Amova Asset Management Asia Limited Privacy Policy ("Privacy Policy”)
Amova Asset Management Asia Limited ("Amova Asia" or the "Company") is committed to maintaining the privacy and security of your personal formation (also referred to as ‘personal data’). This Privacy Policy identifies how we may collect, process, use and disclose your personal data, including in connection with your use of our website (https://sg.amova-am.com) and dependent pages (collectively, the "Site").
We may update this Privacy Policy at any time by posting the amended version on the Site with the effective date of the updated version. By using our Site or requesting information from us after we make such changes to this Privacy Policy, you are deemed to have accepted such changes. We may also provide other privacy notices on specific occasions when we are collecting or using your personal data in ways that materially differ from what we have described here.
This Privacy Policy also serves as a Data Protection Notice under Singapore’s Personal Data Protection Act (PDPA).
PURPOSES OF COLLECTION, USE OR DISCLOSURE OF PERSONAL DATA
Amova Asia may collect, use, process and/or disclose your personal data for one or more of the following purposes:
- updating and maintaining the register(s) of the relevant scheme(s) that you have subscribed to;
- processing instructions from you or persons acting on your behalf or processing your trades or those of persons acting on your behalf;
- complying with any applicable rules, laws or regulations, regulatory policies, guidelines or industry codes, orders, directions or requests issued by any court, legal or regulatory bodies (whether in Singapore or otherwise) including rules and regulations relating to anti-money laundering and countering the financing of terrorism and the carrying out of audit checks, surveillance and investigation;
- preventing, detecting and investigating crime, offence or unlawful activity including but not limited to fraud, money-laundering, terrorist financing and bribery, and analysing and managing commercial risks;
- complying with any applicable treaty or agreement with or between Singapore and a foreign jurisdiction;
- fulfilling a judgment or order of court or of any other tribunal within Singapore and in an applicable foreign jurisdiction;
- providing client-related services, including providing customer support, responding to queries or feedback given by you or persons acting on your behalf, and generating, communicating with and disseminating notices, reports, correspondence, statements, invoices, confirmations and advices to you or persons acting on your behalf;
- verifying your identity or the identity of persons acting on your behalf;
- reviewing and approving your account(s), and the conduct of initial and anticipatory credit checks and assessments, relevant checks, ongoing assessment and verification of ongoing credit worthiness and standing;
- legal claims, actions or proceedings including but not limited to drafting and reviewing documents, obtaining legal advice and facilitating dispute resolution or exercising or enforcing the rights of Amova Asia and/or its related corporations under contract or pursuant to applicable laws and regulations;
- administering, operating, processing or managing units, any scheme or the umbrella structure of any sub-fund;
- meeting or complying with Amova Asia’s and/or its related corporations’ internal policies and procedures;
- handling feedback, queries or complaints;
- maintaining the security of premises including but not limited to the use of forms of surveillance such as security cameras;
- facilitating any proposed or actual business assignment, transfer, participation or sub-participation in any of Amova Asia’s and/or its related corporations’ rights or obligations in respect of your relationship with such entity(ies);
- for marketing activities such as providing you with email alerts, event registrations, social media activity, and other notices concerning Amova Asia’s and/or its related corporations’ products or services, or events or news that may be of interest to you, including through targeted messages and advertisements on or through our websites and apps and through third-party websites and apps;
- improving our website and presenting its contents to you in a tailored and personalised manner;
- for market analysis and product development;
- all purposes reasonably related to one or more of the foregoing; and
- conducting general administration in relation to the foregoing.
Amova Asia also handles personal data in accordance with applicable global privacy standards, including Regulation S-P where relevant, which imposes strict confidentiality and security obligations on financial institutions.
Where you provide personal data relating to third party individuals to Amova Asia (e.g. where you are an institutional investor), you warrant that the prior consent of such third party individual, which will allow Amova Asia to collect, use and disclose that personal data in the manner and for the purposes described above, has been obtained, and you consent to and acknowledge all such collection, use and disclosure on behalf of that third party individual. You shall, upon request from Amova Asia, promptly provide a copy of the document(s) containing or evidencing such prior consent obtained from such third party individual.
Amova Asia will notify you of the purposes for which your personal data is collected, used, or disclosed at or before the time of collection, unless such purposes are already apparent or previously disclosed.
THIRD PARTIES WHO MAY BE PROVIDED WITH PERSONAL DATA
You consent and acknowledge that personal data may be disclosed and transferred to the following parties, in Singapore or in a foreign jurisdiction, for the purposes set out under the section “Purposes of Collection, Use or Disclosure of Personal Data”:
- any related corporations of Amova Asia;
- any person or entity including government authorities, regulatory bodies, courts and tribunals to whom Amova Asia and/or its related corporations are under an obligation to make disclosure pursuant to any domestic or foreign legal process, legal obligation or regulatory obligation; and
- any agent, contractor or third party service provider who provides administrative, mailing, data processing, business process, human resource, information technology or other services to Amova Asia and/or its related corporations in connection with the operation of the business of Amova Asia and/or its related corporations or the administration and operation of any scheme and/or the umbrella structure of any sub-fund.
Amova Asia will not disclose your personal data to unaffiliated third parties for their own purposes unless you have expressly consented or such disclosure is permitted or required by law.
Where personal data is transferred outside Singapore, Amova Asia will ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to the protection under the PDPA.
CONSENT WITHDRAWALS
You may, after consenting to the collection, use and disclosure of your personal data, withdraw your consent by giving notice in writing to Amova Asia’s Data Protection Officer at the contact details set out below.
You should note that a notice of withdrawal of consent submitted by you, or by any third party individuals whose personal data you have provided to Amova Asia (e.g. your beneficial owners, directors or authorised signatories, if you are not an individual), may, among other things:
(i) be deemed to be a request for redemption of all units held by you; and/or
(ii) result in you no longer being a part of our mailing list.
You may request that we do not disclose your personal data to unaffiliated third parties for purposes beyond those necessary to provide our services or comply with legal obligations. This request constitutes an opt-out under applicable privacy standards, including Regulation S-P. Amova Asia will honor such opt-out requests to the extent feasible and consistent with our regulatory obligations. To exercise this right, please contact our Data Protection Officer at [email protected].
ACCESS AND CORRECTION OF PERSONAL DATA
You may request access to your personal data held by Amova Asia and seek correction of any inaccurate or incomplete data, subject to applicable legal and operational limitations. Amova Asia will respond to such requests in accordance with the PDPA and its internal procedures.
ACCURACY OF PERSONAL DATA
You undertake to ensure that all information provided to Amova Asia is true, accurate and complete and that changes to any such information shall be notified to Amova Asia in a timely manner.
Amova Asia maintains procedures to update personal data and encourages clients to communicate changes promptly, in line with Regulation S-P’s expectations for maintaining data integrity.
PROTECTION OF PERSONAL DATA
Amova Asia is committed to safeguarding your personal data. We maintain physical, electronic, and procedural safeguards to protect against unauthorized access, use, or disclosure. Access to personal data is restricted to employees who need it to perform their duties, and all staff are trained on confidentiality obligations.
RETENTION OF PERSONAL DATA
Amova Asia retains personal data for as long as you maintain an ongoing relationship with us, as required by law, for the duration of any legal retention requirements and relevant limitation periods or as long as necessary to fulfill the purposes for which it was collected.
UPDATES TO THIS PRIVACY POLICY
Amova Asia may periodically update this privacy policy. In line with Regulation S-P, we may also provide annual reminders or notices about our privacy practices to ensure transparency and continued compliance.
DATA PROTECTION OFFICER DETAILS
If you have any queries or comments on the use of your personal data, or if you wish to lodge a privacy-related complaint, please contact Amova Asia’s Data Protection Officer at:
Data Protection Officer
Email address: [email protected]
You may also contact the Data Protection Officer to exercise your opt-out rights regarding unaffiliated third-party disclosures, consistent with Regulation S-P.
Amova Asia will honor such requests to the extent feasible, consistent with Regulation S-P’s opt-out provisions.