Privacy Policy of ITUS

1.1 This data protection notice (the “Notice”) outlines how we collect, use, store and disclose your personal data in accordance with the Personal Data Protection Act (“PDPA”).  The PDPA strives to protect personal data of individuals.  Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data.

1.2 This Notice supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Notice to ensure that this Notice is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Notice shall apply. For the avoidance of doubt, this Notice forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

What is Personal Data?

1.3 Personal data refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access.  Depending on your relationship with us (e.g. prospective or current client, employee or business partner), the personal data about you that we may collect, use, store and disclose include:

  1. your contact details like your name, passport or other identification numbers, contact numbers, address, email;
  2. your personal details enabling us to evaluate and manage your client, employment or business relationship with us, e.g. your work experience, education, date of birth, bank details;
  3. your personal details enabling us to analyse your situation, determine suitable strategies and execute respective action, e.g. family status, financial status, transaction history;
  4. photos and videos of you from our events or office surveillances; and
  5. information about your use of our services, website and app, including cookies and IP address.

We Keep Your Personal Data Confidential and Secure.

1.4 At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and procedural safeguards to protect your personal data against loss, misuse, damage and unauthorized access, modifications or disclosures.

Purposes for Collection, Use and Disclosure of Your Personal Data

1.5 We collect, use and/or disclose your personal data to provide enhanced asset management services and/or family office services, including operations for these purposes. This may include the following (non-exhaustive) as applicable to the relationship we have with you:

  1. any other purposes related to the above purposes.
  2. maintaining records of our interactions with you, through telephone recordings, documentation (hard copy and electronic), app and
  3. internal reporting and analysis related to our business operations;
  4. responding to your queries and requests and handling complaints;
  5. updating you on developments in our services and special happenings;
  6. evaluating your performance as our employee or business partner;
  7. reporting to you as our client on your financial situation and our performance of our services to you;
  8. managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;
  9. assessing and processing any applications, requests and instructions for financial products and services offered by us and/or other financial institutions or product providers for you as our client;
  10. analysing your financial situation and determining financial strategies and products suitable for you as our client;
  11. evaluating your standing, resources and capabilities to enter or maintain a relationship with you as a client, employee, business partner or other;
  12. for detecting, conducting any form of investigation and preventing fraudulent, prohibited or illegal activities and analysing and managing commercial risks, including those relating to disputes, billing, fraud, offences, prosecutions etc;

1.6 If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will seek your consent.

How We May Collect Your Personal Data

1.7. Generally, we may collect your personal data ourselves or through third parties in ways including the following:

  1. when you submit your personal data to us for any other reason.
  2. when you respond to our requests for additional personal data; or
  3. when you access our website and app;
  4. when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;
  5. when you communicate with us by email or telephone, your emails will be retained and we may monitor and/or record your voice calls to us;
  6. when you interact with our employees, in particular with your Relationship Manager;
  7. during our preliminary discussions with you to establish a new client relationship, enter into employment or for any other business relationship;

1.8 Without prejudice to the generality of the foregoing clauses, we may collect information about the computer, mobile telephone, smart phone or other device you use to access our websites and apps.

1.9 When you access our website and app you generally do so anonymously. Your activity may however be monitored by Cookies or other navigational data. “Cookies” are small data files sent to your browser to store and track information about you when you enter our websites and apps. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. Our website and app use cookies to distinguish you from other users of our website and app. This helps us to provide you with a good experience when you browse our website and app, and also allows us to improve our site. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser and app. However, you may not be able to enter certain part(s) of our website and app.

1.10 You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please reach out to your Relationship Manager or our Compliance Officer.

1.11 Where you provide us personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

Who We May Disclose Your Personal Data To

1.12 Generally, we shall protect and keep confidential your personal data. We will disclose your personal data only with your consent and for purposes that you have been informed about.

1.13 However, subject to applicable laws, we may disclose your personal data for the purposes set out above to parties such as those described below:

  1. our affiliates, associated entities and any of their branches and offices which may also include entities and activities overseas;
  2. banks, financial institutions, credit card companies and their respective service providers;
  3. companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies;
  4. agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival;
  5. our professional advisers such as our auditors and lawyers; and
  6. regulators and authorities.

1.14 When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available, or where use/disclosure of your personal data is otherwise legally mandated and exempted.

1.15 If your personal data has to be transferred overseas, we will, where legally required, inform you of the extent to which your personal data will be protected, in the foreign jurisdiction(s) to which it will be transferred.

How Long We Keep Your Personal Data For?

1.16 We shall store your personal data for as long as necessary to fulfil the purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required.

Queries, Access/Correction Requests and Withdrawal of Consent.

1.17 If you:

  1. have queries about our data protection processes and practices;
  2. wish to withdraw your consent to our collection, use or disclosure of your personal data; or
  3. wish to request access to and/or make corrections to your personal data in our possession or under our control,

please submit a written request (with supporting documents, if any) to our Data Protection Officer at contact@itusam.com. Our Data Protection Officer shall strive to respond to you within 30 days of your submission.

1.18 Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

If You Have A Complaint

1.19 We are committed to protecting your personal data.  If, however, you should be dissatisfied with our handling of your personal data, please submit a written complaint containing details of your dissatisfaction to our Chief Operating Officer.

1.20 Our Data Protection Officer shall acknowledge in writing the receipt of your complaint within 2 business days. Within 10 business days, our Data Protection Officer shall contact you to provide you with an estimated timeframe for our investigations and resolution of your complaint. If your complaint requires more time beyond such estimation to resolve due to its complexity, our Data Protection Officer shall inform you accordingly on or before the expiry of the original estimated time frame.

1.21 In the event that our Data Protection Officer’s investigations conclude with a solution that is dissatisfactory to you, you may refer your complaint to the Personal Data Protection Commission or consider dispute resolution by way of mediation.

Disclaimer

Please read this page before proceeding, as it explains certain restrictions imposed by law on the distribution of this information and the countries in which our products are authorized for sale.  It is your responsibility to be aware of and to observe all applicable laws and regulations of any relevant jurisdiction.

1. General

ITUS ASSET MANAGEMENT PTE LTD (“ITUS”) is a Singapore Registered Fund Management Company. ITUS holds a Capital Markets Services (CMS) License to conduct regulated activities in Fund Management and Advisory for Accredited Investors and Institutional Investors respectively, as defined under Section 4A of the Singapore Securities and Futures Act (Cap 289).

2. Description of Website

Access to and use of the www.itusam.com website (the “Site”) and the materials found on it (the “Content”), including the investment products referred to on it (the “Investment Products”) are subject to the following terms and conditions (these “Terms”).  By clicking the confirmation at the bottom of these Terms, you signify that you have read, understood and accepted these Terms.

This Site offers information about ITUS.  ITUS may update, revise, delete or modify information on this Site without notice. Information should only be considered current as of the time of initial publication on this Site or as otherwise stated on this Site without regard to the date on which you may access the information.

3. Restricted Access

By using this Site, you represent and warrant that you are an Accredited Investors or Institutional Investors as defined under Section 4A of the Singapore Securities and Futures Act (Cap 289).

This Site, the Content and the Investment Products are not directed at or intended for distribution to any person (or entity) who is a citizen or resident of (or located or established in) any jurisdiction where the use of the Site (or the purchase or sale of the Investment Products) would be contrary to applicable law or regulation or would subject ITUS to any registration or licensing requirement in such jurisdiction.  Persons who wish to access this Site are required by ITUS to inform themselves about and to observe any legal or regulatory restrictions which may affect their eligibility to access the Site or to subscribe for interests in the Investment Products.  Professional advice should be sought from a financial or other professional adviser regarding the suitability of the product.

Only “Accredited Investors” and/or “Institutional Investors” as defined in the Securities and Futures Act (Chapter 289) of Singapore may subscribe for the Investment Products.

4. No Offer

The Content is provided for information purposes only and does not constitute a solicitation or offer, or advice or recommendation, to buy or sell interests in any Investment Products, to effect any transactions, or to conclude any transaction of any kind whatsoever.

None of the information presented is intended to form the basis for any offer or recommendation, or have any regard to the investment objectives, financial situation or needs of any specific person. No reliance may be placed for any purpose on the information provided in this presentation or the accuracy or completeness thereof and no responsibility can be accepted by ITUS and/or any of its affiliated entities to anyone for any action taken on the basis of such information.

Potential investors should read the terms and conditions in the relevant offering materials carefully before any investment decision.  Please note that certain investment products can only be redeemed on a monthly or quarterly basis with initial lockup periods enforced. Investors redeeming before a specified date may be subjected to a redemption fee.

5. Monitoring By ITUS

Your use of the services on this Site may be monitored by ITUS, and the resultant information may be used by ITUS or its affiliates for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organization.

6. No Commercial Exploitation

Except as stated in this section 6, the copyright and other intellectual property rights in the Content are owned by ITUS.  Any use of the Content for any purpose is accordingly prohibited except as stated below.  With the exception of Content supplied on the Site in a format for you to download – “*.PDF”, you may not reproduce, transmit, modify, store, archive or in any other way use for any public or commercial purpose this Site or any of the Content without the prior written permission of ITUS.  In particular, neither you nor any third party acting on your behalf or at your instigation may:

  • Redistribute to any other person any of the Content (whether as part of any library, archive or similar service or otherwise);
  • Remove the copyright or trade mark notice from any copies of Content;
  • Create a database in electronic or structured manual form by systematically downloading and storing all or any of the Content.

7. Responsibilities of User

  • You are responsible for any use of the Site made by you.
  • You undertake to use your best endeavors to use the Site in accordance with applicable law and regulation and to ensure that nothing you do whilst accessing the Site will damage the Site.

8. No Warranties and Exclusion of Liability

Whilst ITUS shall use reasonable efforts to obtain information from sources which we believe to be reliable, ITUS gives no warranty as to the accuracy, completeness or reliability of any information, opinions or forecasts contained on the Site, nor does it undertake to ensure that this Site will be available or accessible at all times.

ITUS shall have no liability (whether in contract, tort or otherwise) for any direct, indirect, consequential or special losses or damages of any kind whatsoever arising from or in connection with the access to, use of or linking to other websites (“Linked Websites”) from this Site or any reliance on any of the Content.

ITUS is not responsible for the content of any Linked Websites and accordingly accepts no liability with respect thereto or for any reliance placed upon such Linked Websites.

ITUS is not liable for persons or matters beyond its reasonable control (such as telephone and other communications networks, the internet or your internet service provider).

ITUS makes no warranties that the information contained herein or the Site and the Linked Websites are free from viruses or bugs that may cause damage to any recipient.

These exclusions of liability do not apply to the extent that such exclusions are invalid or ineffective under any law or regulation applicable to ITUS.

9. Investment Performance

Potential investors should note that investments can involve significant risks and the value of an investment may go down as well as up.  The Investment Products on this Site may use alternative investment strategies and may invest in derivatives of any kind.  The prices of futures, options and other instruments in which the products may invest may fall in value as rapidly as they may rise and it may not be possible to liquidate the positions in the relevant markets before a loss is sustained. No assurance can be given that the investment objective of any Investment Product will be achieved or that substantial losses will not be suffered. There is no guarantee of trading performance and past or projected performance is not necessarily a guide to future results.  Movements in exchange rates between currencies may affect the value of an investment.

10. No Reliance

Nothing contained on this Site constitutes investment, legal, tax or other advice or a recommendation to purchase or sell any investment.  You should not rely on any of the Content in making an investment or other decision but should obtain relevant and specific professional advice and read the terms and conditions contained in the relevant offering prospectus carefully before any investment decision is made.

11. Material Interests

Any one of ITUS or its affiliates or their directors, officers, employees, agents or representatives may have or have had an interest or holding, relationship or other arrangement with the Investment Products which may be material.

You should be aware that any rules and/or regulations applicable to the provision of financial services (and the resultant investor protection benefits that may be available), may not be applicable to interfacing conducted through the internet medium and its various applications, of which this material forms part.

12. Personal Data/Data Protection Notice

Your personal data is important to us.  Please see our Privacy Policy here

13. Miscellaneous

You should be aware that your dealings with any ITUS’s entities are not covered by the rules and/or regulations made for the protection of investors in your country of legal residence, including any compensation arrangements, complaints process or rights of cancellation under the rules of the Financial Services Authority of your country.  Similar protections may be available under the rules and regulations applicable in the jurisdiction in which business is conducted but you must make your own investigation of such matters.

You should be aware that any rules and/or regulations applicable to the provision of financial services (and the resultant investor protection benefits that may be available), may not be applicable to interfacing conducted through the internet medium and its various applications, of which this material forms part.

Any issue arising in connection with this Site shall be governed by the laws of Singapore and without reference to its choice of law or conflicts of laws principles.  The courts of Singapore shall have non-exclusive jurisdiction to settle any dispute which may arise out of, under or in connection with these terms.   

14. How to Proceed to the Site

You will only be eligible to access this web site if you can confirm that each of the statements set out below is true and accurate.

Confirmations:

  • To the best of my knowledge, after due inquiry, I am permitted by the laws of my jurisdiction of residence to access this site and the information contained therein; and
  • I have read and understood the terms and conditions of use and confirm to be bound by them.
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