1. Personal Data We Collect

"Personal Data" has the meaning given in the Personal Data Protection Act 2012 of Singapore (the "PDPA"). It means data, whether true or not, about an individual who can be identified from that data alone, or from that data and other information we have or are likely to have access to.

 

We collect only the Personal Data that is relevant to our business and needed to provide our services. Depending on how you deal with us, this may include:

• (a) identification details, such as your name and date of birth, and your login details if you have an account with us;

• (b) contact details, such as your email address, telephone number and postal address;

• (c) information about your investments with us, and the products and services you subscribe to;

• (d) images recorded by closed-circuit television (CCTV) when you visit our office;

• (e) sensitive personal data, such as information about your health, where this is relevant to a product or service;

• (f) payment information, such as your bank account details;

• (g) limited details of a child, such as name, age and gender, where a parent or guardian names the child as a beneficiary of a fund or trust (we do not offer products or services to children); and

• (h) technical data collected when you use the Site, such as your IP address, browser type and settings, operating system and how you use the Site (see section 13).

 

2. How We Collect Personal Data

We collect Personal Data when you:

• (a) register on the Site;

• (b) give us Personal Data voluntarily;

• (c) make a payment to us;

• (d) use our services or subscribe to our products;

• (e) contact us through the Site or by telephone, post, email or any other means;

• (f) submit an application form for a product or service;

• (g) meet our business development or relationship personnel;

• (h) register for one of our events;

• (i) take part in a competition or promotion we run or sponsor;

• (j) use the Site or any of our other online services; or

• (k) take part in surveys or research that help us improve our products and services.
   

We may also collect Personal Data about you from:

• (l) your financial adviser or other intermediary, who may give it to us on your behalf; and

• (m) business directories and other commercially or publicly available sources.

 

You can browse the Site without giving us your name or contact details. We will still collect technical data, as described in section 13.

Please make sure that any Personal Data you give us is complete, accurate and up to date, and tell us if it changes. If you give us Personal Data about another person, such as a beneficiary, you confirm that you have that person's consent to do so. If information you give us is incomplete or inaccurate, we may be unable to provide our products and services to you.

 

3. Why We Use Personal Data

We may collect, use and disclose your Personal Data to:

• (a) respond to your enquiries;

• (b) verify your identity and carry out customer due diligence, anti-money laundering and other regulatory checks;

• (c) open, maintain and administer your account, including processing subscriptions, redemptions and payments;

• (d) provide the products and services you have asked for;

• (e) run the Site, including login authentication, remembering your settings and hosting our systems;

• (f) manage our business operations and infrastructure;

• (g) comply with applicable laws, regulations, codes of practice, guidelines and requests from regulators or other authorities;

• (h) protect and enforce our legal rights and meet our legal obligations;

• (i) analyse how the Site is used, and improve and develop our products, services and Site (see section 13);

• (j) tell you about changes to our services; and

• (k) send you information about our products, services, events and market updates, where you have agreed to receive it (see section 10).

 

When you deal with us about a particular product or service, we may tell you about other purposes for which we collect, use or disclose your Personal Data.

 

4. Consent

We collect, use and disclose your Personal Data with your consent, or where the PDPA or another law otherwise permits or requires it. This includes, for example, where the PDPA's legitimate interests exception applies.

 

You consent to our collecting, using and disclosing your Personal Data as described in this Privacy Policy when you:

• give us your Personal Data;

• register on the Site; or

• subscribe to any of our products or services.

 

You may withdraw your consent at any time by contacting us (see section 15). We will tell you what is likely to happen if you withdraw your consent. For example, we may not be able to continue providing some or all of our products and services to you. Withdrawing consent does not affect our right to keep using your Personal Data where the law permits or requires us to.

 

5. Disclosure of Personal Data

We do not sell, rent or trade your Personal Data. We disclose it only for the purposes set out in section 3, to the following parties, who may be in or outside Singapore:

• (a) our related corporations and affiliates, who help us provide and support our services;

• (b) banks, trustees, custodians, fund administrators, transfer agents, IT and cloud service providers, and other contractors who provide services to us or on our behalf;

• (c) our professional advisers, such as lawyers and auditors;

• (d) regulators, government authorities, law enforcement agencies, courts and credit reference agencies, where disclosure is necessary to (i) comply with applicable law or regulation, (ii) establish, exercise or defend our legal rights, (iii) carry out credit and identity checks, or (iv) protect your vital interests or those of another person;

• (e) a purchaser or successor, if all or part of our business is sold, merged or restructured; and

• (f) any other person you have asked us to deal with, such as your financial adviser, or anyone else with your consent.

 

We require our service providers to protect your Personal Data and to use it only to provide services to us. Some providers, such as online communication platforms, may also handle Personal Data under their own privacy policies.

 

6. Protection and Security

We make reasonable security arrangements to protect your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal and loss. These include:

• (a) administrative, technical and physical security controls suited to the nature of the data and our business;

• (b) limiting access to Personal Data to employees and service providers who need it, on a need-to-know basis;

• (c) requiring our employees to keep Personal Data confidential, and training them on data protection; and

• (d) securely destroying unsolicited Personal Data that we do not need.

 

No method of transmission over the internet or of electronic storage is completely secure. We cannot guarantee the security of information you send to us online, and you send it at your own risk.

If a data breach occurs, we will assess it and notify the Personal Data Protection Commission (PDPC) and affected individuals as the PDPA requires.

 

7. Your Account and Password

If you have an account on the Site, you are responsible for keeping your username and password confidential and for logging out after each session. Our staff will never ask for your password.

If you suspect unauthorised use of your account, tell us immediately (see section 15). We are not liable for any loss arising from unauthorised use of your account that results from your failure to keep your login details secure.

 

8. Retention of Personal Data

We keep your Personal Data only for as long as we need it for the purposes it was collected for, or as required for legal, regulatory, tax or business reasons. When we no longer need it, we will securely destroy it or anonymise it. We may keep anonymised and aggregated data for analysis.

 

9. Minors

The Site and our products are not intended for anyone under 18. If you are under 18, please do not give us any Personal Data unless your parent or guardian has consented.

We only collect a child's Personal Data as described in section 1(g). If we learn that we have collected a child's Personal Data without the required consent, we will delete it.

 

10. Marketing Communications

We send marketing and promotional communications only where you have agreed to receive them, or where the law otherwise permits. We do not sell, rent or give your email address to third parties for their own marketing.

You can unsubscribe at any time by using the link in any marketing email or by contacting us (see section 15). We will still send you communications we must send for legal reasons or to service your account.

 

11. Transfers Outside Singapore

We may transfer, store or process your Personal Data outside Singapore, for example with service providers located overseas. When we do, we will comply with the PDPA and the Personal Data Protection Regulations 2021. This includes taking appropriate steps to ensure that the recipient is bound to protect your Personal Data to a standard comparable to the PDPA.

 

If you are in the European Union or the United Kingdom, we will use a lawful transfer mechanism recognised under the laws that apply to you. Contact us for more information.

 

12. Your Rights

Under the PDPA, you have the right to:

• (a) access: ask for a copy of the Personal Data we hold about you and information about how it has been used or disclosed in the past year;

• (b) correction: ask us to correct any error or omission in your Personal Data; and

• (c) withdraw consent: withdraw your consent to our collecting, using or disclosing your Personal Data (see section 4).

 

Depending on where you live, the laws that apply to you may give you further rights. These may include the right to ask us to delete, restrict or transfer your Personal Data, to object to certain processing, or not to be subject to decisions made solely by automated means. We will respect these rights where the applicable law provides them.

To exercise any of these rights, contact us (see section 15). We may need to verify your identity first. We aim to respond within 30 days. If we need more time, we will tell you when we expect to respond.

We do not usually charge for an access request. If we do, we will tell you the fee before we process the request. We may refuse a request where the law permits, for example where it relates to opinion data kept solely for evaluative purposes. If we refuse, we will give you our reasons.

If you are not satisfied with our response, you may complain to the Personal Data Protection Commission in Singapore, or to the data protection authority where you live.

 

13. Cookies and Technical Data

Cookies are small data files that are placed on your device when you visit the Site. We use the following types:

• (a) Strictly necessary cookies, which the Site needs to work. For example, these let you log in to secure areas.

• (b) Analytics and performance cookies, which count visitors and show how people move around the Site. We use services such as Google Analytics for this, and the information helps us improve the Site.

• (c) Functionality cookies, which recognise you when you return and remember your preferences, such as language or region.

• (d) Targeting cookies, which record the pages you visit and the links you follow. We use these to make the Site and our advertising more relevant to you, and we may share this information with third parties for that purpose.

We also collect your IP address, which your internet service provider assigns to your device. We use it to run the Site, diagnose problems and produce aggregated statistics.

The Site may include social media features, such as LinkedIn, Facebook or X buttons. 

 

These may collect your IP address and the page you are visiting, and may set cookies. Your use of these features is governed by the provider's privacy policy.

You can set your browser to refuse cookies, delete them, or alert you before they are stored. If you block cookies, some parts of the Site may not work properly.

 

14. Third-Party Websites

The Site may link to websites run by other parties. We do not control those websites and are not responsible for their content or privacy practices. A link does not mean we endorse the website. We encourage you to read the privacy policy of any website you visit.

 

15. Changes to this Privacy Policy and Contact Us

We may update this Privacy Policy from time to time. We will post the updated version on the Site with its effective date. If the changes are significant, we will take reasonable steps to tell you. If you keep using the Site or our services after an update, you accept the updated Privacy Policy.

 

If you have any questions, would like to access or correct your Personal Data, want to withdraw consent or wish to make a complaint, please contact our Data Protection Officer:

 

Data Protection Officer

Auspac Investment Management Pte. Ltd. 

47 Craig Road, Singapore 059915 

Email: info@auspacim.com

 

Last updated: 8 October 2026