Protection of Personal Data is important to us. We outline how we manage the Personal Data we hold.
The words "we", "us", "our" or any of their derivatives refer to PIVOT and its successors and any novatee, assignee, transferee or purchaser of PIVOT's rights and/or obligations hereunder and any reference to PIVOT includes a reference to such successor, novatee, assignee, transferee or purchaser.
The words "you", "your", "yours" or any of their derivatives refer to the person(s) using PIVOT’s products and services which include operating any account maintained with us, accessing our online website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
- In the Act, Personal Data currently refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.
- PIVOT may also generate and compile information about you. Personal information provided by you and all information generated and compiled by PIVOT about you from time to time is collectively referred to as your "Personal Data".
Personal Data We Collect
- We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
Purpose of Collecting Your Personal Data
- 1. The purposes for which your Personal Data may be used are as follows:
- i. offering and providing services and products to you, which may include, financial services and products;
- ii. processing and assessing applications or requests made by you in connection with PIVOT's services or products, issuing or arranging financial reports and maintaining your account with PIVOT;
- iii. designing financial services and products;
- iv. marketing services and products to you;
- v. operating, maintaining and providing subsequent services in relation to the applications for services and/or products;
- vi. creating and maintaining the financial projection, credit, and risk related models of PIVOT;
- vii. processing payment instructions;
- viii. exercising any rights that PIVOT may have in connection with the services and/or products provided to you;
- ix. verifying and conducting any eligibility, credit, physical, security, and/or identity checks in connection with provision of services or products;
- x. complying with a foreign and domestic laws and regulations codes of practice or guidelines applicable to PIVOT;
- xi. meeting commitments with any legal, regulatory, governmental, tax, law enforcement or other authorities, industry bodies in Singapore or any other jurisdictions where the PIVOT has presence or business;
- xii. complying policies and procedures applicable within PIVOT; and
- xiii. any other purposes directly related to (i) to (xii) above.
- If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children, parents and/or beneficiaries) 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.
Disclosure of Your Personal Data
- 1. PIVOT may disclose your Personal Data with the following parties, whether within or outside Singapore for the purposes described in paragraph 9 above:
- i. persons or companies acting for or on behalf of PIVOT, (e.g. professional advisors);
- ii. persons or companies carrying on financial advisory or wealth planning-related activities engaged by PIVOT;
- iii. agents, contractors or service providers which provide services in relation to PIVOT’s businesses; and/or
- iv. persons or companies to whom PIVOT has to make disclosure under any law, rules, regulations, codes of practice or guidelines (whether applicable in or outside Singapore).
Using Your Personal Data
- PIVOT is allowed to (i) use your Personal Data in direct marketing only if you consent or do not object, or (ii) provide your Personal Data to another person or company for its use in direct marketing only if you consent or do not object in writing.
- In connection with direct marketing, PIVOT intends:
- i. to use your name, contact details, services and products information, financial background and demographic data held by PIVOT from time to time in direct marketing;
- ii. to market the following classes of services and products offered by PIVOT and/or Our Partners from time to time:
- • wealth management services and products;
- • financial services and products;
- • insurance services and products;
- • reward, loyalty or privileges programmes and related services and products; and
- • donations and contributions for charitable and/or non-profit making purposes.
- iii. to provide your Personal Data described in paragraph 12(i) above to any members of the PIVOT and/or Our Partners for their use in direct marketing the classes of services and products described in paragraph 12(ii) above.
- If you do NOT wish PIVOT to use your Personal Data in direct marketing or provide your Personal Data to other persons or companies for their use in direct marketing, you may write to PIVOT at the email address below to opt out from direct marketing at any time.
- 14. Access and/or Correction to your Personal Data:
- i. you have the right to request access to your Personal Data held by PIVOT and request correction of any of your Personal Data which is incorrect; and
- ii. PIVOT may charge you a reasonable fee for processing and complying with your data access request.
Accuracy of Personal Data
- PIVOT will ensure the accuracy of all Personal Data collected and processed. Appropriate procedures are implemented so that all Personal Data is regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used.
- PIVOT will endeavour to ensure the accuracy of Personal Data held by PIVOT, and if such Personal Data is transferred to third parties, it will notify that third party of any correction to be made.
Storing & Retention 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. Where we no longer require any Personal Data that we hold, that Personal Data would be destroyed or have particulars or information which may identify individuals removed. No Personal Data is kept for longer than is necessary and PIVOT will comply with all statutory and regulatory requirements in Singapore.
- PIVOT’s website may include hyperlinks to third party websites. PIVOT has no control over the content, accuracy, opinion expressed, and other links provided at these third-party websites or how these third-party websites deal with your personal data. You should visit these third-party websites for details of their privacy policies in relation to their handling of your personal data.
- PIVOT may use "cookies" to improve our internet service to you. Cookies are small data files that are automatically stored on your web browser in your computer that can be retrieved by PIVOT’s website. Cookies enable PIVOT’s website to remember you and your preferences when you visit the website and enable us to tailor the website to your needs. The information collected by cookies is anonymous visitor’s personalised settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No customer personal data is stored in cookies. However, you can disable cookies by changing the settings of your web browser.
- Further enquiries regarding PIVOT's Personal Data Protection Policy and Practices may be directed to firstname.lastname@example.org