Updated 24 April 2015

Caritas Legacy & Estate Planning Pte Ltd (“Caritas”) is committed to maintaining a robust privacy policy for the protection of its users. The purpose of this privacy policy is to inform you of how we manage personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”). This policy is designed to help you understand how we may collect, use and safeguard the personal data you provide to us and to assist you in making informed decisions when using our services.

In this policy, “We,” “Us,” “Our,” refers to Caritas, its related corporations and affiliates, as well as our respective representatives. “You”, “your” or “yours” means the persons to whom this policy applies. By communicating with us, submitting information to us or engaging any services offered by us, you agree and consent to our collection, storage, use, disclosure and sharing amongst ourselves your personal data, and disclosure of such personal data to our authorized service providers and relevant third parties in the manner set forth in this privacy policy.

For avoidance of doubt, this privacy policy shall form an integral part of the Website Terms and Conditions (‘Website Conditions’). In the event of any conflict, inconsistency or ambiguity between this privacy policy and the Website Conditions, this privacy policy shall prevail. All defined terms contained in the Website Conditions shall apply to this privacy policy unless otherwise specifically stated.

WHAT PERSONAL DATA WE COLLECT

“Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such personal data include but are not limited to:

• Your personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, email address and/or education details);
• Your images (e.g. photographs, photocopy of passport and official identification);
• Your employment details (e.g. occupation, directorships, employment history and/or educational qualifications);
• Your financial details (e.g. financial statements, investment accounts, bank accounts and/or bank transactions);
• Personal data of your family members, such as next of kin, spouses, and children;
• Personal data derived from legal documents (eg. Insurance Policies, Wills, Letters of Administration, Grants of Probate and/or Powers of Attorney);
• Personal opinions made known to us (e.g. feedback or responses to surveys); and/or
• Information about your usage of and interaction with our website and/ or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website.

HOW YOUR PERSONAL DATA IS COLLECTED

Generally, your personal data is collected in the following ways:

• When you register for or use any of our services on websites owned or operated by us;
• When you purchase and use some of our products or services;
• When you submit forms relating to any of our products or services;
• When you perform any transaction or communication with any of our employees, staffs or representatives;
• When you request that we contact you;
• When you respond to our promotions and other initiatives;
• When you ask to be included in an email or other mailing list;
• When you are contacted by, and respond to, our marketing representatives and agents;
• When you attend our public talks and seminars;
• When you respond to our request for additional personal data;
• From third party sources such as referrers, government agencies and publicly available sources of information; and/or
• When you submit your personal data to us for any other reason.

If you provide us with any personal data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorized representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes.

You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you need as well as any relevant updates and information.

PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

We may collect, use, disclose and/or retain your personal data for the following purposes:

• Facilitating will-writing, trust, lasting power of attorney and other estate planning instruments as instructed by you;
• The incorporation of companies;
• The provision of training and workshops;
• Billing and financial purposes, including payments for our services (and all transactions related thereto), accounting and tax;
• Administrative purposes;
• Monitoring products and services provided by or made available through us;
• Compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
• Communicating with you, including providing you with updates on changes to our products or services;
• Responding to your queries or feedback;
• Addressing or investigating any complaints, claims or disputes;
• Conducting analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
• Verifying your identity for the purposes of providing our products or services;
• Preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
• Protecting and enforcing our contractual and legal rights and obligations;
• Seeking professional advice, including legal advice;
• Managing our infrastructure and business operations and complying with internal policies and procedures;
• Preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances); and/or
• Any other purpose reasonably related to any of the above.

When using your personal data to contact you for the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone or any other means. We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customer.

USE OF PERSONAL DATA FOR MARKETING PURPOSES

We may use your personal data to provide information and updates on new products or services, including our latest activities that may be of interest to you and special offers or promotions which we feel you may benefit from. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.

If you have provided your Singapore telephone number(s) and have given us your consent to receive marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, short message service, fax or other means) with information about our products and services (including discounts and special offers). If we have an on going relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your Singapore telephone number, we may send you telemarketing messages to that number related to the subject of our on going relationship via facsimile, short message service and other mobile messaging services (other than a voice or video call).

You may at any time request that we stop contacting you for marketing purposes via selected or all modes. To learn more on how you can change the way we use your personal data for marketing purposes, please contact us (please see the “How to contact us” section below).

Nothing in this section shall vary or supercede the terms and conditions that govern our relationship with you.

DISCLOSURE AND SHARING OF PERSONAL DATA

Subject to the provisions of all applicable laws on data privacy, we my disclose your personal data to the following third parties, whether they are located in Singapore or elsewhere, for the purposes listed above (where applicable):

• Affiliates, service providers, agents or such other third party service providers who provide services relating to the purposes for which the personal data is collected;
• Our service providers and professional advisors on a need to know basis such as consultants, auditors, lawyers and advisors;
• External business and non-profit organizations in relation to corporate promotional events;
• The Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
• Any depository, agents, clearing system, issuer, registrar, fund manager or Manager, data management company, associated companies of Caritas, or our assignee, purchasers or transferees;
• Any person in relation to any merger or proposed merger of Caritas or any acquisition or issue or proposed acquisition or issue, of any part of the share capital of Caritas whether or not the merger or acquisition is subsequently entered into or completed;
• Any relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority or competent court in Singapore;
• Any other party to whom you authorise us to disclose your personal data; and/or
• Any person or organisation who is under a duty of confidentiality to Caritas and has undertaken to keep such information confidential, provided such person or organisation has a legitimate right to access such information.

Except as set out in this privacy policy, we do not sell your personal data to any third parties. We shall remain compliant of any duty or confidentiality obligations under the applicable agreement(s) and/or terms and conditions governing your relationship with us or any applicable law.

We may transfer, process, store and/or deal with your personal data at any location outside of Singapore for the purposes set out above. In doing so, we will comply with the PDPA and ensure that the recipient of your personal data is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data.

COOKIES AND RELATED TECHNOLOGIES

Caritas uses “cookies”, where a small text file is placed on your computer or device to track Information about you when you visit our websites. The cookie is used to collect information such as date and time of your visit, your frequency of use, profiles, navigational history and preferred sites.

You may set up your web browser to block cookies from monitoring your web site visit. You may also remove cookies stored from your computer or device. However, if you do block cookies, you may not be able to use certain features and functions of our web sites. This privacy policy covers the collection of information and use of cookies by Caritas only, and does not cover the use of cookies or other technologies by third parties to collect information.

THIRD-PARTY WEBSITES

Our web sites may contain links to third-party websites which may have different privacy policies or practices. We assume no responsibility for the privacy practices of such linked sites and encourage you to become acquainted with them prior to use. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

CHILDREN

We do not solicit or collect personal data from anyone under the age of 21 without parental consent. If you are under 21, you shall not use or enter information on this site without parental consent.

RETENTION OF PERSONAL DATA

Your personal data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.

WITHDRAWAL, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

You may make any enquiries or request access or corrections to your personal data held by us. We may charge a fee depending on the nature and complexity of your request.

Please contact us (please see the “How to contact us” section below) for details on how you may request such access or corrections.

AMENDMENTS AND UPDATES OF CARITAS LEGACY PRIVACY POLICY

We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way Caritas uses your personal data or any changes to the laws and regulations applicable to Caritas. We will make available the updated policy on our web site www.caritaslegacy.com/privacy. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.

GOVERNING LAW

This privacy policy is governed by the laws of Singapore. You consent to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this privacy policy.

HOW TO CONTACT US

Please use the contact form for any feedback, comments, requests in relation to this policy or your personal data or other communications with Caritas.