ROCKWORTH’S PERSONAL DATA PROTECTION POLICY
Revised and Posted as of 15 July 2020
Protection of your Personal Data is important to us, and Rockworth Capital Partners Pte Ltd (“Rockworth”) takes its responsibilities under the Singapore Personal Data Protection Act (No. 26 of 2012) (“PDPA”, or “the Act”) very seriously.
This Rockworth Personal Data Protection Policy (“Data Protection Policy”, or “Policy”) outlines how we manage the Personal Data we hold, and informs you of how we collect, use, manage, disclose and/or process your Personal Data (as defined below) that you entrust to us, subject to the PDPA.
The Act is designed to protect the confidentiality of data and the privacy of individuals by regulating the way in which Personal Data is managed.
Please take a moment to read this Data Protection 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 and services offered by us, you agree and consent to Rockworth, including any of its representatives and/or agents, collecting, using, storing, processing, disclosing and sharing amongst themselves your Personal Data as data controllers, and disclosing such Personal Data to Rockworth’s authorised service providers and relevant third parties either as data controllers and data processors as appropriate in the manner set forth in Policy.
Your consent to this Policy supplements but does not supersede nor replace any other consents you may have previously provided to Rockworth nor does it affect any rights which Rockworth may have at law in connection with the collection, use or disclosure of your Personal Data.
This does not affect any rights which Rockworth may have at law in connection with the collection, use or disclosure of your Personal Data.
- Your Personal Data
- “Personal Data” refers to any data or information, whether true or not, about you from which you can be identified either (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 which you may provide us include (depending on the nature of your interaction with us):
- your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
- information about your use of our websites and services, including cookies, IP addresses, and account details;
- your employment history, education background, occupation and income levels;
- your background / know-your-client information which was collected or provided for the purposes of meeting legal compliance requirements; and
- your payment related information, such as your bank account or credit card information, and your credit history.
- Where you are a corporate entity, such personal data may include information about your directors, officers, employees, beneficial owners, partners, members, authorised signatories, representatives, agents, guarantors, other security providers and other natural persons related to you.
- Collection of Personal Data
- Generally, Rockworth collects your Personal Data in the following ways:
- when you submit forms, including but not limited to customer inquiry forms or other forms relating to any of our services;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us;
- when you use any of our services;
- when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online forms, reservation chat, social media platforms and emails;
- when you request that we contact you;
- when you respond to any request from us, including our marketing representatives, sales representatives or partners; for additional Personal Data;
- when you ask to be included in an email or other mailing list;
- when you participate in our outreach events or activities (eg. investor outreach, staff recruitment events), marketing pitches / meetings, introductions or other events or activities;
- when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
- 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 our events;
- when we carry out your instructions or respond to any enquiry purporting to be given by you or on your behalf;
- when we receive references or background information from business partners and third parties, for example, where you have been referred by them;
- when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
- when you browse our website; 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 Paragraph 6 below for information on cookies and other technologies which we have implemented on our website.
- We may collect your Personal Data for the purposes of managing the administrative and business operations of Rockworth and complying with internal policies and procedures, including conducting audits, preventing, detecting and investigating crime and analysing and managing commercial risks and conducting investigations relating to disputes, billing, fraud, money-laundering, financing of terrorism, and other related purposes.
- We may collect your Personal Data in order to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Rockworth, to facilitate any mergers, acquisitions or asset sales and to safeguard and enforce our contractual and legal rights and obligations, and other related purposes.
- We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. We will inform you about the recording when you call us and give you the opportunity to indicate that you do not wish for the conversation to be recorded.
- If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.
- You have the option of not providing the Personal Data requested (see Paragraphs 11 and 12 below). However, please note that we may be legally permitted or required to continue to collect your Personal Data in certain circumstances in accordance with applicable law even if you withdraw your consent.
- Depending on the nature of your request and the Personal Data concerned (for example, if you do not provide us with necessary or mandatory information), we may not be able to process your inquiries, registrations or requests, or continue providing you with the products or services requested or administer any contractual relationship which may be in place.
- You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. In the event your Personal Data becomes inaccurate because of modifications, it is your responsibility to update your information with Rockworth. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
- Generally, Rockworth collects your Personal Data in the following ways:
- Use and Disclosure of Personal Data
- Our business is to understand and meet your needs and provide you with the products and services that you require. We utilise Personal Data collected about you to do so effectively.
- In general, Rockworth uses and discloses your Personal Data for the following purposes:
- to provide you with the products or services that have been requested;
- to provide you with information and updates about your investment portfolios, products and services, in accordance with Rockworth’s internal rules and regulations;
- to record business carried on by us;
- to conduct any due diligence checks as necessary;
- to verify your identity;
- to help us manage the delivery of and enhance our products and services, including analysing future customer needs;
- to access and manage your financial, real estate or other assets in the course of delivering our products and services as agreed upon, including but not limited to the allotting and transferring interests in funds or accounts and identifying or assessing (and advising you on) the suitability and value of current and potential investments;
- to enter into or perform any financial transaction, as mutually agreed upon, on your behalf;
- to communicate with you and provide information and updates about your investment portfolio (including by the issue of statements), and to update you periodically in relation to the products or services which you are subscribed to or which you have requested us to provide;
- to send you property market updates, property newsletters and other information on our products, services, offers or promotions which may be of interest to you;
- to respond to your queries, requests and complaints;
- to request feedback or participation in surveys;
- to conduct market research or data analysis for statistical, profiling or other purposes for us to design our services, understand customer behaviour, preferences and market trends, in order for us to review, develop and improve the quality of our products and services, and to develop special offers, financial products, promotional and/or marketing programmes pertinent to our client base or personalised to your needs and preferences;
- to provide ongoing information about our products and services which may be of interest to you;
- to draft and review documents, transaction documentation, to obtain legal advice, or to facilitate dispute resolution;
- to protect and enforce our contractual and legal rights and obligations;
- to carry out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or in accordance with our risk management procedures;
- to prevent, detect and investigate crime, including fraud, money-laundering, and terrorism financing, and to analyse and manage other commercial risks;
- to manage the infrastructure and business operations of Rockworth and to comply with internal policies and procedures;
- to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
- to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving Rockworth;
- to collect amounts outstanding from you where guarantees or security were provided for your debts;
- to match Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Rockworth or third parties;
- to comply with any applicable rules, laws and regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Rockworth (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations), or to assist in law enforcement and investigations by relevant authorities in Singapore or elsewhere;
- to deliver any other services as may be agreed to between you and Rockworth; and/or
- purposes which are reasonably related to the aforesaid.
- In addition, Rockworth may use and disclose your Personal Data for the purposes of your investments with us and investments made by for us in respect of assets or investments managed for you, including:
- for administrative purposes such as verification and background checks on you;
- to administer and manage such investments;
- to conduct financial reporting and analysis;
- to comply with any applicable rules, laws and regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Rockworth (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations), or to assist in law enforcement and investigations by relevant authorities in Singapore or elsewhere; and/or
- for any purposes which are reasonably related to the aforesaid.
- In each case described in paragraphs 2 and 3.3 above, we will only send you marketing and promotional material where such practice is in accordance with applicable laws and, where required under applicable laws, with your prior express consent.
- Where you are an individual who have submitted an application to us as a candidate for prospective employment, Rockworth may also use and disclose your Personal Data for the following purposes:
- to process your application including pre-recruitment checks;
- to provide or to obtain references for background screening/vetting;
- to collect information about your suitability for the position applied for;
- to organise training and staff development programs;
- to assess your performance;
- to conduct interviews;
- to enrol successful candidates as our employees and facilitating human resource planning and management (including but not limited to preparing letters of employment, name cards and building access passes);
- to communicate with you as required by Rockworth to comply with its policies and processes, including for business continuity purposes; and
- any other purposes relating to the aforesaid.
- In relation to particular products or services or in your interactions with us, we may also notify or have specifically notified you of other purposes for which we collect, use or 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.
- Your Personal Data will be protected and kept confidential. However, subject to the provisions of any applicable law, and in order to conduct our business operations more smoothly, we may be disclosing your Personal Data you have provided to us (with your consent) to the following third parties:
- agents, contractors, third party service providers and specialist advisers to Rockworth who have been contracted to provide Rockworth with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
- insurers or insurance investigators and credit providers;
- credit bureaus, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving Rockworth;
- our professional advisors such as our consultants, auditors and lawyers;
- relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
- anyone to whom we transfer or may transfer our rights and obligations;
- banks, credit card companies and their respective service providers;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
- our corporate clients; and/or
- any other party as may be consented to by you, as specified by that individual or in the applicable contract.
We require that organisations outside Rockworth which handle or obtain Personal Data as service providers to Rockworth acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.
- In carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers. Some of these related corporations and third party service providers may be located in countries outside Singapore that may not afford an adequate protection to personal data or have protections in place which are similar to those in your country of residence. However, Rockworth will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected.
- Rockworth will take reasonable steps using administrative, technical and physical safeguards to protect your Personal Data. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of the personal data provided. However, we cannot assume responsibility for any unauthorised use of such personal data by third parties which are wholly attributable to factors beyond our control.
- You always have the option of withdrawing your consent to any or all use of your Personal Data, (seeParagraphs 11 and 12 below), although please note that we may be legally permitted or required to continue to process your Personal Data in certain circumstances in accordance with applicable law even if you withdraw your consent.
- While we will not disclose personal data provided to us to third parties without first obtaining the relevant consent(s) permitting us to do so, please note that we may disclose the personal data you provided to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
- cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;
- cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
- cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
- cases in which the disclosure is necessary for any investigation or proceedings;
- cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
- cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
- where such disclosure without your consent is permitted by the PDPA or by law.
- However, depending on the nature of your request and the Personal Data concerned we may not be able to process your registration or request, or continue providing you with the products or services requested or administer any contractual relationship which may be in place.
- Keeping Your Personal Data Accurate and Up-To-Date
- We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.
- Do Not Call Provisions
- Our laws regulating telemarketing relates only to individual users of Singapore telephone numbers, and where we do conduct telemarketing, our policy is to comply with the Do Not Call (“ DNC”) provisions under Singapore’s Personal Data Protection Act 2012 (“ PDPA”). We do not generally conduct telemarketing except where this is business to business telemarketing (if at all), which is not prohibited by the DNC provisions.
- Use of Log Files, Cookies & DoubleClick DART Cookies
- As with most other websites, we collect and use the data contained in log files. The information in the log files include your IP (internet protocol) address, your ISP (internet service provider, such as AOL or Shaw Cable), the browser you used to visit our site (such as Internet Explorer or Firefox), the time you visited our site and which pages you visited throughout our site.
- A cookie is a small file containing a string of characters that is sent to your computer when you visit our websites for record keeping purposes.
- Cookies are stored in your browser’s file directory, and the next time you visit the website, your browser will read the cookie and relay the information back to the website or element that originally set the cookie.
- Depending on the type of cookie it is, cookies may store user preferences and other information, such as how a visitor arrives at our sites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page). There are several types of cookies:
- Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session.
- Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites.
- First-party cookies are set by the site you are visiting.
- Third-party cookies are set by a third party site separate from the site you are visiting.
- We also may use DART cookies for ad serving through Google’s DoubleClick, which places a cookie on your computer when you are browsing the web and visit a site using DoubleClick advertising (including some Google AdSense advertisements). This cookie is used to serve ads specific to you and your interests (“interest based targeting”). The ads served will be targeted based on your previous browsing history (For example, if you have been viewing sites about visiting Las Vegas, you may see Las Vegas hotel advertisements when viewing a non-related site, such as on a site about hockey). DART uses “non-personally identifiable information”. It does NOT track personal information about you, such as your name, email address, physical address, telephone number, social security numbers, bank account numbers or credit card numbers. You can opt-out of this ad serving on all sites using this advertising by visitinghttp://www.doubleclick.com/privacy/dart_adserving.aspx
- Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options. Deleting cookies does not mean you are permanently opted out of any advertising program. Unless you have settings that disallow cookies, the next time you visit a site running the advertisements, a new cookie will be added.
- Web beacons are small graphic images (also known as “pixel tags” or “clear GIFs”) which may be included on our sites and services. Web beacons typically work in conjunction with cookies to profile each unique user and user behaviour.
- We offer certain site features and services that are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits.
However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.
- To track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
- To make the websites easier to use and to better tailor our products and services to your interests and needs.
- To help speed up your future browsing activities and boost your overall user experience on our websites.
- To enable our websites to operate, for example, cookies that enable you to log onto secure parts of our websites.
- When you interact with us on our websites, cookies may be used to collect for the purposes of analysis statistical information from which individuals cannot be identified (“ Aggregate Information”), such as number of users, their frequency of use, the number of page views (or page impressions) that occur on the websites and common entry and exit points into and out of the websites.
- The Aggregate Information is purely statistical in nature to understand how people use our websites and to help us improve their structure and contents. We cannot identify you personally from this information.
- Which cookies are used on our website?
Cookie Name Purpose Google Analytics These cookies are used to collect information about how visitors use our Site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Session cookies These cookies are used to make the websites easier for you to use, and to enable you to navigate from page to page within each website more easily.
These cookies are automatically deleted once you close your browser.
Unique third-party persistent cookies, clear gifs or beacon gifs These cookies do not collect personally identifiable information on you. The information collected via these cookies are used to build profiles of different types of users in order to better tailor our products and services to each profiled group of visitors.
- As we use Google Analytics on the website, a service provided by Google Inc, you should also review the Google Analytics security and privacy principles available at https://support.google.com/analytics/answer/6004245?hl=en. We use Google Analytics cookies to collect information about how visitors use our websites and the total number of times a visitor has been into our website. We use the information to improve the website and enhance the experience of our online visitors. You can, at any time, opt-out from the use of Google Analytics by either changing the settings on your browser accordingly or by clicking at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.
- Information stored in cookies on the website is used exclusively by Rockworth except the one saved by Google Analytics, which is used and maintained by Google and Rockworth, for statistical purposes. Our third party ad-servers, if any, may also use the information stored in the cookies to customise your website experience. We do not have any direct control over the content of these adverts.
- The way which cookies can be managed depends on your browser. The following links provide information on how to configure or disable cookies in each browser:
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Internet Explorer: http://windows.microsoft.com/en-SG/internet-explorer/delete-manage-cookies#ie=ie-9
- Safari: http://support.apple.com/kb/HT1677?utm_source=Agillic%20Dialogue
- Safari for iPhone: http://support.apple.com/kb/ta38619
- Chrome for Android: https://support.google.com/chrome/answer/2392971?hl=en
- Third-Party Sites
- Storing of Personal Data
- We will safeguard the confidentiality of your Personal Data, whether you interact with us personally, by telephone or mail, over the Internet or other electronic media. We hold Personal Data in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the Personal Data we hold from misuse, loss, unauthorised access, modification or disclosure.
- We do not keep Personal Data longer than is necessary and will destroy or anonymise Personal Data which we no longer require.
- Term of Retention of Your Personal Data
We will retain your information for a term which shall not exceed the time strictly necessary for the purposes set out in this Policy, or for our legal or business purposes. In any case, such retention will not exceed seven (7) years after the last contact between you and us, unless you continue to have a subsisting relationship with us.
- Management and Security
We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the PDPA. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data. Rockworth regards breaches of the PDPA very seriously.
- Withdrawal of Consent
- You may withdraw your consent given for any or all purposes set out in this Policy in writing by emailingDPO@rockworth.com.sg.
- If you withdraw your consent to any or all purposes and depending on the nature of your request, Rockworth may not be in a position to continue to provide our products or services to you. Without prejudice to the foregoing, you agree and acknowledge any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to Rockworth in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information.
- Contacting Us
- In accordance with applicable law, you have a right to access, update, rectify and modify the Personal Data we have about you which is held by us. You also have a right to oppose, for legitimate grounds, to the processing of your information, including objecting to the processing of user profiles or to the use of your Personal Data for marketing purposes. Should you oppose to the processing of your information for legitimate grounds, you understand that we may not be able to provide you with the Products and Services.
- You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will require adequate information from you in order to ascertain your identity as well as the nature of your request, so as to be able to process your request.
- For a request to rectify personal data, once we have sufficient information from you to process the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Please note that the PDPA exempts certain types of personal data from being subject to your correction request.
- We may/will charge you a service fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or process your access request unless you have agreed to pay the fee.
- You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control.
- We will process your request within 30 days from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
- If you wish to withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Rockworth may not be in a position to continue to provide its services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Rockworth, and your being in breach of your contractual obligations or undertakings. Rockworth’s legal rights and remedies in such event are expressly reserved.
- If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), or would like to exercise any of the rights set out in Paragraph 12.1, please contact the designated Data Protection Officer for Rockworth as follows:
Name of Data Protection Officer (DPO) Contact Number Email Address Zyn Leow
+65 6438 6630 DPO@rockworth.com.sg
- Please note that if your Personal Data has been provided to us by a third party (e.g. a general practitioner or your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Rockworth on your behalf.
- Governing Law
- Amendments and Updates of the Policy
- As part of our efforts to ensure that we properly manage, protect and process personal data provided to us, this Policy will be reviewed from time to time by Rockworth. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.
- We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at
- In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.