On 15 October 2012, The Personal Data Protection Act sets out the law on data protection in Singapore. This Personal Data Protection Policy (“the Policy”) helps you understand how we collect, use and disclose the personal data you have provided to us.

  1. PERSONAL DATA

1.1 “personal data” means data, whether true or not, about an individual who can be identified:

a. from that data; or

b. from that data and other information to which we have or are likely to have access.

1.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information and financial information.

  1. PURPOSE OF COLLECTION AND DISCLOSURE OF PERSONAL DATA

2.1 Such personal data will be collected, used, disclosed and/or processed for purpose(s) such as:

a. providing product advise specific to the content on our website;

b. providing information about services that our Organization believes to be of potential interest to you;

c. surveys and marketing, statistical and other research carried out;

d. informing of new products and services of Fortitude Funds and its authorised affiliates.

2.2 We may disclose your personal data:

a. to financial adviser representatives;

b. to insurers;

c. to third party service providers we may engage to provide services such as marketing and research, sms marketing, telemarketing and mail distribution.

d. regulators or law enforcement agencies to comply with applicable laws or regulation or upon their valid request.

  1. USE OF COOKIES

3.1 A “cookie” is a small piece of information that is placed on your computer when you visit certain websites.

3.2 Cookies are used by the computer to remember your browsing preference, keep track of your interaction with the website and collecting data for access analytics purposes.

  1. PROTECTION OF YOUR PERSONAL DATA

4.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

4.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

  1. RETENTION OF YOUR PERSONAL DATA

5.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

5.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

  1. WITHDRAWING OF YOUR CONSENT

6.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

6.2 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

  1. ACCESS TO AND CORRECTION OF YOUR PERSONAL DATA

7.1 If you wish to make:

a. an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or;

b. a correction request to correct or update any of your personal data which we hold about you,

you may submit your request via email to our Data Protection Officer at the contact details provided below.

  1. CONTACT INFORMATION

8.1 You may contact admin@fortitude-funds.com if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.

  1. CHANGE OF POLICY

9.1 We may revise the policy from time to time without any prior notice.