Personal Data Protection Policy
DATA PROTECTION NOTICE
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 2012 of Singapore (“PDPA”).
This Data Protection Notice (“Notice”) sets out the basis on which GIL may collect, use, disclose or otherwise process personal data of our stakeholders in accordance with the PDPA.
This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
(A) General Privacy Policy Statement
(1) Collection, Use and Disclosure of Personal Data
Personal data such as your name and identification information such as your NRIC Number, contact information such as your address, email address or telephone number, nationality, photographs and other audio-visual information, employment information and financial information provided to GIL may be processed by GIL and third parties (including the Manager of GIL, Singapore Consortium Investment Management Limited (“SICIM”) and its agents) on behalf of GIL for any of the following purposes (“Purposes”):
1. statutory compliance with the Singapore Securities and Futures Act 2001, Companies Act 1967, listing rules of the Singapore Exchange and any other applicable laws, regulations, codes of practice, guidelines, or rules (as may be amended from time to time) or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
2. management of investors, including the compilation of investors’ data and implementing various measures to ensure a smooth relationship between investors and GIL;
3. responding to your enquiries or requests pursuant to emails, telephone calls, faxes and/or completion of forms;
4. verifying your identity;
5. responding to and taking follow-up action on complaints;
6. performing office and operational administrative matters following your request;
7. any other purposes for which you have provided the information;
8. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
9. any other incidental business purposes related to or in connection with the above.
(2) Consent
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
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 listed above and to the disclosure to GIL and/or SICIM and its agents, and other third parties as GIL and SICIM 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, SICIM and to other third parties as GIL and SICIM deem fit and the subsequent processing of such personal data.
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.
We may disclose your personal data: (a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or (b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed above for us. The Purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
(3) Withdrawing your Consent
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 Protection 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.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
(4) Access to and Correction of Personal Data
GIL may, upon your written request to our Data Protection 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 (ii) if an investigating authority or government institution objects to GIL complying with such request.
(5) Retention of Personal Data
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 or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
(6) Accuracy of Personal Data
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.
We generally rely on personal data provided by you or your authorised representative. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below. If you hold GIL shares in the securities account with The Central Depository (Pte) Limited (“CDP”), you should update the changes with CDP. If you hold GIL shares with a depository agent, you should update the changes with your depository agent.
(7) Protection of Personal Data
GIL has in place appropriate administrative, physical and technical 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.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
(8) Transfer of Personal Data outside of Singapore
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
(B) Other Matters
(1) Links to other Websites
As stated under the Terms and Conditions link of this site, GIL provides you with links to other websites for your convenience and information. GIL cannot control the policies of other websites we may link to, or the use of any personal data you may share with them. Please note that GIL’s Privacy Policy does not cover these other websites, and GIL recommends that you apprise yourself of their specific policies.
(2) Cookies
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.
(3) Effect of Notice and changes to Notice
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
(4) Contact Us
If you:
- 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:
Email: DPO@globalinvestmentslimited.com
Write to: Data Protection Officer
Global Investments Limited
250 Tanjong Pagar, #09-01 St Andrew Centre
Singapore 088541
Updated as of 28th October 2025