By interacting with us, submitting information to us, or by your continued engagement and/or employment with us, you agree and consent to us, as well as our respective agents (collectively referred to herein as “One Heritage Capital Management (SG) Pte Ltd”, “1HCapital”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data that is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“Act”), and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
In this Data Protection Policy, “Personal Data” refers to any 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 we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
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 fulfil your requests and/or applications.
Collection of Personal Data
Generally, we may collect Personal Data in the following ways:
(a) when you submit forms or applications to us;
(b) when you submit queries or requests to us;
(c) when you submit a complaint or provide feedback;
(d) when you respond to our request for additional Personal Data;
(e) when you ask to be included in an email or other mailing list;
(f) when you respond to our initiatives;
(g) when you visit our website, via cookies or other technologies deployed for analysis of visits to websites or the use of any information technology application; and
(h) when you submit your Personal Data to us for any other reasons.
If you provide us with any Personal Data relating to a third party (e.g. information of your dependent, spouse, children and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of that third party to you providing us with their Personal Data for the respective purposes.
Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, 1HCapital collects, uses and discloses your Personal Data for the following purposes:
(a) responding to or processing your queries, requests, complaints or instructions;
(b) sending you details of services, events and programmes, whether by email, newsletter or otherwise;
(c) managing the administrative and business operations of 1HCapital and complying with internal policies and procedures;
(d) maintaining security of any premises occupied, operated or otherwise utilised by 1HCapital (including but not limited to CCTV surveillance);
(e) obtaining or providing access to services, events or programmes, including physical access to locations, venues, buildings etc where such services, events or programmes may be held;
(f) conducting research, generating reports and analytics in relation to our services, and understanding and determining preferences and demographics for us to review, develop and improve our services, events and programmes;
(g) applying for and maintaining services deemed necessary by 1HCapital Sg;
(h) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on 1HCapital (including but not limited to audit checks);
(i) legal purposes (including but not limited to drafting and reviewing documents, and obtaining legal advice);
(j) generally, administration, management and/or evaluative purposes and/or any of the other legitimate activities of 1HCapital; and
(k) purposes which are reasonably related to the aforesaid.
In addition, 1HCapital collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship with you:
- If you are an employee or owner of an external service provider of 1HCapital, 1HCapital collects, uses and discloses your Personal Data for the following purposes:
- managing and evaluating project proposals or tenders;
- processing and payment of invoices;
- drafting and reviewing of contracts and agreements; and
- purposes which are reasonably related to the aforesaid
If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, 1HCapital may contact you using such Singapore telephone number(s) (including via voice calls, text, fax, email or other means) with information about our products and services (including discounts and special offers).
Disclosure of Personal Data
Your Personal Data held by us shall be kept confidential. However, in order to provide you with effective and continuous products and services, and for the purposes listed above (where applicable), your Personal Data may be disclosed :
(a) to agents, contractors or third party service providers who provide operational services to 1HCapital, such as photography services, courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services;
(b) to our professional advisers such as financial advisors, auditors and lawyers;
(c) to relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
(d) to counterparties, billing organisations and their respective banks in relation to fund transfers and payments;
(e) to companies and brokers providing insurance products and services;
(f) to any business partner, investor, assignee or transferee (actual or prospective) to facilitate transactions involving 1HCapital; and
(g) to any other party to whom you authorise us to disclose your Personal Data to.
Further, if you attend events or programmes organised, managed, administered or publicised by 1HCapital, by attending such events, you agree and consent to the use of your photograph, voice, likeness, and image in any broadcasts of such event and in subsequent productions drawn from video or audio recordings of such event. The photographs and recordings may be published or broadcasted in 1HCapital publications and in publicity materials, including 1HCapital’s websites and social media or entities under the One Heritage Group. All recordings, articles, quotes, photographs, films, audio or video and/or any reproductions of same in any form, are the property of 1HCapital, its affiliates, employees, representatives and agents are released from any and all claims, demands, costs and liability that may arise from the use of these interviews, recordings, photographs, videotapes or films, and/or any reproductions of same in any form, as described above, arising out of being interviewed, recorded, photographed, videotaped or filmed. If you do not wish to have your photos/audio-visual recordings taken at such event, it is your responsibility to remove yourself from group and candid shots/recordings that the photographers/videographers intend to capture.
Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access and make corrections to your Personal Data records, please contact 1HCapital as follows:
Write in: 7 Straits View, Marina One East Tower #05-04, Singapore 018936
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, 1HCapital may not be in a position to continue to provide its services to you, administer our relationship with you, and may be considered a termination by you of the relationship you have with 1HCapital.
Please note that if your Personal Data has been provided to us by a third party, you should contact that party to make such queries, complaints, and access and correction requests to 1HCapital on your behalf.
This Data Protection Policy supplements and does not supersede nor replace any other consents you may have previously provided to 1HCapital in respect of your Personal Data, and your consents herein are additional to any rights which to we may have at law to collect, use or disclose your personal data.
1HCapital may from time to time update this Data Protection Policy to ensure that this Data Protection 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 the Data Protection Policy as updated from time to time on our website www.1HCapital.sg . Please check back for updated information on the handling of your Personal Data.