In this respect, see the separate section on Marketing below;
Training our staff or monitoring their performance;
For the administration and management of our business, including recovering money you owe to us, and archiving or statistical analysis;
Seeking advice on our rights and obligations, such as where we require our own legal advice.

In this respect, we will share your personal data with the following:

Our advisers or agents where it is necessary for us to obtain their advice or assistance;
With third parties and their advisers where those third parties are acquiring, or considering acquiring, all or part of our business.

( III ) Legal obligations

We also process your personal data for our compliance with a legal obligation which we are under. In this respect, we will use your personal data for the following:

To meet our compliance and regulatory obligations, such as compliance with anti-money laundering laws;
As required by tax authorities or any competent court or legal authority.

In this respect, we will share your personal data with the following:

Our advisers where it is necessary for us to obtain their advice or assistance;
Our auditors where it is necessary as part of their auditing functions;
With third parties who assist us in conducting background checks;
With relevant regulators or law enforcement agencies where we are required to do so.

The categories of personal data we collect

We collect the following categories of personal data about you:

Your name and contact information such as your home or business address, email address and telephone number;
Biographical information which may confirm your identity including your date of birth, tax identification number and your passport number or national identity card details, country of domicile and/or your nationality, country of tax residency;
Information relating to your financial situation such as income, expenditure, assets and liabilities, sources of wealth, as well as your bank account details;
Information about your knowledge and experience in the investment field;
An understanding of your goals and objectives in procuring our services;
Information abouti your employment/business, education, family or personal circumstances, and interests, where relevant; and
Information to assess whether you may represent a politically exposed person or money laundering risk.

Marketing

We will send you marketing about similar services we provide, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to you.

We will communicate this to you in a number of ways including by post, telephone, email or other digital channels.

If you object to receiving marketing from us at any time, please contact us:

By post – Attention: Data Protection Officer, Eurofin Investments Pte Ltd,6 Raffles Quay #11-05 Singapore 048580
By email – compliance@efa-group.net
By telephone – +65 63250150

Retention of your data

We will only retain your personal data for as long as we have a lawful reason to do so. In particular:

where we have collected your personal data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that personal data for five years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
otherwise, we will in most cases retain your personal data for a period of seven years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.