Data Protection Policy
Azzarion Advisory Pte Ltd (AA) is a consultancy firm providing advisory services in family governance and family business succession planning.
We value your right to control your personal data and privacy. Your trust in how we handle your personal data is important to us. For that reason, we have implemented the Data Protection Policy laid down in this statement.
The purpose of this Data Protection Policy is to let you know how we collect, use, disclose and protect your personal data. Our Policy meets the standards of the Personal Data Protection Act 2012 and will be reviewed regularly, along with our practices and procedures to take into account any change in the law or best practices. You can find our latest policy on our webpage www.azzarion.com
Under the PDPA, personal data, which is data that can be specifically linked to you as an individual (by itself or in conjunction with other databases – both internal and public) must be handled so as to meet certain standards in nine areas. These nine areas and our promises about them are set out below.
Consent
For the most part, your consent will be sought to collect, use and disclose personal data, subject to certain exceptions. Your consent may be expressed in writing (including electronic writing), orally, or through your authorised representatives. In certain circumstances, it may also be deemed or implied. We will not ask you to provide personal data as a pre-condition for providing a product or service if the purpose is beyond what is reasonable to provide that product or service.
The Personal Data Protection Act allows us to collect, use, disclose and transfer your personal data without your consent in the following situations:
Where collection is in your interest, consent cannot be obtained in a timely manner, and you would not be reasonably expected to withhold consent;
Collection is necessary in an emergency that threatens your life, health or safety, or that of another person; or
The personal data is publicly available.
A fuller list of such situations may be found in the Second, Third and Fourth schedules of the PDPA.
You may withdraw your consent by giving us written notice and allowing us a reasonable period of time. But do note that withdrawing consent may mean that we may not be able to provide those services that require the use of the personal data withdrawn.
What personal data do we collect?
Offline
The personal data we collect vary according to the service we provide you. In all cases, we collect personal data from you only with your consent or as required or permitted by law. In general, we will collect personal data such as your name, gender, address, date of birth, telephone number(s), NRIC/ FIN/ passport number for identification and authentication purposes. When needed we may collect personal data such as your credit card numbers and expiry dates to facilitate payments.
Online
The terms and conditions for the use of our website are available at www.azzarion.com
If you send us email, we may retain such personal data so as to contact you and to send you more information.
AA will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the law or comply with legal process served on AA or the site; (b) protect and defend the rights or property of AA; or (c) act under exigent circumstances to protect the personal safety of users of AA, or the public.
Purpose
Whenever we collect, use or disclose your personal data, we will tell you why we are doing so. Your personal data will be collected, used and disclosed for the purposes you consented to, or as permitted or required by law.
We collect, use and disclose personal data for these reasons:
Claims & disbursements
Comply with legal obligations and regulatory requirements
Conduct credit checks, screenings or due diligence checks as may be required under applicable laws/regulation
Conduct risk assessment
Income tax returns
Process and administer financial records
Provide customer service and support
Provide family business advisory services
Provide information to partners or third party providers that perform services for us
Provide updates on changes / notifications
Respond to inquiries and provide customer services
Update records in our database
Notification
We will inform you of the purposes for which we collect your personal data before or at the time that we collect the personal data from you. For personal data that we intend to use or disclose, we will inform you of the purposes before using or disclosing them.
Should you need clarification, do contact your consultant who, if he or she is not able to answer your question immediately, will be able to find the person in the company who will be able to do so.
Access and Correction
You can ask us about the personal data we have about you or that is in our control. You may also ask us about personal data we have used or disclosed to others up to a year earlier. Your request should be written and you should give us a reasonable period to respond to you. Because responding to your request requires additional time and effort on our part, we will charge a reasonable fee. We will inform you of the fee before responding your request.
Subject to certain exceptions under the PDPA, you will be given access to your personal data. Such access is usually to verify the accuracy and completeness of information. You may request that your personal data be corrected, amended, or withdrawn as appropriate.
Accuracy
We will make all reasonable effort to ensure that your personal data will be as accurate, complete and as up-to-date as is practicable. To this end, we encourage you to access, review and correct regularly the personal data that you have given to us and to update these as promptly as you can so that we will always possess complete and accurate data on you.
We will correct and update the personal data you supply as soon as is practicable..
Retention
We will keep your personal data only for as long as is necessary to serve the purposes for which they were collected, or for as long as they are needed for our business and operational reasons.
Transfer
We may store or process your personal data with trusted organisations outside Singapore. Unless otherwise permitted by the Personal Data Protection Commission, when we do so, we will ensure that the organisation will be able to protect our personal data to a standard comparable to that under Singapore law. All such organisations will be prohibited from using your personal data except as instructed by us and they are required to maintain the confidentiality of your personal data.
Openness
Information about our data protection policies and practices will be made available to you upon request. This request is to be directed to our Data Protection Officer whose contact information is at the end of this Policy.
To give feedback about our data protection policies or practices, please contact our Data Protection Officer at:
Data Protection Officer
Azzarion Advisory Pte Ltd
#14-02 Clifford Centre
24 Raffles Place
Singapore 048621
Tel: 6532-3233
Fax: 6220-5377
Email: dpo@azzarion.com