Global Investments Limited (“GIL”) treats your personal data in accordance with the policies set forth below, which is governed by, among others, the Personal Data Protection Act “PDPA”).
(1) Use of Personal Data
Personal data such as your name, address and NRIC Number provided to GIL may be processed by GIL and third parties (including ST Asset Management Ltd. (“STAM”) and its agents) on behalf of GIL for any of the following purposes (“Purposes”):
- statutory compliance with the Bermuda Companies Act 1981, Bermuda Investment Funds Act 2006, the Securities and Futures Act Cap 289, the Singapore Companies Act Cap 50, the listing rules of the Singapore Exchange and other applicable relevant laws, as may be amended from time to time;
- management of investors, including the compilation of investors’ data and implementing various measures to ensure a smooth relationship between investors and GIL;
- responding to your enquiries or requests pursuant to emails, telephone calls, faxes and/or completion of forms;
- responding to and taking follow-up action on complaints;
- performing office and operational administrative matters following your request; and
- for any other purpose that is incidental or ancillary or in furtherance to any or all of the above.
You are deemed to have:
- provided consent to the collection and use of your personal data in instances where you have provided such personal data for the Purposes and to the disclosure to STAM and its agents, and other third parties as GIL and STAM may think fit for the Purposes;
- obtained the consent of the third party when you provide personal data of such third party to act as his or her proxy at any general meeting, to the disclosure of personal data of such third party to GIL, STAM and to other third parties as GIL and STAM deem fit and the subsequent processing of such personal data.
If you wish to withdraw your consent to the collection, use or disclosure of your personal data at any time in the future, GIL will require your written request to our Data Privacy Officer (see details under Section B(4) below). As a consequence of withdrawal of consent, if you are an investor, your rights may be affected and GIL may not be able to carry out the Purposes for which you have provided the personal data.
(3) Access to and Correction of Personal Data
GIL may, upon your written request to our Data Privacy Officer (see details under Section B(4) below, allow you to have access to your stored personal data or correct an error or omission in the personal data. GIL may charge a reasonable administrative fee for such service. In exceptional circumstances, GIL reserves the right to deny your request and may provide an explanation as required by applicable laws. Such exceptional circumstances include where (i) such requests would unreasonably interfere with the operations of GIL because of the repetitious nature of such requests or if an investigating authority or government institution objects to GIL complying with such request.
GIL will retain your personal data for as long as it is necessary to fulfil the Purposes for which it was collected, or as required by relevant laws.
GIL takes reasonable steps to ensure that personal data collected by or on its behalf is accurate and complete and will update the information that it has collected where necessary.
(6) Transfer of Information Overseas
As GIL is incorporated in Bermuda, personal data of investors will be transferred to service providers in Bermuda.
There are circumstances in which GIL would not need to seek your consent to collect, use and disclose your personal data and these are set out in the PDPA.
(8) Security safeguards
GIL has in place measures to secure and protect your personal data. As a matter of principle, GIL restricts access to personal data on a need-to know basis and only for the Purposes.
(B) Other Matters
(1) Links to other Websites
GIL collects general information (such as browser type, files requested, and the domain name and country from which you request information) periodically in order to improve this website. This website may have pages that contain “cookies” which are small amounts of data sent by our website and stored on your computer’s hard drive. This allows GIL servers to recognise you when you visit the website in the future. Most web browsers can be configured not to accept cookies, or to notify you if a cookie is sent to you. If you voluntarily provide personal data to GIL through our website or e-mail correspondence, we may collect and use that information to respond to your inquiries or to supply you with requested information. Although GIL uses security measures that we believe to be appropriate to protect the limited personal data disclosed to GIL through this website, GIL does not guarantee that its security precautions will protect against and we expressly disclaim any liability for any loss, misuse, or alteration of your information or from your access to or use of our information.
(4) Contact Us
- have any questions or feedback relating to your personal data or this policy;
- would like to withdraw your consent to the collection, use or disclosure of your personal data as set out in this Data Protection Policy;
- would like to obtain access or make corrections to your personal data records, please contact our Data Protection Officer as follows:
Write to: Data Protection Officer
Global Investments Limited
c/o ST Asset Management Ltd.
60B Orchard Road
#06-18 Tower 2
The Atrium @Orchard