This Policy applies to ECG Pte Ltd (201622990Z ) and any holding companies, other subsidiaries or related entities of Asiaforexmentor.com, all of which are referred to as “Asiaforexmentor”, “we”, “our”, or “us”. The Policy extends to and covers all operations and functions of LTTTM.
“Personal information” is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information, which we collect, is “sensitive information”. “Sensitive information” includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, which is also personal information, and also includes health information about an individual.
- How we collect personal information
As the provider of financial services, including trading education, we may collect sensitive information about an individual’s personal circumstances and financial details, which may potentially identify the individual and/or contains an opinion about the individual.
Our ability to provide individuals with our products and services is sometimes dependent on us obtaining certain personal information about the individual. Typically, the type of personal information we collect about the individual includes his or her name, age, date of birth, occupation, mailing address, phone numbers, email address and other information that is relevant to the products and services we provide.
The personal information may also include information about the form of identification used in relation to an individual to send or receive a transaction (required by law in some instances), and information about a transaction in relation to an individual, including details of the amounts paid in or out of an individual’s account as well as delivery instructions.
We generally collect personal and/or sensitive information from individuals by the following methods:
1.1 directly from applications, questionnaires and/or forms completed by individuals (via our websites), which include surveys or special offers, when individuals wish to use our services, purchase our products or apply for a position in our organisation;
1.2 from information disclosed to us by an individual on the phone, or by sending us correspondence (by letter, fax or email) or contact us in person; and
1.3 from a variety of third party sources, including our business contacts credit reference and credit checking agencies, and financial institutions.
The above list is not exhaustive.
In some circumstances we may be provided with personal information about an individual from somebody else, for example a referral from another person. We will take reasonable steps to inform the individual that it holds the personal information and the purpose for which it holds the personal information.
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) require us to collect certain identification information about you. We will collect personal information from third parties in respect of AML/CTF checks which are required to be carried out, under AML/CTF Legislation.
We must not collect sensitive information unless the individual has consented, or it is required by law, or in other special specified circumstances.
Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact our office. Please note that withdrawing your consent may lead to us no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.
If the personal information we request is not provided, we may not be able to provide individuals with the benefit of our services, or meet an individual’s needs appropriately.
- Incomplete or Inaccurate Information
We may not be able to provide you with the products or services you are seeking if you provide incomplete or inaccurate information.
- Why do we collect personal information?
We collect personal information for the following purposes:
* to conduct our business of providing our products and services to our clients;
* to enter into contracts with sub-contractors to conduct our business;
* to assess applications by individuals to provide them with our products and services;
* complying with our legal obligations
* to comply with our legal obligations; and
* to help us manage and enhance our services.
We may also obtain information from time to time through market research, to enable us to improve our services or to consider the wider needs of our customers or potential customers.
- Information we may collect
The personal and sensitive information we collect generally consists of name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and e-mail) and financial information.
We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non photographic documents) in order to meet the standards set under those laws.
We may take steps to verify the information we collect; for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation.
- About whom do we collect personal information?
The type of information we may collect and hold includes (but is not limited to) personal information about:
* third parties;
* prospective employees; and
* other people with whom we come into contact.
- Dealing with unsolicited personal information
If we receive personal information that is not solicited by us, we will only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.
If these conditions are not met, we will destroy or de-identify the information.
If such unsolicited information is sensitive information we will obtain your consent to retain it regardless of what the circumstances are.
- How might we use and disclose personal information?
When we refer to “use “of personal information, we mean use within our organisation for the purposes outlined above. When we use the word “disclose” we mean providing the information to persons outside of our organisation.
We may use and disclose personal information for the primary purposes for which it is collected, and also for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g., where required by law).
We may use and disclose personal information for the following purposes:
* to conduct our business of providing our products and services to clients;
* to register and handle product warranties, and product warranty claims;
* to enter into contracts with sub-contractors to conduct our business;
* to assess applications by individuals to provide them with our services;
* to communicate with individuals, by providing them from time to time with information contained in newsletters, emails or brochures;
* to comply with our legal obligations; and
* to help us manage and enhance our services.
When you enter provide your contact details as part of a survey or market research questionnaire, we may ask for your name, address, and e-mail address so we can conduct the survey and thereby enhance our services. We may ask for other information to enable us to improve our websites or to send you special offers. In these instances we will usually provide you with an opportunity to opt out from receiving any information after providing your details.
Unless a client agrees and consents, we do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive personal or contact information for direct marketing purposes without the consent of clients or users.
We may engage other people to perform services for us, this may involve those people handling personal information that we possess. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it.
We may disclose personal and/or sensitive information to:
* third parties, including (but not limited to) any entities or organisations handling any claims;
* consultants we engage to assist individuals;
* consultants we engage to manage our business;
* third party service providers;
* organisations involved in a transfer or sale of all or part of our assets or business (including accounts and trade receivables);
* our lawyers;
* our accountants;
* our compliance consultants;
* regulatory authorities, including the Singapore Securities and Investment Commission; and
* anyone else to whom the individual authorises us to disclose it.
We may also collect personal and/or sensitive information from these organisations and individuals, and deal with that information in accordance with this Policy.
Asiaforexmentor trains its employees and advisers who handle personal information to respect the confidentiality of customer information and the privacy of individuals. Asiaforexmentor regards breaches of your privacy very seriously and will impose appropriate penalties for breach of this Policy, which may, in certain circumstances, include dismissal.
Disclosure required by law
We may be required to disclose customer information by law e.g. under Court Orders or Statutory Notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter terrorism financing.
We will only use or disclose the personal information we hold about you for the purpose of direct marketing if we have received the information from you and you have not requested not to receive such information.
Direct marketing means that we should use your personal information to provide you with information on our products and services that may interest you.
If you wish to opt-out of receiving marketing information altogether, you can:
* write to us at admin (@) asiaforexmentor.com
- Sending information overseas?
We will only disclose your personal information to a recipient who is not in Singapore and who is not our entity after we ensure that:
* the overseas recipient does not breach the Singapore Privacy Principles; or
* you will be able to access to take action to enforce the protection of a law or binding scheme that has the effect of protecting the information in a way that is at least substantially similar to the way in which the Singapore Privacy Principles protect the information; or
* you have consented to the disclosure after we expressly you that there is no guarantee that the overseas recipient will not breach the Singapore Privacy Principles; or
* the disclosure of the information is required or authorised by or under a Singapore law or a court/tribunal order; or
* a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) Privacy Act) exists in relation to the disclosure of the information.
- Management of personal information
The Privacy Act requires us to take all reasonable steps to protect the security of personal information. Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium.
We hold personal information in a combination of secure computer storage facilities and paper based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.
We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes unless required or authorized to do so by or under Singapore law, regulation or court/tribunal order.
Before using or disclosing a government related identifier of an individual, we will ensure that such use or disclosure is:
* reasonably necessary for us to verify your identity for the purposes of the our activities or functions; or
* reasonably necessary for us to fulfil its obligations to a government agency or a State or Territory authority; or
* required or authorised by or under an Singapore law, regulation or a court/tribunal order; or
* within a permitted general situation (other than the situation referred to in item 4 or 5 of the table in subsection 16A(1) Privacy Act); or
* reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
- How do we keep personal information accurate and up-to-date?
We take reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out at the end of this document.
- Access to personal information
Under the Privacy Act, you have the right to obtain a copy of any personal information which Asiaforexmentor holds about you and to advise Asiaforexmentor of any perceived inaccuracy.
To make a request, you will need to complete an application form verifying your identity and specifying what information you require. We will acknowledge your request within 14 days and respond promptly to it or if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within 30 days.
If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act.
We will require identity verification and to specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise of the likely cost in advance.
If we refuse to give access to the personal information or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.
Additionally, we will endeavour to give access in a way that meets both yours and our needs.
- Correction of personal information
We will correct all personal information that we believe to be inaccurate, out of date, incomplete, irrelevant or misleading given the purpose for which that information is held or if you request us to correct the information.
If we correct your personal information that we previously disclosed to another SPP entity you can request us to notify the other SPP entity of the correction. Following such a request, we will give that notification unless it is impracticable or unlawful to do so.
If we refuse to correct the personal information as requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.
If we refuse to correct the personal information as requested by you, you can request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then associate the statement in such a way that will make the statement apparent to users of the information.
- Updates to this Policy
- Privacy Training
- Non-compliance and disciplinary actions
- Incidents/Complaints Handling
If an individual has a privacy complaint, he or she is required to send it in writing to the Privacy Officer.
Asiaforexmentor has an effective incidents/complaints handling process in place to manage privacy risks and issues. The incidents/complaints handling process involves:
* identifying (and addressing) any systemic/ongoing compliance problems;
* increasing consumer confidence in Asiaforexmentor’s privacy procedures; and
* helping to build and preserve Asiaforexmentor’s reputation and business.
- Contractual arrangements with third parties
We must ensure that all contractual arrangements with third parties adequately address privacy issues.
* regulating the collection, use and disclosure of personal information;
* de-identifying personal information wherever possible;
* ensuring that personal information is kept securely, protected from loss or misuse, with access to it only by authorised employees or agents of the related organisations; and
* ensuring that personal information is only disclosed to organisations which are approved by Asiaforexmentor.
The third parties specifically agree only to use personal information for the purposes consented to by Asiaforexmentor or by the individual concerned.