The purpose of this document ("Privacy Policy") is to inform you of how Bibby Financial Services (Singapore) Pte Limited ("BFSS") manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) ("PDPA"). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to BFSS and its related companies (collectively, the "Companies"), as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "BFSS", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.
This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to BFSS in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.
BFSS may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our website www.bibbyfinancialservices.sg/footer/privacy. Please check back regularly for updated information on the handling of your Personal Data.
Personal Data
“Personal data” is data that can be used to identify a natural person. Some examples of personal data that we may collect are:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
- specimen signature(s);
- financial details (e.g. income, expenses, and/or credit history);
- images and voice recordings of our conversations with you;
- employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- tax and insurance information;
- information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- banking information (e.g. account numbers and banking transactions); and/or
- personal opinions made known to us (e.g. feedback or responses to surveys);
Collection of Personal Data
Generally, we collect Personal Data in the following ways:
- when you submit any form, including but not limited to application, declaration, proposal or referral forms;
- when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
- when you interact with our staff, including business development managers, client managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
- when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
- when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;
- when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
- when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
- when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
- when you use our electronic services, or interact with us via our websites or use services on our websites;
- when we seek information about you and receive your Personal Data in connection with your relationship with us, including for financial products, insurance policies or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or
- when you submit your Personal Data to us for any other reason.
When you browse our website, you generally do so anonymously but please see our Cookies Policy. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or log in with your account credentials.
If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
Your personal data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.
You may request access or make corrections to your personal data held by BFSS. BFSS may charge a reasonable fee for processing your request for access. Please contact us (please see the “How to contact us” section below) for details on how you may request such access or corrections.
Usage of Your Personal Data
We may use your personal data for our core business purposes, such as:
- developing and providing credit facilities, products or services (whether made available by us or through us), including but not limited to:
- executing investments, banking, commercial or other transactions and clearing or reporting on these transactions;
- carrying out research, planning and statistical analysis; or
- analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
- assessing and processing applications, instructions or requests from you or our customers;
- communicating with you, including providing you with updates on changes to products, services and credit facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and credit facilities and their terms and conditions;
- managing our infrastructure and business operations and complying with internal policies and procedures;
- responding to queries or feedback;
- addressing or investigating any complaints, claims or disputes;
- verifying your identity for the purposes of providing banking facilities, products or services;
- conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
- complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
- monitoring products and services provided by or made available through us;
- complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
- creating and maintaining credit and risk related models;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enabling any actual or proposed assignee or transferee, participant or sub-participant of BFSS’s rights or obligations to evaluate any proposed transaction;
- enforcing obligations owed to us; and/or
- seeking professional advice, including legal advice.
We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customer.
We may also obtain some personal information from monitoring or recording calls. We may record or monitor phone calls with you for regulatory purposes, for training purposes, to ensure and improve quality of service delivery, to ensure safety of our staff and customers, for other security purposes and to resolve queries or issues. Such recordings belong to us.
Use of Personal Data for Marketing Purposes
We may use your personal data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
In respect of sending telemarketing messages to your Singapore telephone number via short message service, telephone calls, facsimile and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry. If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your Singapore telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
To find out more on how you can change the way we use your personal data for marketing purposes, please contact us (please see the “How to contact us” section below).
Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
Disclosure and Sharing of Personal Data
We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of BFSS and/or any other Bibby related company or to third parties, whether located in Singapore or elsewhere, where data protection laws may be less demanding than those in Singapore, in order to carry out the purposes set out above. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.
For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or our customer. You may also contact us for more information (please see the “How to contact us” section below).
We wish to emphasize that BFSS does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.
We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
How to Contact Us
In accordance with the PDPA, you may make data access or data correction requests or request information regarding policies and practices and kinds of data held. Such requests should be addressed to:
Data Protection Officer
Bibby Financial Services (Singapore) Pte Ltd
6 Shenton Way OUE Downtown 2 #18-08A Singapore 068809
Email: singapore@bibbyfinancialservices.com
Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to BFSS on your behalf.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, BFSS may not be in a position to continue to provide its products or services to you or administer any contractual relationship already in place. This may also result in the termination of any agreements you have with BFSS, and you are being in breach of your contractual obligations or undertakings. BFSS's legal rights and remedies in such event are expressly reserved.
Last Updated: May 2019