PRIVACY STATEMENT
Collection, Use and Disclosure of Personal Data
Cornerpiece Capital Partners Pte Ltd (“CCP”) shall collect, use or disclose personal data about an individual only for purposes that is reasonably considered appropriate in the circumstances.
- CCP shall not collect, use or disclose personal data about an individual unless:
- it has obtained informed consent of the individual to the collection, use or disclosure of his/her personal data for a purpose on or before collecting the personal data (or for any other purpose, before using or disclosing the personal data) and on the individual’s request provided the business contact information of the DPO as the person who is able to answer on CCP’s behalf the individual’s questions about the collection, use or disclosure of the personal data;
- The individual is deemed to have consented to the collection, use or disclosure of personal data about the individual by CCP if the individual, without actually giving informed consent, voluntarily provides the personal data to CCP in circumstances where it is reasonable that the individual would voluntarily provide the data; or
- The collection, use or disclosure is required or authorised under the PDPA or any other written law, including compliance with CCP’s obligations to prevent money laundering and counter the financing of terrorism, as stated below.
CCP shall not require an individual to consent to the collection, use or disclosure of personal data about the individual beyond what is reasonable to provide services to that individual or obtain or attempt to obtain consent for collecting, using or disclosing personal data by providing false or misleading information or using deceptive or misleading practices.
CCP shall collect personal data about an individual without consent or from a source other than the individual only in the circumstances and subject to any condition in the Second Schedule of the PDPA.
CCP shall use or disclose personal data about an individual without consent of the individual only in the circumstances and subject to any condition in the Third and Fourth Schedules respectively of the PDPA.
An individual may give reasonable period of notice to CCP to withdraw any consent given or deemed to have been given in respect of the collection, use or disclosure by CCP of personal data about that individual for any purpose. On receipt of such reasonable notice, CCP shall inform the individual of the likely consequences of withdrawing his consent. CCP shall cease (and cause its data intermediaries and agents to cease) collecting, using or disclosing the personal data, as the case may be, unless:
- such collection, use or disclosure, as the case may be, without the consent of the individual is required or authorised under the PDPA or other written law.
- retention of such data is necessary for legal or business purposes.
Access to Personal Data
CCP shall as soon as reasonably possible provide an individual on his or her request with:
- personal data about that individual that is in the possession or under the control of CCP and information about the ways in which such personal data was or may have been used or disclosed by CCP within a year before the date of the request, except in certain circumstances as set out in the PDPA;
- A correction of an error or omission in the personal data about the individual that is in the possession or under the control of CCP, unless it is reasonably satisfied that the correction should not be made or the correction relates to a record set out in the Sixth Schedule of the PDPA. CCP shall send the corrected personal data to any other organisation to which it disclosed the personal data pre-correction within a year before the date that the correction was made unless the other organisation does not need the corrected personal data for any legal or business purpose. If CCP does not make the correction it shall record each such requested correction and full details of and reasons for the request and refusal. This record shall be kept for 5 years.
Accuracy, Retention and Protection of Personal Data
- CCP shall take reasonable efforts to ensure that:
- personal data collected by or on behalf of CCP is accurate and complete; it ceases to retain documents containing personal data or the means by which personal data can be associated with particular individuals once it is reasonable to assume that the purpose for collecting such personal data is no longer being served by retaining of the personal data or retention is no longer necessary for legal or business purposes.
CCP protects personal data in its possession or under its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
Transfer of Personal Data outside Singapore
CCP shall not transfer any personal data outside Singapore except in accordance with the PDPA.
Exceptions for prevention of money laundering and countering the financing of terrorism
- Subject to paragraph (2), and for the purposes of complying with its obligations to prevent money laundering and counter the financing of terrorism, CCP shall not be required to provide an individual client, an individual appointed to act on behalf of a client, an individual connected party of a customer or an individual beneficial owner of a client (each, an “Individual Client Party”), with:
- any access to personal data about the individual that is in CCP’s possession or under its control;
- any information about the ways in which the personal data of the individual under subparagraph (1)(a) has been or may have been used or disclosed by CCP; and
- any right to correct an error or omission of the personal data about the individual that is in CCP’s possession or under its control.
- CCP shall, as soon as reasonably practicable, upon the request of an Individual Client Party, provide the requesting individual with the right to:
- access the following types of personal data of that individual, that is in CCP’s possession or under its control:
- his full name, including any alias;
- his unique identification number (such as an identity card number, birth certificate number or passport number);
- his residential address;
- his date of birth;
- his nationality;
- in accordance with the PDPA, any other personal data of the respective individual provided by that individual to CCP; and
- in accordance with the PDPA, correct an error or omission in relation to the types of personal data set out in subparagraphs (2)(a), provided CCP is satisfied that there are reasonable grounds for such request.
- access the following types of personal data of that individual, that is in CCP’s possession or under its control:
For the purposes of complying with its obligations to prevent money laundering and counter the financing of terrorism, CCP may, whether directly or through a third party, collect, use and disclose the personal data of an Individual Client Party, without the respective individual’s consent.