Privacy Policy

Last updated on 9 January 2023

  1. Red Beacon Asset Management Pte. Ltd. (hereinafter “we“, “us“, “our“, “RBAM”) respects the privacy rights of our users and is strongly committed to protecting your privacy. This Privacy Policy applies to this Website, websites owned and operated by RBAM, any newsletters subscribed to via this Website (collectively, the “Covered Platforms“), but does not apply to any other products or services or to information collected in any other way by RBAM (such as information collected offline), its general and limited partners, and its subsidiaries, and their respective general partners and affiliates, unless expressly indicated by RBAM (such as by including a link to this Privacy Policy on other RBAM websites).
  2. This Privacy Policy is based on the Singapore Personal Data Protection Act 2012 (2020 Revised Edition) (“PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Singapore and any other relevant authority. We reserve the right to amend this Privacy Policy as and when for compliance with new developments and prevailing legislation.
  3. By visiting or using the RBAM website, you agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully before visiting or using our website, or otherwise providing us with any of your personal data. If you do not agree with any of our terms, please cease any use of the Covered Platforms and DO NOT provide any personal data to us.

Collection, Use and Disclosure of Personal Data

  1. RBAM may collect certain types of personal data. As used in this Privacy Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which RBAM has or is likely to have access. Personal data includes, among other things, personal information that you voluntarily provide on this Website, and on third-party websites, which may include your: name; street or mailing address; e-mail addresses; telephone number(s); date of birth; gender; nationality; passport number; payment information; credit card numbers; billing information; information used to provide products or services; and any other types of information that you choose to provide to us or that we may collect about you through your transactions with RBAM.
  2. We may as and when necessary, implement reasonable measures to check the accuracy and completeness of the personal data which you have provided to us. However, it is your responsibility to ensure that the personal data which you have provided is accurate, complete and up to date. RBAM shall not be liable for any damage, losses or claims arising out of or in relation to any personal data which you have provided to us that is inaccurate, false, incomplete or outdated.
  3. RBAM may use your personal data to (i) evaluate and respond to your query, (ii) provide you with services, information, special offers, and/or promotions, (iii) verify your identity, (iv) facilitate business asset transactions, and/or other purposes reasonably related to the aforesaid, via various means including email.
  4. In addition to personal data that you provide to us, we may collect certain information about you that is not generally or uniformly considered personal data when viewed in isolation and which we consider to be non-personal data. We collect this information to create a better user experience and to identify areas of improvement on our websites and for our services. Such non-personal data is collected and may include information such as the type of Internet browser you are using, your IP address, the pages you visited on our websites, how you arrived at our websites (i.e., through a search engine or a referring website), and other types of information.
  5. You may instruct RBAM at any time not to use your data covered by this Privacy Policy, whether considered personal or non-personal to provide you with information and event by contacting our Data Protection Officer at the email provided at the end of this Privacy Policy.
  6. To assist us with the purposes described in this Privacy Policy, information collected about your use of this Website or other websites may be combined with personal or other data about you from other online or offline sources. If you prefer that we not combine non-personal information that has been collected, through cookies, about your use of this Website or other websites with personal or other information about you, then please delete and disable cookies for each browser, on each computer you use to surf the Web.
  7. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geo-location data. You need to set each browser on each device you use to surf the Web. Thus, if you use multiple browsers (e.g., AOL, Safari, Internet Explorer, Firefox, etc.), you should repeat this procedure with each one. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of this Website, such as the polls, surveys, contests, and product sales, and certain areas of the Website for which you need to log in, will not function properly, and the advertising you receive when you visit this Website may not be advertisements tailored to your interests.
  8. If you have provided us with personal data of any other individual apart from yourself, you warrant to us that you have validly obtained each individual’s consent for, and hereby consent on behalf of each individual to, the collection, processing, use, retention, disclosure and transfer locally or abroad of his/her personal data, that is necessary for use in relation to the Covered Platforms in accordance with our Privacy Policy.
  9. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes which we have collected the relevant personal data for, including for the purposes of satisfying any legal, business, regulatory, tax, accounting or reporting requirements.

Security of Your Personal Data

  1. To safeguard your personal data against unauthorised access, collection, use, disclosure and modification and other similar risks, we have implemented reasonable security arrangements (including where appropriate, physical, administrative, procedural and information & communications technology measures) to protect all personal data in our control or possession.
  2. While we will endeavour to ensure that our systems are secure, no electronic transmission over the Internet or information storage technology is guaranteed to be secure against all cyber threats. In this respect, you should ensure that you take the appropriate safety measures when providing your personal data to us.

Transfer of Personal Data to Other Countries

  1. Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal data to and in various countries around the world that may have different levels of privacy protection than Singapore. By submitting your personal data, you consent to such transfers and processing. We will take reasonable steps to ensure that all recipients / data processors are either in a jurisdiction which has data protection laws of a comparable standard or are contractually bound to safeguard your personal data.

Links to Third Party Websites

  1. RBAM may provide links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for the collection, use or disclosure of any information that you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

Your Personal Data Protection Rights

  1. You have rights of access and correction in relation to your personal data in the possession or under the control of RBAM. The Do Not Call (DNC) Registry will also allow you to opt out of unsolicited marketing calls, messages and faxes.

Access of Your Personal Data

  1. In responding to your request for access of your Personal Data (“Access Request“), please note that we reserve the right to take the following actions:
    1. To charge a reasonable administrative fee for each Access Request, which will vary depending on the circumstances, including but not limited to the type of data involved, the volume, and the year which the data was collected by us;
    2. Conduct reasonable measures in accordance with our standard operating procedures, to verify your identity, prior to granting your Access Request.
    3. Refuse your Access Request (with our notification to be provided), if RBAM is of the view that:
      1. The requesting individual’s identity or authority is not sufficiently verified; or
      2. the Access Request falls within legal exceptions or conditions provided for in the PDPA or any associated regulations and guidelines issued by relevant authorities from time to time.

Correction of Your Personal Data

  1. In responding to your request to correct your personal data (“Correction Request“), please note that we reserve the right to take the following actions:
    1. Conduct reasonable measures in accordance with our standard operating procedures, to verify your identity, the nature of the correction and whether the correction should be made, prior to granting your Correction Request.
    2. Refuse your Correction Request (with our reasons to be provided), if RBAM is of the view that:
      1. The requesting individual’s identity or authority is not sufficiently verified; or
      2. There are no valid grounds on which the correction should be made; or
      3. the Correction Request falls within legal exceptions or conditions provided for in the PDPA or any associated regulations and guidelines issued by relevant authorities from time to time
  1. Should you be making an Access and/or Correction request on behalf of an individual that is not yourself, we reserve the right to request for documentary evidence showing that you have the legal authority to validly act on behalf of the relevant individual.
  2. Also, please note that if you withdraw your consent to any or all uses or disclosures of your Personal Data, depending on the nature of your request, we may not be in a position to continue to engage with you or to provide you with services.

Governing Law and Jurisdiction

  1. This Privacy Policy shall be governed and interpreted in accordance with the laws of the Republic of Singapore. Any dispute, actions, claims or causes of action arising out of or in connection with any term within this Privacy Policy shall be irrevocably and unconditionally subjected to the exclusive jurisdiction of the courts of the Republic of Singapore.

Questions Regarding this Privacy Policy

  1. If you have questions regarding this Privacy Policy, please contact our Data Protection Officer at dpo@redbeaconam.com.