Privacy Policy

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal data when you use our site or engage our financial planning services, including annual financial planning, investment strategies, wealth management, retirement planning, estate planning, and risk assessment.

We aim to handle personal data lawfully, fairly, and transparently. Depending on your location and the circumstances of our relationship, applicable requirements may include Singapore’s Personal Data Protection Act 2012 and, where applicable, the European Union General Data Protection Regulation.

Personal Data We Collect

We may collect information that you provide or that is generated through your use of our online platform, including:

• Your name, residential or mailing address, date of birth, nationality, identification details, and other information needed to establish or manage a client relationship.
• Financial information, such as income, assets, liabilities, investments, insurance arrangements, pension information, tax-related details, financial objectives, and risk tolerance.
• Information about your family, beneficiaries, dependants, business interests, or estate where relevant to planning or wealth management.
• Information submitted through forms, enquiries, consultations, appointments, surveys, or other interactions with our service.
• Technical information, such as device identifiers, browser type, approximate location, access times, pages viewed, and security or usage logs.

How We Use Personal Data

We may use personal data to:

• Understand your financial circumstances and prepare annual financial plans, recommendations, projections, and reviews.
• Provide investment strategy, wealth management, retirement, estate planning, and risk assessment services.
• Verify identity, assess suitability and risk, prevent fraud, and comply with applicable anti-money-laundering, counter-terrorism financing, tax, regulatory, and legal obligations.
• Manage appointments, client records, service administration, billing, complaints, and dispute resolution.
• Maintain, secure, troubleshoot, and improve our site, systems, and services.
• Send service-related information and, where permitted and with any required consent, information about relevant services or educational content.

Legal Bases for Processing

Where the GDPR applies, we process personal data when necessary to perform a contract, take steps at your request before entering into a contract, comply with a legal obligation, pursue legitimate interests that do not override your rights, or obtain your consent. Where we rely on consent, you may withdraw it at any time; withdrawal does not affect processing carried out before withdrawal.

Disclosure of Personal Data

We may disclose personal data only when reasonably necessary and subject to appropriate safeguards, including to:

• Service providers that support technology, hosting, document management, identity verification, compliance, accounting, or secure administration.
• Financial institutions, insurers, investment providers, professional advisers, executors, trustees, or other parties involved in delivering requested planning services.
• Government authorities, regulators, courts, law-enforcement bodies, or other parties where disclosure is required or permitted by law.
• A purchaser, successor, or professional adviser in connection with a merger, restructuring, financing, or transfer of all or part of our business, subject to applicable confidentiality requirements.

International Transfers

Some service providers or recipients may process personal data outside Singapore or the country where you live. Where required, we use legally recognised safeguards, such as adequacy decisions, contractual protections, consent, or another permitted transfer mechanism, and take reasonable steps to protect transferred data.

Cookies and Similar Technologies

Our site may use essential cookies and similar technologies to operate securely, remember preferences, understand usage, and improve performance. Where required, non-essential technologies will be used only with your consent. You can manage cookie settings through your browser or any controls provided on our site, although disabling certain technologies may affect functionality.

Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this policy, to provide services, maintain accurate records, resolve disputes, enforce agreements, meet regulatory and legal obligations, and protect our legitimate interests. Retention periods depend on the type of data and the nature of the relationship.

Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal data against unauthorised access, alteration, disclosure, loss, misuse, or destruction. No online transmission or storage system can be guaranteed to be completely secure.

Your Rights

Subject to applicable law, you may have the right to:

• Request access to personal data we hold about you and information about how it is used.
• Request correction of inaccurate or incomplete personal data.
• Request deletion, restriction, or limitation of processing in appropriate circumstances.
• Object to processing based on legitimate interests or object to direct marketing.
• Request portability of certain personal data where applicable.
• Withdraw consent where processing is based on consent.

To protect personal data, we may need to verify your identity before fulfilling a request. We may also decline or limit a request where permitted by law. You may lodge a complaint with the Personal Data Protection Commission in Singapore or, where the GDPR applies, with your relevant data protection supervisory authority.

Children’s Privacy

Our site and services are not directed to children who are unable to enter into a lawful relationship for the relevant service. We do not knowingly collect personal data from such children without appropriate parental or legal guardian involvement.

Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our services, technology, or legal obligations. The updated version will be published on our site and will apply from the date it is made available, unless a different date is stated.

Contact and Complaints

For privacy requests or complaints, please write to us at our physical address: Unnamed Road, Singapore 117606, Singapore. We will review requests and complaints in accordance with applicable privacy laws and respond within the period required by law.