By Edwin Lee
As per the PDPA, the below information maps out how Covenant Capital Pte Ltd. collects, uses, discloses, and protects the personal data you have provided to us.
What types of Personal Data do Covenant Capital collect?
Personal data is any information that relates to an identifiable individual and we may collect this information when you interact with our staffs:
1. Personal Particulars (e.g. name, address, date of birth)
2. Tax, Insurance and employment details
3. Banking information and financial details
4. Details of interactions with us (eg. Images, voice recordings, personal opinions)
5. Information obtained from mobile devices with your consent
How do we collect your Personal Data?
The below are the ways that we collect your data:
1. Investment Management Agreement forms, Risk Profile forms, Subscription forms
2. Via emails, SMSes, Whatsapps, phone calls or any other digital means to the office or its’ staffs
3. Photos and videos of you from our events; and
4. Information about your use of our services and website, including cookies and IP address
How do we use your Personal Data?
1. For General Support
a. Verify your identity before providing our services, or responding to any of your queries, feed-back and complaints
2. For our Internal Operations
a. Aid our analysis so that we can improve our services and products
b. Manage the company’s day-to-day business operations
c. Ensure that the information that we have on you is current and up to date
d. Conducting Due Diligence checks to reduce Money Laundering and Terrorist Financing Schemes
3. Financing Schemes
e. Comply with all laws and obligations from any legal authorities
f. Seek professional advice, including legal
g. Provide updates to you
Who do we share your Personal Data with?
1. Any officer or employee of the company and its related companies;
2. Third parties that works with us, such as Custodian Bank of choice, Fund Administrators for the Funds that we manage, any third party Fund’s Administrators, IT support who back up our database and other service provider
3. Relevant authorities such as government or regulatory authorities, statutory bodies, law enforcement agencies
4. Your authorized representatives and any other third-party whom you authorize the company to disclose your personal data to;
5. We require all personnel of the company and third party to ensure that any of your data disclosed to them is kept confidential and secure
6. We do not sell your Personal Data to any third party, and we shall comply fully with any duty and obligation of confidentiality that governs our relationship with you
When the company discloses your personal data to third-parties, the company will, to the best of its abilities, exercise reasonable due diligence that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where by your personal data is publicly available.
Accessing and Correction Request and Withdrawal of Consent
Please contact your advisor/banker or alternatively you can contact email@example.com should you have the following queries.
1. Regarding the company’s data protection policies and processes
2. Request access to and/or make corrections to your personal data in the company’s possession; or
3. Wish to withdraw your consent to our collection, use or disclosure of your personal data.
The company endeavours to respond to you within 30 days of the submission.
Should you choose to withdraw your consent to any or all use of your personal data, the company might not be able to continue to provide any further services or maintain further relationships. Such withdrawal may also result in the termination of any agreement or relationship that you have with us.
If you wish to make a complaint with regards to the handling and treatment of your personal data, please contact the company’s Data Protection Officer, mentioned below, directly. The DPO shall contact you within 5 working days to provide you with an estimated timeframe for the investigation and resolution of your complaint. Should the outcome of the resolution is not satisfactory, you may refer to the Personal Data Protection Commission (PDPC) for any further resolutions.
If you have any doubt, please contact Mr Tay Kian Ngiap, the PDPA Data Protection Officer for Covenant Capital Pte. Ltd. He can be reached at firstname.lastname@example.org
By accessing this website, you hereby agree to the terms listed on the website, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. Any claim relating to Covenant Capital’s website shall be governed by the laws of the Republic of Singapore without regard to its conflict of law provisions.
1. License to Use
Permission is granted to download information and materials on Covenant Capital’s website for personal, non-commercial viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:
i) modify or copy the information and materials;
ii) use the information and materials for any commercial purpose, or for any public display (commercial or non- commercial);
iii) attempt to decompile or reverse engineer any software contained on Covenant Capital’s web site;
iv) remove any copyright or other proprietary notations from the materials; or
v) transfer the materials to another person or “mirror” the materials on any other server.
All content, including but not limited to logo, tagline, graphics, images, text contents, buttons, icons, design and structure are property of Covenant Capital. All content on this website is protected by copyright, patent and trademark laws.
The Covenant Capital logo should not be used for any purpose whatsoever beyond what is available on the website, unless you have obtained written approval from us.
The materials on Covenant Capital’s website are provided “as is”. Covenant Capital makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Covenant Capital does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet web site or otherwise relating to such materials or on any sites linked to this site.
It is your responsibility to evaluate the accuracy, completeness, or usefulness of any information, advice and other content available through this website.
You should not solely rely on the information, advice and other contents available on our website for decisions on investment(s) or decision with respect to our company’s products and services. You are advised to seek additional information required for you to make sound, well-informed and reasonable decision.
In no event shall Covenant Capital or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption,) arising out of the use, inability to use or user’s reliance on the materials obtained through Covenant Capital’s web site, even if Covenant Capital or a Covenant Capital authorized representative has been notified orally or in writing of the possibility of such damage.
4. No Offer
Nothing in this website constitutes a solicitation, an offer, or a recommendation to buy or sell any investment instruments, to effect any transactions, or to conclude any legal act of any kind whatsoever. The information on this web site is subject to change (including, without limitation, modification, deletion or replacement thereof) without prior notice. When making decision on investments, you are advised to seek additional information required for you to make sound, well-informed and reasonable decision.
5. Revisions and Errata
The materials appearing on Covenant Capital’s website may include technical, typographical, or photographic errors. Covenant Capital does not warrant that any of the materials on its website are accurate, complete, or current. Covenant Capital may make changes to the materials contained on its website at any time without notice. Covenant Capital does not, however, make any commitment to update the materials.
Your privacy is very important to us and we respect your online privacy. This Policy has been developed in order for you to understand how we collect, use, communicate and disclose and make use of personal information. We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.
1. Collection and Use of Information
We may collect personal identifiable information, such as names, postal addresses, email addresses, etc., when voluntarily submitted by visitors to our website. This information is only used to fulfill your specific request, unless further permission is provided to us to use it in any other manner or for any other purpose.
2. Web Cookies / Tracking Technology
We use traffic log cookies to identify which pages are being used. This helps us analyse data about website traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
3. Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such sites, and this privacy statement does not govern such sites. You should exercise caution and review the privacy statement applicable to that particular website.
4. Distribution of Information
We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties’ products or services, which we think you may find interesting if you tell us that you wish this to happen.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the above address. We will promptly correct any information found to be incorrect.
When required by law, we may share information with governmental agencies or other companies assisting in the investigations. The information is not provided to these companies for marketing purposes.
5. Commitment to Data Security
To make sure your personal information is secured, we communicate our privacy and security guidelines to all Covenant Capital’s employees and strictly enforce privacy safeguards within the company.
Your personal identifiable information is kept secure. Only authorised employees, agents and contractors who have a direct need to access the information will be able to view this information.
We reserve the right to make changes to this policy. Any changes to this policy will be posted.
By entering this site you agree to be bound by the Terms and Conditions of Use. COVENANT CAPITAL PTE LTD (“CCPL”) is a Capital Markets License (AI/II) holder and regulated by the Monetary Authority of Singapore (‘MAS’).
By using this site you represent and warrant that you are an accredited investor or institutional investor as defined in the Singapore Securities and Futures Act (Chapter 289). In using this site users represent that they are an accredited and/or Institutional investor and use this site for their own information purposes only.