The purpose of this notification (“Data Protection Policy”) is to inform you how Atlas Asset Management Pte. Ltd. (“Atlas”) manages Personal Data (as defined below) which is subject to the Personal Data Protection Act (No. 26 of 2012) (“the Act”) of Singapore.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Atlas, as well as its representatives and/or agents (“Representatives”) (together with Atlas, collectively referred to herein as “Atlas“, “us“, “we” or “our“) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth herein.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to Atlas in respect of your Personal Data, and your consents herein are additional to any rights which Atlas may have at law to collect, use or disclose your Personal Data.

Atlas may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time on our website www.atlasam.com.sg. Please refer to our website for updated information on the handling of your Personal Data.

A. Personal Data

In this Data Protection Policy, “Personal Data” refers to any 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 we have or are likely to have access, including data in our records as may be updated from time to time.

Some examples of Personal Data you may provide to us include your name, NRIC or passport or other identification number, date of birth, telephone number(s), mailing address, email address, employment details, information relating to your financial circumstances and any other information relating to any individuals which you have provided us in any forms you may have submitted to us or documents and/or agreements you may have signed with us.

B. Collection of Personal Data

1. Personal Data may be collected by us in the following ways:

(a)  when you submit any form to us in the course of our relationship, including but not limited to declaration forms (relating to tax, investment status or otherwise), update of particulars forms, update of investment guidelines forms etc.;

(b)  when you enter into any agreement or provide other documentation or information to us in respect of or in connection with engaging or utilising our services;

(c)  when you interact with our staff, including relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;

(d) when you respond to our request for additional Personal Data;

(e)  when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;

(f)  when we seek information about you and receive your Personal Data in connection with your relationship with us, including for job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or

(g)  when you submit your Personal Data to us for any other reason.

When you browse our website, you generally do so anonymously. We do not, at our website, automatically collect Personal Data.

If you provide us with any Personal Data relating to a third party (e.g. information on your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.

C. Purposes for the Collection, Use and Disclosure of Your Personal Data

1. Atlas collects, uses and discloses your Personal Data for the following purposes:

(a)  verifying your identity;

(b)  assessing and processing any applications or requests made by you for products and services offered by Atlas;

(c)  responding to your queries and requests and handling complaints;

(d)  managing the administrative and business operations of Atlas and complying with internal policies and procedures;

(e)  facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving Atlas;

(f)  matching any Personal Data held which relates to you for any of the purposes listed herein;

(g)  preventing, detecting and investigating crime, including fraud and money- laundering or terrorist financing, and analysing and managing commercial risks;

(h)  managing the safety and security of our premises and services (including but not limited to conducting security clearances);

(i)  in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

(j) managing and preparing reports on incidents and accidents;

(k)  complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

(l)  financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;

(m)  project management;

(n)  providing media announcements and responses; and/or

(o)  any other purpose relating to any of the above.

2. In addition, Atlas collects, uses and discloses your Personal Data for the following purposes, depending on the nature of your relationship with us:

(a) If you are a client of Atlas:

(i)  facilitating the continuation or termination of the relationship and/or the provision of the investment advisory and/or investment management services to you in accordance with the mandate that you have agreed with us;

(ii)  carrying out client reviews, for example, annual reviews of your portfolio;

(iii)  to establish your risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;

(iv)  relationship management;

(v)  meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Atlas (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence);

(vi)  archival management (including but not limited to warehouse storage and retrievals);

(vii)  administering and facilitating any transactions dealing with securities, derivatives or other instruments or investments; and/or

(viii)  any other purpose relating to any of the above.

(b) If you are an employee or agent of an introducer or other intermediary:

(i)  marketing and leads management;

(ii)  processing commission remuneration; and/or

(iii)  any other purpose relating to any of the above.

(c) If you are an employee, officer or owner of an external service provider or vendor outsourced by Atlas:

(i)  managing the supply of goods and services;

(ii)  processing and payment of vendor invoices;

(iii)  complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or

(iv)  any other purpose relating to any of the above.

(d)  If you are a shareholder:

(i)  maintaining statutory registers; and/or

(ii)  any other purpose relating to the above.

(e)  If you submit an application to us as a candidate for an employment or representative position:

(i)  conducting interviews;

(ii)  processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;

(iii)  providing or obtaining employee references and for background screening;

(iv)  assessing your suitability for the position applied for;

(v)  processing staff referrals; and/or

(vi)  any other purposes relating to any of the above.

(f)  If you are an existing employee of Atlas:

(i)  providing remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, appraisals and evaluation;

(ii)  staff orientation and entry processing;

(iii)  administrative and support processes relating to your employment, including its management and termination, as well as staff benefits, including travel, manpower, business continuity and logistics management or support, processing expense claims, medical insurance applications, medical services, leave administration, training, learning and talent development, and planning and organising corporate events;

(iv)  providing you with tools and/or facilities to enable or facilitate the performance of your duties;

(v)  compiling and publishing internal directories and emergency contact lists for business continuity;

(vi)  conducting analytics and research for human resource planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;

(vii)  ensuring that the administrative and business operations of Atlas function in a secure, efficient and effective manner (including but not limited to examining or monitoring any computer software and/or hardware installed within Atlas, your work emails and personal digital and storage devices);

(viii)  compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks or surveillance and investigation);

(ix)  administering cessation / termination processes; and/or

(x)  any other purposes relating to any of the above.

(g) If you are a director of Atlas:

(i)  facilitating appointment to the Board;

(ii)  complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);

(iii)  administrative matters (including but not limited to the maintenance of statutory registers and updating of particulars with the Accounting and Corporate Regulatory Authority of Singapore);

(iv)  managing insurance programmes; and/or

(v)  any other purpose relating to any of the above.

3. If you have a Singapore telephone number(s) and have provided your Singapore telephone number(s) and indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Atlas may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

In relation to specific services or in your dealings with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

D. Disclosure of Personal Data

1. Atlas will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

(a)  Atlas’s related corporations;

(b)  counterparties and their respective banks in relation to payments, and other transactions;

(c)  companies providing services relating to insurance to Atlas;

(d)  agents, contractors or third party service providers who provide operational services to Atlas, such as courier services, telecommunications, information technology, payroll, corporate secretarial services, processing, training, market research, storage, archival or other services to Atlas;

(e)  any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving Atlas;

(f)  external banks and their respective service providers;

(g)  third party introducers;

(h)  our professional advisers such as our auditors and lawyers;

(i)  relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore and the Accounting and Corporate Regulatory Authority, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;

(j)  hotels, travel agents and foreign embassies in relation to overseas travel arrangements for staff;

(k)  brokerage houses, fund houses, registrars, custodians, nominee banks, external banks and investment vehicles in relation to asset management and investment product settlement processing;

(l)  any swap repository, trade data repository or reporting agent; and/or

(m)  any other party to whom you authorise us to disclose your Personal Data to.

E. Transfer of Personal Data Outside Singapore

To the extent that Atlas may need to transfer your Personal Data to service providers outside of Singapore (such as for data storage, data management and/or disaster recovery purposes), we will do so in accordance with the Act to ensure that a standard of protection is provided to the transferred Personal Data that is comparable to the protection under the Act,

F. Data Security

Atlas will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

G. Retention of Personal Data

Atlas will retain your Personal Data to the extent one of more of the purposes for which it was collected remains valid and for other legal or business purposes for which retention may be necessary.

H. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

1. If you:

(a)  have any questions or feedback relating to your Personal Data or our Data Protection Policy;

(b)  would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

(c)  would like to obtain access and make corrections to your Personal Data records, you can approach us through any of the avenues below:

(i)  Email us at dpo@atlasam.com.sg

(ii)  Call us at +65 6590 0299

(iii)  Contact your Relationship Manager

2. You may also write to our Data Protection Officer as follows:

Data Protection Officer
Atlas Asset Management Pte. Ltd. 80 Raffles Place
#57-01 UOB Plaza 1
Singapore 048624

3. Please note that administrative charges may be imposed in connection with any requests to obtain access and to make corrections to your Personal Data.

4. Please note that if your Personal Data has been provided to us by a third party (e.g. an introducer), you should contact such party directly to make any queries, feedback, and access and correction requests to Atlas on your behalf.

5. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Atlas may not be in a position to continue to provide its services to you, or administer any contractual relationship already in place. Any withdrawal of consent may also result in the termination of any agreements you have with Atlas and you being in breach of your contractual obligations or undertakings. Atlas’ legal rights and remedies in such event are expressly reserved.

I. Governing Law

This Data Protection Policy shall be governed by, and construed in accordance with, the laws of Singapore.