DATA PRIVACY POLICY AND PERSONAL INFORMATION COLLECTION STATEMENT
This Data Privacy Policy and Personal Information Collection Statement (“Privacy Policy”) outlines how Huatai Securities (Singapore) Pte. Limited (“Huatai”, “we”, “us”, “our” or derivatives therefrom) collects, uses and discloses the personal data of Data Subjects (as defined below) who use our Services in their own names or on behalf of our Client. Huatai and its holding companies, subsidiaries, affiliates or business partners, whether in Singapore or elsewhere (“Associates”) recognise their responsibilities in relation to the collection, holding, processing, use and/or transfer of its Data Subject’s personal data under the Singapore Personal Data Protection Act 2012 (“PDPA”). This Privacy Policy should be read together with, and forms part of, our Terms and Conditions for Accredited, Institutional and Expert Investors for Singapore (“Terms”) (as amended or supplemented from time to time). Unless otherwise defined herein, capitalised terms in this Privacy Policy have the meaning given to them in those Terms.
The term “Data Subject” refers to the individual who is the subject of the personal data collected, held, processed, used and/or disclosed by Huatai.
The term “personal data” is as defined under the PDPA, and generally refers to any data (i) relating directly or indirectly to the Data Subject; and (ii) from which it is practicable for the identity of the Data Subject to be directly or indirectly ascertained.
This Privacy Policy supplements but does not supersede or replace any other consents the Data Subject may have previously provided to us in respect of their personal data, and the Data Subjects’ consents herein are additional to any rights which Huatai may have at law to collect, hold, process, use and/or disclose such personal data. The Data Subject may withdraw their consent to the collection, use or disclosure of personal data for any or all of the purposes communicated to the Data Subject, by sending us a notice in writing to the address in the section on “Access and correction of personal data”. On receipt of such notice, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
Please note, however, that failure by the Data Subject to supply personal data and/or the absence of or withdrawal of consent may result in Huatai being unable to open or continue operation of the relevant accounts on behalf of the Data Subject (the “Accounts”), to provide the information, products or services as requested by the Data Subject or comply with any laws or guidelines issued by regulatory or other authorities.
1. Types of personal data collected: The personal data we collect varies upon the nature of the Services provided or used, and our interactions with individuals. We collect the following categories of information that may constitute personal data:
a) Name, contact information and other identifiers: identifiers such as name, Account name, password, address, phone number, birth date, email address and other online identifiers.
b) Device information: internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, and mobile advertising identifiers.
c) Communications and requests: direct communication, web forms, online polls, or interactions with our Services. We collect and maintain a record of the Data Subject’s contact details, communications and our responses.
d) User content: if a Data Subject posts content on the Services, interacts with any user of our Services or submits feedback and comments to us (“User Content”), we may maintain a record of the Data Subject’s User Content, including the location, date and time of submission, as well as any other information contained in that User Content.
e) ransaction information: Details of Transactions including the names of ultimate beneficiaries and persons who give instructions in relation to any Transaction.
f) Cookie data: as explained in more detail later in this Privacy Policy.
g) Marketing, surveys and events: if the Data Subject signs up to receive news, updates, offers and other marketing communications from us, we may collect their name, contact information and information about their preferences.
h) Location data: location information about a particular individual or device, general location information (for example, the Data Subject’s IP address may indicate their more general geographic region).
i) Profiles and inferences: inferences drawn from any of the information identified above to create a profile reflecting a Data Subject’s preferences.
2. Purpose: From time to time, it is necessary for Huatai to collect the Data Subject’s personal data which may be used, stored, processed, transferred, disclosed or shared by Huatai for any one or more of the following purposes (“Purposes”), including
2.1 the daily operation of the facilities, services or products provided to the Data Subject and the Account;
2.2 designing financial services or related products for the Data Subject’s use;
2.3 processing and evaluating any applications or requests made by the Data Subject for facilities/products/services offered by Huatai or its Associates;
2.4 providing subsequent services to the Data Subject, including but not limited to administering the facilities/products/services provided by Associates and policies issued herewith;
2.5 any purposes in connection with any claims made by or against or otherwise involving the Data Subject in respect of any products/services provided by Huatai and/or its Associates;
2.6 conducting one-off or regular credit checks, maintaining credit history and ensuring ongoing credit worthiness;
2.7 assisting other institutions to conduct credit checks and collect debts;
2.8 determining the amount of indebtedness owed to or by the Data Subject;
2.9 collecting amounts outstanding from the Data Subject and those providing security for the Data Subject’s obligation;
2.10 evaluation of the Data Subject’s investment experience (if any), investment objective, risk appetite, financial condition and financial needs;
2.11 offering, providing and marketing the products/services of Huatai or its Associates (refer to “Use and provision of personal data in direct marketing” below) to the Data Subject, and administering, maintaining, managing and operating such products/services;
2.12 making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Singapore or elsewhere;
2.13 carrying out services in connection with the operation of Huatai and/or its Associate’s business;
2.14 complying with the obligations, requirements or arrangements for disclosing and using data that apply to Huatai or that it is expected to comply according to:
a) any law binding or applying to it within or outside Singapore existing currently and in the future;
b) any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial service providers within or outside Singapore existing currently and in the future;
c) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial service providers that is assumed by or imposed on Huatai by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
2.15 complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within Huatai and its Associates and/or any other use of data and information in accordance with any regulations for compliance with sanction purposes or prevention or detection of money laundering, terrorist financing or other unlawful activities;
2.16 enabling an actual or potential assignee of all or any part of the business and/or asset of Huatai or participant or sub-participant of Huatai’s rights in respect of the Data Subject, to evaluate the transaction intended to be the subject of the assignment, participation or sub-participation;
2.17 managing, monitoring and assessing the performance of any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or securities clearing or other services to Huatai in connection with the establishment, operation, maintenance or provision of facilities, products and services; and
2.18 other purposes directly relating to any of the above.
3. Transfer of personal data: Huatai will duly keep all personal data of the Data Subject confidential but, subject to the provisions of any applicable law, may provide or disclose such data to:
3.1 any of Huatai’s Associates, third party financial institutions, third party securities and investment services providers, Huatai’s co-branding partners, charitable or non-profit making organisations, the Data Subject’s broker, industry associations or federations, fund manager company or financial institutions within Singapore or elsewhere and in this regard the Data Subject consents to the transfer of their data outside Singapore;
3.2 credit reference agencies to ensure the credit worthiness of the Data Subject, creating and maintaining credit and risk related models, providing the personal data to credit reference agencies for the purposes of conducting credit checks and other directly related purposes, determining the amount of indebtedness owed to or by the Data Subject and collection of amounts outstanding from the Data Subject and those providing security for the Data Subject’s obligations;
3.3 any person (including private investigators) in connection with any claims made by or against or otherwise involving the Data Subject in respect of any products/services provided by Huatai and/or its Associates;
3.4 any agent, contractor or third party who provides administrative, telecommunications, computer, payment or securities clearing, technology or other services (including direct marketing services and audit, legal or other professional services) to Huatai and/or its Associates in Singapore or elsewhere, who also has a duty of confidentiality to the same extent as Huatai, as mentioned above;
3.5 any actual or proposed assignee, transferee, participant or sub-participant of Huatai’s rights or business; and
3.6 any government department, other appropriate governmental or regulatory authority, or self-regulatory industry body or associations of financial services providers, or other persons to whom Huatai is under a duty to disclose, in Singapore or elsewhere.
For Huatai’s policy on using the Data Subject’s personal data for marketing purpose, please see the section below “Use and provision of personal data in direct marketing”.
Transfer of the Data Subject’s personal data will only be made for one or more of the Purposes specified above. We ensure that third parties who receive any Data Subject’s personal data will handle such personal data as required by the PDPA and applicable laws, such as by putting in place appropriate contracts with third parties to protect your personal data.
4. Use and provision of personal data in direct marketing: Huatai intends to use the Data Subject’s data in direct marketing and Huatai requires the Data Subject’s consent (which includes an indication of no objection) for this purpose. In light of this purpose, Huatai intends to:
4.1 use the Data Subject’s name, contact details, products and services portfolio information associated with the Account, transaction pattern and behavior, financial background and demographic data held by Huatai from time to time for direct marketing; and
4.2 conduct direct marketing in relation to the following classes of products and services that Huatai, or its Associates may offer:
a) financial services, securities, investment services, insurance services, retirement planning services and other wealth management related products and services;
b) reward, loyalty, co-branding or privileges programmes and related products and services;
c) wealth management or non-wealth management related seminars, events or other activities;
d) products and services offered by Huatai’s co-branding partners; and
e) donations and contributions for charitable and/or non-profit making purposes.
4.3 The above products and services may be provided by :
a) Huatai and/or any of Huatai’s Associates;
b) third party financial institutions, insurers, insurance agents, insurance brokers, securities and investment services providers;
c) the business partners / co-branding partners of Huatai and/or Associates providing the product and services set out in (4.2) above;
d) third party reward, loyalty or privileges programme providers supporting Huatai or any of the above listed entities; and/or
e) charitable or non-profit making organisations.
4.4 In addition to marketing the above products and services, Huatai also intends to provide the data described in (4.1) above to all or any of the persons described in (4.3) above for use by them in marketing those products and services, and Huatai requires the Data Subject’s written consent (which includes an indication of no objection) for that purpose;
4.5 Huatai may receive money or other property in return for providing the data to the other persons in (4.4) above and, when requesting the Data Subject’s consent or no objection as described in (4.4) above, Huatai will inform the Data Subject if it will receive any money or other property in return for providing the data to the other persons.
Before using the Data Subject’s personal data for the purpose and providing it to the transferees as set out above, Huatai must obtain the Data Subject’s written consent, and only after having obtained such written consent, may use and provide the Data Subject’s personal data for any promotional or marketing purpose.
The Data Subject may withdraw their consent to the use and provision of personal data for direct marketing.
The Data Subject may withdraw their consent by sending a notice to Huatai in writing to the address in the section on “Access and correction of personal data”. Huatai shall, without charges to the Data Subject, ensure that the Data Subject is not included in future direct marketing activities.
5. Cookies and analytics: Cookies are small alphanumeric identifiers or small data text files that are sent from a server during a browsing session and is placed on the Data Subject’s computer. When we refer to “cookies” we include other technologies with similar purposes, such as pixels, tags and identifiers.
5.1 We use cookies or similar technologies, which may be provided by third parties, on our Services to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Services and the emails that we send, and to personalise content and provide more relevant information (including advertisements or marketing materials). We may combine the information we collect via these technologies with other information, including personal data.
5.2 The Data Subject may indicate and choose their cookies preferences at any time through their browser settings, such as to accept certain cookies but reject others.
5.3 Our policy relating to cookies complies with the PDPA and applicable laws. There are some internet activities that cannot take place without cookies collecting, using or disclosing personal data, such as those relating to security and network management (“Necessary Cookies”). Necessary Cookies also for example allow Data Subjects to navigate back and forth between pages without losing their previous actions from the same session. For such Necessary Cookies, if Data Subjects use any of our websites, they will be considered to have consented to the collection of personal data by such Necessary Cookies.
5.4 We will get Data Subjects’ express consent where our cookies collect personal data in the course of internet activities which Data Subjects have not clearly requested for, or where Data Subjects have not voluntarily provided their personal data, or where personal data collected from such cookies are used for informed or marketing materials requested for and/or directed at Data Subjects.
6. Security: The security of Data Subjects’ personal data is important to Huatai. We have put in place safeguards to protect the personal data we collect from unauthorised access, use and disclosure, and we take steps to ensure that all of our employees, agents, contractors and other third parties have similar adequate measures in place. We also have procedures to deal with any suspected personal data breach, and we will notify the Data Subject and any applicable regulator when we are legally required to do so. However, we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge Data Subjects to take steps to keep their personal data safe, such as choosing a strong password and closing their web browser when they have finished using the Services.
7. links to third-party websites: Our Services provide links to various websites operated by third parties including, but not limited to, third-party sites that may display Huatai’s trademarks. This Privacy Policy does not apply to third-party websites that are accessible through the Services, unless such website directs Data Subjects to this Privacy Policy. When Data Subjects click on one of these links, they will be transferred out of the Services and connected to the website of the organisation or company that maintains that website. Even if an affiliation exists between our Services and a third-party website, we exercise no control over and assume no responsibility for linked websites. Each of these linked websites maintains its own independent privacy and data collection policies and procedures. We encourage Data Subjects to read the privacy policies of those other websites to learn how they collect, use, share, and secure their information before providing any personal data.
8. Access and correction of personal data: Under the PDPA, the Data Subject has the right to ascertain whether Huatai holds the Data Subject’s personal data, to obtain a copy of the said data, and to correct any data that is inaccurate or has subsequently been changed. The Data Subject may also request Huatai to inform the Data Subject of the type of personal data held by Huatai.
All requests for access to, correction and changes of the Data Subject’s data held by Huatai or for information regarding policies and practices and kinds of data held by Huatai should be addressed in writing to:
Data Privacy Officer
Huatai Securities (Singapore) Pte. Limited
8 Marina Boulevard, #08-02, MBFC Tower 1, Singapore 018981
Or email to htsgdataprivacy@htsc.com
A reasonable fee may be charged to offset Huatai’s administrative and actual costs incurred in complying with the Data Subject’s data access requests mentioned above.
9. Recordkeeping: After termination of service or closure of the relevant Account, Huatai shall continue to hold personal data relating to the Data Subject for a period of time as Huatai considers prudent or such other period as prescribed by applicable laws and regulations.
10. Circulate to all Data Subject(s): Please circulate this document to any and all Data Subject(s) relating to your Account(s) at Huatai.
11. Changes to information: It is important that the information we hold about Data Subjects is accurate and current. Data Subjects should keep us informed as soon as possible if their personal data changes or is inaccurate during their relationship with us by using the contact details set out above under “Access and correction of personal data”.
12. Contact us: If Data Subjects have any concern about our privacy practices, they may contact us using the contact details set out above under “Access and correction of personal data”.
13. Effect of Privacy Policy and changes thereto: This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : [15 September 2023]
Last updated : [15 September 2023]
Should there be any inconsistencies between the English and Chinese versions of this document, the English version shall prevail.
