Introduction

In the course of the provision of our services and in order to operate effectively, the Association of Independent Wealth Managers Singapore (“AIWM Singapore” or “we”) may collect, use and disclose personal information of individuals, including but not limited to personal information of current, past and prospective members, members’ employees and employees.

The purpose of this policy is to detail our approach to the protection of Personal Data (as defined below) and to ensure the consistent handling of Personal Data and compliance with the regulations of the Singapore Personal Data Protection Act 2012  (“PDPA”).

By using the services of AIWM Singapore and attending its events, you, the subject of such Personal Data (“Data Subject”), consent to the collection, usage and processing of your Personal Data according to the terms set out in this policy.

Personal Data

The PDPA defines “Personal Data” as the data of an individual or as data that together with any other information to which an organisation has or is likely to have access, regardless of its accuracy, can be used to identify said individual.

In many instances, the information collected by AIWM Singapore may be Business Contact Information to which the PDPA does not apply. “Business Contact Information” refers to an individual’s name in connection with the position, name or title, business, telephone and fax numbers, business email addresses, business addresses and similar information from this individual, not provided solely for personal purposes. AIWM Singapore will, however, take all reasonable precautions to adhere to the terms of this policy also in regard to Business Contact Information.

Purposes of Collection, Use and Disclosure of Personal  Data

AIWM Singapore may collect, use and disclose Personal Data and other information or pictures for the purposes of:

1. providing our services;
2. member relationship management (including sending updates, information relating to our services, services offered by third parties, event invitations, newsletters or publications and marketing materials);
3. providing networking opportunities, information on business opportunities and introductions to other organisations;
4. supporting and assisting AIWM Singapore members in Singapore;
5. publication on AIWM Singapore’s website, in newsletters and other publications;
6. regulatory compliance and internal record keeping;
7. liaising with other Swiss related or Singapore based associations, organisations or institutions in order to promote AIWM Singapore’s objectives as stated in the AIWM Singapore Rules;
8. evaluating and processing applications for membership, committee positions or employment;
9. managing or terminating employment relationships and employee evaluations;
10. any other purposes necessary and/or incidental to our objectives as stated in the AIWM Singapore Rules and any purposes necessary for or related to any of the above purposes.

Should Personal Data be required for a new purpose not listed above, the data subject’s approval will be obtained prior to using his/her Personal Data for the new purpose, or the data subject will be notified accordingly, provided that no exemption to the consent or notification obligation applies according to the PDPA.

Disclosure and Transfer of Personal  Data

Personal Data may be disclosed within AIWM Singapore or to any other third party/ies, such as other business organisations, members of AIWM Singapore, services providers assisting AIWM Singapore (e.g. in connection with events organized by AIWM Singapore), professional consultants or advisors (including law firms), accountants, insurers, governmental bodies and authorities, or any other third party, in order to satisfy the purposes for which the Personal Data has been collected.

Personal Data may be transferred outside of Singapore in accordance with the requirements of the PDPA.

Protection

Appropriate technical, organisational and administrative security measures are in place to protect Personal Data against unauthorised access, collection, use, disclosure, copying, alteration, accidental loss or theft, destruction, damage or similar risks.

Retention

AIWM Singapore will retain Personal Data no longer than necessary for the purpose it was collected for, or any other business or legal purposes (“Purposes”). AIWM Singapore will take all reasonable steps to ensure that all Personal Data is destroyed, permanently deleted or anonymised when it is no longer required for those Purposes.

Accuracy

Personal Data held by AIWM Singapore is usually provided by the Data Subject himself/herself. Therefore, AIWM Singapore is not responsible for the accuracy of the data in the first instance. However, in the event that there is a complaint regarding the inaccuracy of Personal Data kept by AIWM Singapore, that complaint may be referred to the Data Protection Officer.

Your Data

Under the PDPA, as the Data Subject, you have the right to withdraw your consent to the collection, use and disclosure of your Personal Data. In the event that you withdraw your consent, AIWM Singapore will advise you on the consequences of the withdrawal and will cease to use or disclose the Personal Data should your consent be legally required.

According to the PDPA, a Data Subject has the right to access information relating to him/herself held by AIWM Singapore and, if the details are inaccurate, may request for the data to be amended. The right of access and correction may be exercised in accordance with the PDPA. Any access request may be subject to a fee to meet the cost of providing details of the information AIWM Singapore holds relating thereto. Such a request must be made in writing to the Data Protection Officer at the address listed below.

The Data Protection Officer

AIWM Singapore has appointed Mr. Alexander Floersheim as its Data Protection Officer. Any requests and complaints must be addressed to the Data Protection Officer. The Data Protection Officer can be contacted via the email address Alexander.Floersheim@lci.com.sg

Amendment of Policy

AIWM Singapore reserves the right to change or amend this Personal Data Protection Policy from time to time at its sole discretion. The revised Policy will be available from the Data Protection Officer and on AIWM Singapore’s website.