Pursuant to the Personal Data Protection Act 2012 (the “PDPA”), the following information is provided in connection with an individual’s dealings with and provision of data or information to BNY Mellon Investment Management Singapore Pte. Ltd or its holding company, representative offices, subsidiaries and affiliates from time to time (each “BNY Mellon IM SG Entity”; collectively “BNY Mellon IM SG Entities”). Please be aware that this Statement replaces any notice or statement of similar nature that may have been provided to you previously. BNY Mellon Investment Management Singapore Pte. Ltd (“BNY Mellon IM SG”) is committed to maintaining personal data in accordance with the requirements of the PDPA and will take all reasonable steps to ensure that personal data is kept secure against unauthorised access, loss, disclosure and destruction. BNY Mellon IM SG Entities are ultimately owned by The Bank of New York Mellon Corporation.
1. Personal Data
“Personal data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which the BNY Mellon IM SG has or is likely to have access to.
Personal data that we collect from you includes but is not limited to:
- full name;
- passport or other identification number;
- contact details (including address, telephone number, e-mail address);
- employment, education, assets and income details;
- information about your transactions with BNY Mellon IM SG Entities and others (including balances, parties to the transactions, and account usage); and
- other information relating to you which you have provided to us in any forms submitted to us, or through other forms of interaction with you.
2. Collection of Personal Data
a) From time to time, it is necessary for clients and various other individuals (“data subjects”) to supply BNY Mellon IM SG with data (including personal data) in connection with various matters such as account opening or continuations, or provision of services to clients and other individuals.
b) Failure to supply such data (including personal data) may result in BNY Mellon IM SG being unable to open or continue accounts or provide any services.
c) It is also the case that data (including personal data) will be collected from data subjects in the ordinary course of the continuation of BNY Mellon IM SG’s relationship with them, for example, when data subjects open account, write cheques, transfer funds, effect transactions, attend seminar/events or generally communicate verbally or in writing by data subjects with BNY Mellon IM SG. BNY Mellon IM SG may also conduct independent checks or verification on the data collected from data subjects for the purposes referred to in sections 4(a) and (l) below from time to time.
3. Employee Data
BNY Mellon IM SG collects, processes, uses and maintains personal data of its employees and contractors for a variety of purposes relating to employment or engagement by BNY Mellon IM SG. BNY Mellon IM SG will provide its employees and contractors with a separate Personal Information Collection Statement which will be applicable to personal data of its employees.
4. Purposes for Use of Personal Data
The purposes for which personal data of a data subject may be used will vary depending on the nature of the data subject’s relationship with BNY Mellon IM SG. They may comprise any or all of the following purposes:
a) the processing of applications for an account with and/or other financial services provided by BNY Mellon IM SG Entities; and conducting background searches, screening and monitoring on an on-going basis as part of BNY Mellon IM SG’s obligations described in section 4 (g), (h) and (i) below;
b) enabling BNY Mellon IM SG Entities to ensure the daily operation of the services provided to the data subjects, including without limitation provision of asset management, dealing and advisory services and investment in collective investment schemes;
c) assessing the suitability or appropriateness of a transaction with the data subject or for the data subject;
d) providing alerts, newsletter and investment education materials requested/signed up by the data subjects;
e) designing and organising financial, investment seminars/events/forums;
f) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision of services by BNY Mellon IM SG Entities;
g) meeting the disclosure and compliance requirements under any laws or regulatory requirements applicable to BNY Mellon IM SG Entities in Singapore or elsewhere from time to time;
h) complying with the obligations, requirements or arrangements for collecting, disclosing, maintaining and using data (including personal data) that apply to BNY Mellon IM SG Entities or that they are expected to comply with according to;
(i) any laws or regulatory requirements binding or applying to BNY Mellon IM SG Entities within or outside Singapore currently existing and in the future, including without limitation those with respect to anti-money laundering and counter terrorist-financing, automatic exchange of financial account information, Foreign Account Tax Compliance Act (FATCA) and any related group policies;
(ii) any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside the Singapore existing currently and/or in the future;
(iii) any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on BNY Mellon IM SG Entities by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
i) complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information (including personal data) within BNY Mellon IM SG Entities and/or any other use of data and information (including personal data) in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
j) any purpose related to the administration of the products or services offered by BNY Mellon IM SG Entities to the data subject or the data subject’s participation therein;
k) enabling a potential purchaser, transferee or assignee of all or any part of the business or shares of BNY Mellon IM SG Entities to evaluate the transaction intended to be the subject of the purchase or restructuring; and
l) any purposes directly related or incidental to the above, including seeking professional advice.
You should ensure that all personal data submitted to BNY Mellon IM SG 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. Where personal data is submitted by you on behalf of another individual or concerns another individual other than yourself (or, in the case of situations where you, as a representative of your company or organisation, are submitting the personal data of individuals as part of the disclosures by the company or organisation to us), you represent and warrant to us that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in the relevant sections of this Statement) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.
5. Persons to whom the Data may be transferred
Personal data held by BNY Mellon IM SG relating to the data subject or his / her / its representatives will be kept confidential but BNY Mellon IM SG may provide such information to the following parties within or outside Singapore for any of the purposes set out in section 4 “Purposes for Use of Personal Data” of this Statement above:
a) any BNY Mellon IM SG Entity, agent, auditor, contractor, or third party service provider, law enforcement agency, information provider, trade repository (including related third party service providers), court of competent jurisdiction, exchange, depository, clearing house or any government, tax or other regulatory body or agency or any other person we think necessary for any of the purposes outline above;
b) any person to whom any BNY Mellon IM SG Entity outsources any services in accordance with relevant regulatory requirements and applicable data protection legislation;
c) any other person under a duty of confidentiality to BNY Mellon IM SG including a BNY Mellon IM SG Entity which has undertaken to keep such information confidential;
d) any person to whom any BNY Mellon IM SG Entity is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to any BNY Mellon IM SG Entity, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which any BNY Mellon IM SG Entity is expected to comply, or any disclosure pursuant to any contractual or other commitment of any BNY Mellon IM SG Entity with local or foreign legal regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, existing currently and/or in the future;
e) any actual or proposed assignee of a BNY Mellon IM SG Entity or participant or sub-participant or transferee of its rights and obligations in respect of the data subject;
f) the service providers of any BNY Mellon IM SG Entity including the registrar, transfer agent, the custodian, administrative service agent, share distributors, securities and investment service providers and the auditor of each products or services offered by any BNY Mellon IM SG Entity;
g) any agent, contractor or third party service provider who provides administrative, research, design, launch, telecommunications, printing, mailing, computer, payment, securities clearing and settlement or other services to any BNY Mellon IM SG Entity in connection with the operation of their business;
h) the intermediaries of any BNY Mellon IM SG Entity including third party financial institutions (e.g. banks, Independent Financial Advisors, insurers), third party product issuers, correspondent banks which may handle or process payment to/from data subjects;
i) the following entities:
(i) any other BNY Mellon IM SG Entities;
(ii) third party financial institutions, insurers, credit card companies, securities and investment services providers;
(iii) third party reward, loyalty, co-branding and privileges programme providers;
(iv) our co-branding partners;
(v) charitable or non-profit making organisations; and
(vi) external service providers (including but not limited to printing houses, mailing houses, telecommunication companies, public relation companies, advertising agency, telemarketing companies, data processing companies, storage companies, call centres, market research firms, and information technology companies), that any BNY Mellon IM SG Entity engages for the purposes set out in paragraphs (a)-(h) in this section.
Such information may be transferred to a place outside Singapore, to the extent permitted by law.
6. Use of Data in Direct Marketing
If BNY Mellon IM SG intends to use the data subject’s data (including personal data) in direct marketing, BNY Mellon IM SG may not so use such data unless with the data subject’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
a) the name, contact details (including residential address, correspondence address, permanent address (if applicable), contact/mobile phone number, email address, facsimile number), products and services portfolio information, transaction pattern and behaviour, financial background and demographic data of the data subject held by BNY Mellon IM SG from time to time may be used by BNY Mellon IM SG in direct marketing;
b) the following classes of services, products and subjects may be marketed in direct marketing:
(i) financial, investment, wealth management, securities, retirement, insurance and related services and products; and
(ii) reward, loyalty or privileges programmes, promotional offers and related services; and
(iii) invitations to financial and investment seminars/events/forums;
c) the above services, products and subjects may be provided or (in the case of donations and contributions) solicited by BNY Mellon IM SG and/or:
(i) any other BNY Mellon IM SG Entities;
(ii) third party financial institutions, insurers, credit card companies, securities and investment services providers;
(iii) third party reward, loyalty, co-branding or privileges programme providers;
(iv) our co-branding partners; and
(v) charitable or non-profit making organisations;
d) in addition to marketing the above services, products and subjects, BNY Mellon IM SG also intends to provide the data (including personal data) described in sub-paragraph (a) in this section to all or any of the persons described in sub-paragraph (c) in this section for use by them in marketing those services, products and subjects, and
If the data subject does not consent to BNY Mellon IM SG using his / her / its data for the purposes set out in this Section 6 (Use of Data in Direct Marketing) in relation to direct marketing, the data subject needs to tick the box below, provide the details as below, and contact the Data Protection Officer at One Temasek Avenue, #03-01 Millenia Tower, Singapore 039192 or by sending an email with a copy of the same to email@example.com.
The data subject (details as stated below) objects to the proposed use of his/her/ its personal data for the purposes set out in section 6 (Use of Data in Direct Marketing) of this Statement in relation to direct marketing.
Correspondence address: ________________________________________
Contact phone number: ________________________________________
Date of objection: ________________________________________
If the data subject has previously consented to BNY Mellon IM SG’s use of its data for direct marketing purposes but it now wishes to withdraw its consent, please also contact the Data Protection Officer at One Temasek Avenue, #03-01 Millenia Tower, Singapore 039192 or by sending an email to firstname.lastname@example.org who will be able to assist the data subject in this regard.
7. Rights of the Data Subject
a) Under and subject to the terms of the PDPA, any data subject has the right:
(i) to check whether BNY Mellon IM SG holds personal data about the data subject and of access to such personal data; (ii) to be informed about the way in which personal data has been or may have been used or disclosed by BNY Mellon IM SG within a year of such request; (iii) to require BNY Mellon IM SG to correct an error or omission in any personal data which is in possession or under control of BNY Mellon IM SG; (iv) to ascertain BNY Mellon IM SG’s policies and practices in relation to compliance with the PDPA and its compliant process;
b) In accordance with the terms of the PDPA, BNY Mellon IM SG has the right to charge a reasonable fee for the processing of any data access request.
c) The person to whom requests for access to personal data or correction of personal data or for information regarding policies and practices and the complaints process are to be addressed is as follows:
The Data Protection Officer
BNY Mellon Investment Management Singapore Pte. Ltd
One Temasek Avenue
#03-01 Millenia Tower
d) Nothing in this notice shall limit your rights under the PDPA.
8. Withdrawal of Consent
If you wish to withdraw your consent to any use or disclosure of your personal data as set out in this Statement, please contact our Data Protection Officer at email@example.com. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.
9. Retention of your Personal Data
BNY Mellon IM SG will retain your personal data in accordance with applicable laws for so long as it is necessary.
10. Security Measures
BNY Mellon IM SG is committed to ensuring that your personal data is secure. In order to prevent unauthorised access or disclosure, BNY Mellon IM SG has implemented appropriate technical and organisational security measures to protect and secure your personal data. BNY Mellon IM SG will take all steps reasonably necessary to ensure that your personal data is treated securely and used only in accordance with this Statement.
11. Changes to the Statement
Please be aware that this Statement may be updated at any time. As such, please ensure that you regularly read the latest version of the page http://www.bnymellonimapac.com/sg/privacy-statement. We may also circulate separate guidance to appropriate personnel on specific issues from time to time.
If you have any questions or complaints relating to this Statement, how BNY Mellon IM SG uses your personal data, or correcting your personal data previously provided to BNY Mellon IM SG, please contact our Data Protection Officer at firstname.lastname@example.org who will endeavour to respond to you promptly.