(a) 'Personal Data' refers to any data, whether true or not, about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time; and
(b) 'Website' includes but is not limited to the information, materials, data, reports, text, images, links, sounds, graphics and video sequences displayed herein.
2. Types of Personal Data or information collected
Depending on the nature of your interaction with us, we may collect Personal Data such as but not limited to the following:
(b) passport or other identification number;
(c) information on your financial condition;
(d) telephone number;
(e) mailing address;
(f) email address; and
(g) any other information which you have provided via any other forms of interaction with us.
Apart from Personal Data, we also collect other types of information which may not be related to a specific individual. Such information is anonymous and will be used in an aggregated form. Examples would include but are not limited to information such as the traffic and usage patterns of our Website visitors ascertainable through the use of “cookies”. Further details on our cookies policy can be found below.
For avoidance of doubt, the Singapore National Registration Identification Card (“NRIC”) number and any other identification card numbers or passport numbers will only be collected, used and/or disclosed if necessary and only in accordance with the guidelines set out by the Personal Data Protection Commission of Singapore.
3. Purposes for collection, use and disclosure of your Personal Data
Generally, we collect, use, and disclose your Personal Data for the following purposes:
(a) providing a service and/or product to you;
(b) the execution or administration of any transaction(s) requested and/or authorised by you;
(c) the maintenance, servicing and/or termination of any account relationship with us or our services providers;
(d) communicating with you on matters relating to your account relationship with us and your interest in our products and/or services;
(e) responding to your queries and requests;
(f) enhancing the content and user experience of the Website and/or any of our services or products;
(g) disseminating information for marketing purposes about services or products;
(h) providing events or activities to you;
(i) verifying due diligence or Know-Your-Customer checks and the status of your financial standing;
(j) managing the administrative and business operations of the ZHBR Group and complying with internal policies and procedures;
(k) matching any Personal Data held which relates to you for any of the purposes listed herein;
(l) resolving complaints and handling requests and enquiries;
(m) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing commercial risks;
(n) meeting or complying with any applicable laws, regulations, directives, rules, codes of practice or guidelines issued by any legal or regulatory bodies which any member of the ZHBR Group may be subject, whether local or overseas (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
(o) legal and accounting purposes (including but not limited to obtaining legal advice and dispute resolution);
(p) disclosure to other members of the ZHBR Group, business partners, or third party service providers; and
(q) all other purposes which are reasonably related to the aforesaid.
In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, or use disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. To whom may we disclose Personal Data
In order that we may provide you with effective and satisfactory services and products, and in accordance with the purposes set out above, your Personal Data may be disclosed to the following parties:
(a) entities belonging to the ZHBR Group;
(b) agents, contractors or third party service providers who provide operational services to the ZHBR Group, including but not limited to courier services, telecommunications, information technology, payment, payroll, processing, training, survey, market research, storage, archival or other service providers;
(c) vendors and other third party service providers in connection with promotions, online campaigns, products and services offered by the ZHBR Group;
(d) any business partners, other financial institutions and their respective service providers;
(e) our professional advisers such as financial advisors, auditors and lawyers;
(f) relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any court orders, requirements of legal authorities, laws, rules, guidelines and regulations or schemes to which the ZHBR Group may be subject, whether situated locally or overseas;
(g) counterparties, billing organisations and banks in relation to fund transfers, payments and drawing of cheques;
(h) brokerage houses, fund houses, registrars, custodians, external banks and investment vehicles in relation to any custodial services and settlement processing;
(i) external businesses and partners in relation to the marketing and promotion of products, gift redemptions and corporate promotional events; and
(j) any other party to whom you authorise us to disclose your Personal Data to.
5. Transfer of Personal Data out of Singapore
Where there is a necessity to transfer Personal Data outside of Singapore, whether to our affiliates, related companies, business partners, authorized agents, third party service providers or to data storage facilities, we endeavor to do so in accordance with the requirements of the Personal Data Protection Act 2012 (“Act”) and/or the privacy laws of any other applicable jurisdiction, to ensure that the standard of protection applied personal data so transferred is comparable to the protection under the Act and/or the applicable privacy laws of the applicable governing jurisdiction.
Generally, when we request for your Personal Information in the course of providing a service or product to you, and where you provide us with such Personal Data, there is implied consent that you agree to provide us with your Personal Data in order that we may provide you with the requested product and/or service.
In some circumstances and as required by applicable law, we will seek your express consent when collecting your Personal Data. This is particularly where fresh consent is required for a new purpose in which your Personal Data will be used.
With respect to any withdrawal of your consent for marketing or promotional activity, we will require some time to process your withdrawal request. During this period of time, you may still receive marketing or promotional materials or communications from us.
7. Security of your Personal Data
The security of your Personal Data is our utmost priority. We endeavour to take all reasonable steps to properly safeguard your Personal Data.
Should we disclose your Personal Data to a third party (such as our business partners, authorised agents, or service providers), we will require them to appropriately safeguard the Personal Data provided to them.
While we have put in place measures to ensure that your Personal Data remains safe, secure and private, you should be aware that transmission over the Internet is not entirely secure and therefore we cannot guarantee the security or integrity of any Personal Data which is transferred from you or to you via the Internet.
In the event of a data breach, we will endeavour to take all reasonable steps to contain the breach, and notify the Personal Data Protection Commission of Singapore and affected individuals as soon as practicable.
We will only retain your Personal Data for so long as it is necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory and internal requirements.
9. Access to your Personal Data
You are also entitled to certain access rights to your Personal Data. Should you wish make to a request, you may contact us using the contact details found below. We will endeavour to provide a response within thirty (30) days of receiving your request, and will inform you should we be unable to accede to your request for any reason.
Kindly note that we may charge an administrative fee in connection with any requests made for accessing your Personal Data. We will notify you of such administrative fees (if any) in advance.
10. Accuracy and correction
We endeavour to ensure that your Personal Data is as accurate and up-to-date as possible. However, should you wish to correct, amend or update your Personal Data, you may contact us using the contact details found below.
11. Contact details
Your visits to the Website may be recorded for analysis on the number of visitors to the Website and general usage patterns through the use of “cookies”. Should you wish to disable cookies associated with the Website, you may do so by adjusting the settings on your browser.
14. Third-party Websites
Version dated 9th November, 2023