The protection of your personal data is a very serious matter for us.
This should be the case for any business which collects user data in the course of business but for us it runs deeper than that. We specifically set this business up to help consumers to get their wealth working. We want to provide a simple and effective way of doing that for our users. Earning money from selling your contact details is not part of our business model nor our ethos. We take pride in bringing a helpful and trustworthy business to our users and that is far more important to us than degrading our brand by trying to sell your personal details.
There is an important distinction between what we call ‘personal details’ and simply other information that you provide us. Your ‘personal details’ is information that identifies you. In our case if you use us to search for a Professional Service Firm we ask for your Name, Email and Phone number to search for a Professional Service Firm. We have to ask you for that so that we can a) tell you who your best-matches are, and b) communicate with you to refine your matches if needed, and c) introduce you to the chosen Professional Service Firms if you choose to pursue that. We are not responsible for the privacy policies, activities and any content provided by Professional Service Firms and their websites, and we would recommend that you read the privacy policies and terms on any external sites you use.
The rest of your information is anonymised information which by itself is incapable of identifying you. However, we look at all the anonymised data that we collect to work out interesting trends that we think will be of use to our users or to the wealth professional industry. We may publish this analysis. All with the aim of providing useful information to help wealth work better – both that of the consumers but also the services offered by the professionals.
Now to the legalities
The law of Singapore applies to these terms and conditions and any disputes will be subject to the exclusive jurisdiction of the Singapore courts.
Your express consent will be sought when collecting your personal details. There will also be instances where your consent for the collection or use of your personal details will necessarily be implied from the circumstances by nature of the task or transaction, including your interaction with us or in the course of signing up for, or accepting, any of our products, services or activities you have requested.
How we process your data
We will process your information for limited purposes that will include:
- responding to your requests;
- asking you for feedback;
- providing our services in accordance with our terms and conditions;
- developing and improving our services to you and to other customers;
- compiling technical and statistical data which we use to improve our Website and to provide you with information about products and services which may be of interest to you, which does not affect your right to opt-out from receiving marketing material;
- providing you with information about special features of our Website; and, occasionally,
- informing you by email or telephone about WEALTH services that may be of interest to you.
You may tell us by emailing us at [email protected] if you
- would like to withdraw your consent to any use of your personal details; or
- do not wish to receive marketing material from us. To the extent that marketing materials from us are sent to you via email, then all of our marketing emails feature an ‘unsubscribe’ function on the emails; or
- would like to obtain access and make corrections to your personal details; or
To protect your privacy and security, we will also require you to verify your identity before we can respond substantially to your request.
We do not share with others any personal details that you provide to us, except as described below.
(i) Marketing and business partners. As part our core business of introducing customers to Professional Service Firms to assist customers with specific investment management and/or financial planning needs, we share personal details that you provide with such Professional Service Firms for you to be introduced to them (“Referral”). To the extent that your personal details are collected and shared pursuant to a Referral, then the collection and processing of your personal details were undertaken for and on behalf of the Professional Service Firms. If you agree to receive Services from a Professional Service Firm subsequent to a Referral, then your information shall be processed in accordance with the terms of your agreement with that Professional Service Firm.
(iii) Where required by law, court order or necessity. We may release personal information if we believe in good faith that: the law or legal process requires it; we have received a valid administrative request from a law enforcement agency, including in connection with any investigation to help prevent unlawful activity; if required by any law or order of a court of competent jurisdiction or recognised regulatory body of competent jurisdiction; or such release is necessary to protect our rights, property or safety, or that of any of our affiliates, business partners or customers.
(v) Sale of business. If WEALTH’s business is sold or integrated with another business, as a going concern, your personal details that are in our possession or control may be disclosed to WEALTH’s advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.
We will process your personal details fairly and lawfully and will store this information in accordance with the relevant data protection legislation.
The information about you that we will use will depend upon the information that you give to us and the information that is necessary to collate in order to carry out our services for you. In all circumstances the information will be adequate, relevant and not excessive and will be processed in line with your rights. We do not collect any personally identifiable information from users of our ‘public’ area of our Website. All we do is to gather information on the numbers of visitors to certain areas and the manner in which the Website is navigated.
Most browsers are initially set to accept cookies, but you can alter this if you prefer. Your navigation of the Questionnaire and subsequent Results area may also be less efficient if your browser is set to disable persistent cookies (i.e. those which remain permanently on the cookie file of your computer). Please visit http://www.allaboutcookies.org/manage-cookies/ for more information on how cookies work and how they may be managed.
Protecting your personal details
We are committed to ensuring the security and protection of your personal details in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks.
Examples where WEALTH has put in place the security procedures and technical and organisational measures to safeguard your personal information include:
- your answers to the Questionnaire shall be stored on a secure network;
- the Website is regularly assessed and tested by third party security experts, the Website is certified as being compliant with Industry Data Security Standards and WEALTH keeps up to date with the latest threats and vulnerabilities, to ensure that you are protected;
- WEALTH’s servers run the latest patched software versions to avoid any compromise due to known vulnerabilities;
- WEALTH’s servers are protected by high specification Cisco PIX firewall hardware;
- the Website employs advanced 128-bit hashing encryption to store user login credentials; and
- the Website is protected by an advanced 128-bit encryption Extended Validation Secure Socket Layer (SSL) from Godaddy to ensure that no data can be intercepted by malicious third parties when in transit from WEALTH to the Professional Service Firms.
However, the use of the internet is not entirely secure and for this reason WEALTH cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet, or that no harmful code will enter our Websites (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with disclosing any information or transacting over the Internet or when using online portals, and we urge you to take every precaution when using the Internet to disclose your personal details to us, including using strong passwords, changing your password regularly and using a secure browser.
If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any loss or damage resulting from your act or omission to safe-keep your username and password from unauthorised use.
Access to your information
You may enquire about the personal details that WEALTH hold about you, namely the ways in which your personal data has been or may have been used or disclosed within a year before the request, by sending an email to [email protected]. WEALTH where required or authorised to do so by law, we reserve the right to charge a reasonable administrative fee for this service and/or deny your request for access to your Personal Data.