Pursuant to the Singapore Personal Data Protection Act (the "PDPA"), this Personal Information Statement (the "Statement") is provided to you in connection with your dealings with and provision of data or information to FIL Investment Management (Singapore) Limited ("Fidelity") or its holding company, representative offices, subsidiaries and affiliates from time to time. The Statement sets out Fidelity's policy on its collection, use and disclosure of personal information.
Fidelity is committed to protecting your personal data in accordance with the requirements of the PDPA, and will take all reasonable steps to ensure that your personal data is kept secure against unauthorised access, loss, disclosure and destruction.
What personal information does Fidelity collect?
The type of personal information collected depends on how you interact with us and which of our products or services you use.
If you acquire our products and services, we may require your personal particulars (e.g. name contact information, date of birth, national identification number).
Sometimes we may need to collect personal information about individuals who are not customers of Fidelity (e.g. business contact details of a company representative whom we deal with).
Generally, we will not collect sensitive information about you (such as your race, political beliefs, religion or health) unless this is required to enable us to provide you with services. If we need sensitive information, we will ask for your consent when we collect this information (unless an exception applies).
Fidelity will also collect information about the use of our website which includes the number of users, when they visit, how they navigate through the pages, which pages are visited and the amount of time spent on looking through the website. Additionally, if you have accessed this website from another site, the address of that website will be known and your identity may be able to be matched to your use of the website.
By using this website, you agree to our collection and use of this information.
Similar statistical information is also collected when we distribute other electronic material such as marketing information on our products and services or market updates.
How is the personal information collected and stored?
This will depend on how you interact with us or the services you request from us. We may collect personal information about you from an application form or a registration form or verbally if you call our call center, or speak directly with our staff.
If you access this site, we may collect information about your visits by using 'cookies'. A cookie is a packet of information which is sent by our website to your computer to track your use of our website and to allow you to effectively access your account information. In general, we use 'cookies' for security purposes and to assess the usage and improve the functionality of our website.
You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please refer to your browser instructions or help screens to learn more about these functions. If you reject all cookies, you may not be able to use our web sites.
Protecting your personal information is a priority to us. Fidelity takes reasonable steps to ensure the security of personal information and takes measures to avoid risks such as loss or unauthorised access, destruction, use, modification or disclosure. Your information will be held in confidence and will not be passed to any persons, other than as already indicated in this Statement, without your consent, or unless required by law.
Within Fidelity, access to non-public information about a client is restricted to employees who need to know the information to provide products or services to the client. Fidelity maintains physical, electronic and procedural safeguards that protect client information.
To assist us with ensuring the security of your information, we ask that you observe security measures in relation to your username and password which are used to access the restricted areas of the site.
How is the personal information used?
From time to time, it is necessary for clients and various other individuals ("data subject") to supply Fidelity with data in connection with various matters such as account opening or continuations, or provision of services to clients and other individuals. Failure to supply such data may result in Fidelity being unable to open an account or continue providing services to clients and various other individuals, or comply with any laws or guidelines issued by regulatory or other authorities.
It is also the case that personal information is collected from data subjects in the ordinary course of the continuation of Fidelity's relationship with them.
The purposes for which personal information may be collected, used or disclosed will vary depending on the nature of your relationship with Fidelity. To the extent applicable, Fidelity collects, uses and/or discloses the personal information for the following purposes in connection with the products and services which you have applied for:
- Processing your application for any of the products or services offered by Fidelity;
- Managing our relationship with you;
- Evaluating your eligibility profile;
- Providing the products and services applied for by you;
- Performing verification;
- Generating financial, regulatory, management or other related reports and performance analytics;
- Preventing, detecting and investigating crime, offences or breaches including fraud, money laundering, counter-terrorist financing and bribery;
- Meeting or complying with Fidelity's internal policies and procedures;
- Complying with any applicable rules, laws, regulations or guidelines issued by a competent authority;
- Legal purposes;
- Handling customer feedback or complaints;
- Organising financial, investment seminars/events/forums;
- Designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision of services by Fidelity;
- Enabling a potential purchaser of all or any part of the business or shares of Fidelity to evaluate the transaction intended to be the subject of the purchase; and
- Maintaining the security of our office premises (including the use of closed-circuit cameras).
At present, Fidelity has no intention to use the personal information in its possession for direct marketing purposes. If it does, Fidelity will request the consent (which includes an indication of no objection) from the individuals concerned, as well as check against the "Do Not Call" registry maintained by the Singapore Personal Data Protection Commission.
Will the personal information be disclosed?
Personal information may be disclosed outside of Fidelity for any one of the purposes as set out in the preceding section.
The parties whom Fidelity may disclose personal information to, may include but not limited to -
- Law enforcement agencies, government agencies, or courts
- Service providers (e.g. mailing and printing companies)
- Distributors of Fidelity products and services
- Banks or agents which handle or process payments
- Fidelity's group of companies
Fidelity may also disclose the information to third parties that are located offshore. We will only do so where this is permitted by law or where we have your consent to do so.
Can you access and correct your personal information?
You have a right to seek access to information which we hold about you, although there are some exceptions to this (e.g. MAS Notices on Anti-money Laundering and Countering the Financing of Terrorists). In accordance with the PDPA, Fidelity reserves the right to charge a reasonable fee for the processing of any data access request.
You also have the right to ask Fidelity to correct information about you which is inaccurate, incomplete or out-of-date. We will use all reasonable efforts to provide you with access as well as correct the information.
To assist us in this process, please ensure that you advise us of any changes to your contact details (e.g. phone numbers and email addresses) and alert us if you believe your personal information held by us is incorrect. In most instances, Fidelity may need to refer your requests to the distributors, whom you have purchased our products or services from, for verification purposes before we could proceed to amend or correct your personal information.
This website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.
When you use or purchase Fidelity's products and services, you are deemed to agree to our collection, use and disclosure of personal information as set out in this Statement.
You may withdraw your consent by providing a written notification to Fidelity at the contact address stated below. If you withdraw your consent, Fidelity may not be in a position to continue to provide our products or services to you.
Your withdrawal may also be considered a termination by you of any contractual relationship which you may have with Fidelity, and in most instances, Fidelity may need to request that you contact the distributors, whom you have purchase our products or services from, to effect the termination.
Changes to this statement
This Statement is subject to change from time to time for any reason(s) without prior notice. You should periodically check this Statement to ensure you are aware of how your personal information may be collected, used or disclosed.
If you have -
- if you have a complaint about our collection, use or management of your personal information, or
- if you wish to access or correct your personal information,
please contact Fidelity's Privacy Compliance Officer in writing at the following address:
Privacy Compliance Officer
FIL Investment Management (Singapore) Limited
8 Marina View, #35-06, Asia Square Tower 1