Data Protection Policy

The purpose of this document ("Data Protection Policy") is to inform you of how Bank of Singapore Limited and Bank of Singapore Nominees Pte Ltd manage Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) ("the Act"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Bank of Singapore Limited and Bank of Singapore Nominees Pte Ltd (including their related corporations and overseas branches and offices) (collectively, the "Companies"), as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "BOS", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to BOS in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

BOS may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website http://www.bankofsingapore.com/Data-Protection-Policy.html. Please check back regularly for updated information on the handling of your Personal Data.

  1. Personal Data

    In this Data Protection Policy, "Personal Data" refers to any 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, including data in our records as may be updated from time to time.

    Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

  2. Collection of Personal Data

    1. Generally, we collect Personal Data in the following ways:

      1. when you submit any form, including but not limited to application forms or other forms relating to any of our products or services or any investments which you purchase through the Companies;
      2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
      3. when you interact with our staff, including relationship managers and their assistants, example via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
      4. when your images are captured by us via closed-circuit television cameras ("CCTVs") while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
      5. when you use some of our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;
      6. when you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
      7. when you are contacted by, and respond to, our marketing representatives, agents and other service providers;
      8. when we seek information about you and receive your Personal Data from third parties in connection with your relationship with us, for example, from referrers, business partners, external or independent asset managers, public agencies or the relevant authorities;
      9. through physical access, internet and information technology monitoring processes;
      10. in connection with any investigation, litigation, registration or professional disciplinary matter, criminal prosecution, inquest or inquiry which may relate to you or any Connected Person; and/or
      11. when you submit your Personal Data to us for any other reason.
    2. When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.

    3. If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes.
      "Connected Person" may include but is not limited to any beneficial owner, authorised signatory, director, shareholder, officer of a company, partner or member of a partnership, settlor, trustee, beneficial owner, protector or grantor of trust, mandate holder, power of attorney holder, surety, third party security provider, provider of funds, founder and/or employee, payee of designated payment, representatives, agents or nominees.

    4. 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 have requested. You agree to inform BOS immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as BOS may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

  3. Purposes for the Collection, Use and Disclosure of Your Personal Data

    1. Generally, BOS collects, uses and discloses your Personal Data for the following purposes:

        1. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
        2. verifying your identity and customer due diligence;
        3. managing the administrative and business operations of the Companies and complying with internal policies and procedures (including but not limited to facilitating business continuity planning);
        4. audit purposes;
        5. verifying or confirming trade orders or instructions from you or for your account (including but not limited to instructions on fund transfers or remittances);
        6. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
        7. matching any Personal Data held which relates to you for any of the purposes listed herein;
        8. resolving complaints and handling requests and enquiries;
        9. preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks (including but not limited to preventing and detecting loss of BOS’ proprietary and sensitive information);
        10. project management;
        11. providing media announcements and responses, for example in relation to complaints or law suits;
        12. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
        13. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
        14. managing and preparing reports on incidents and accidents;
        15. organising events, seminars or trainings;
        16. complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to BOS or that it is expected to comply, according to:
          1. any law binding or applying to it within or outside Singapore existing currently and in the future;
          2. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Singapore existing currently and in the future;
          3. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on BOS by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
        17. to assist in law enforcement and investigations by relevant authorities;
        18. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
        19. archival management (including but not limited to warehouse storage and retrievals); and/or
        20. any other purpose relating to any of the above.

      These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

    2. In addition, BOS collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

      1. If you are a prospective customer:
        1. evaluating your eligibility to open an account with us and your financial and banking needs and providing recommendations to you as to the type of products and services suited to your needs;
        2. assessing and processing any applications or requests made by you for products and services offered by BOS; and/or
        3. any other purpose relating to any of the above.
      2. If you are a customer holding an account with BOS or a Connected Person or an administrator, executor, liquidator, official assignee, receiver, judicial manager or other similar official who has been so appointed pursuant to bankruptcy or insolvency proceedings instituted in Singapore or elsewhere in respect of a BOS customer or any security provider:
        1. opening, maintaining or closing of accounts and our establishing or providing banking and trust services to you;
        2. processing fund transfers or any other instructions provided in relation to the account of a BOS customer;
        3. where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and / or in accordance with the terms and conditions of our agreement with you;
        4. processing applications for and facilitating the daily operation of services and credit facilities provided to you or other persons or corporations for whom you act as surety or third party service provider;
        5. conducting credit checks at the time of application for credit and at the time of regular or special credit reviews;
        6. facilitating or processing your application for insurance products and/or trust services offered by BOS and its business partners;
        7. carrying out client reviews, for example, annual reviews of your portfolio;
        8. to establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;
        9. providing web banker services or internet banking services (including but not limited to carrying out special handling requests for PIN mailers and tokens);
        10. networking to maintain customer relationship;
        11. providing client servicing (including but not limited to responding to individual requests by customers, mailing services, reconciliation services and providing customer satisfaction);
        12. facilitating the transfer of funds within BOS banking accounts or from BOS accounts to external banking accounts and vice versa;
        13. administering exceptional approvals, fee adjustments or waivers;
        14. dealing with and designing investment products (for example, bonds, derivatives, equities, funds);
        15. registering the pledge or charge that you or the surety or the third party security provider has granted in favour of BOS as security for the credit facilities granted by BOS to you; 
        16. administering credit and debit cards (including but not limited to processing card applications, transactions and credit limit approvals); 
        17. providing cheque deposits and issuance services;
        18. determining and collecting amounts owed by you or the borrower for whom you act as surety or third party security provider or those providing security or acting as surety for your liabilities and obligations;
        19. enabling any Company or third party to perform the functions that BOS may have outsourced to it in relation to the management of your account or transactions;
        20. enabling an actual or proposed assignee of BOS, or participant or sub-participant or transferee of BOS’ rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer; and/or
        21. any other purpose relating to any of the above.
      3. If you are an employee or agent of a referrer or other intermediary:
        1. marketing services and products;
        2. processing commission remuneration;
        3. performing due diligence and reference checks; and/or
        4. any other purpose relating to any of the above.
      4. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by BOS;
        1. managing project tenders or the supply of goods and services;
        2. processing and payment of vendor invoices;
        3. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or
        4. any other purpose relating to any of the above.
      5. If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):
        1. providing cash, payment and transactional services (including but not limited to the execution, settlement, reporting and/or clearing of the relevant transaction); and/or
        2. any other purpose relating to any of the above.
      6. If you sit on the BOS Board of Directors:
        1. facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);
        2. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);
        3. administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee);
        4. managing insurance programmes; and/or
        5. any other purpose relating to any of the above.
    3. In addition, where permitted under the Act, BOS may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):

      1. providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
      2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by BOS or other third parties;
      3. sending you details of products, services, special offers and rewards, investment or research reports or guides, either to our customers generally, or which we have identified may be of interest to you; and/or
      4. conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
    4. If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, BOS may contact you using such Singapore telephone number(s) (including via voice calls, text , fax or other means) with information about our products and services (including discounts and special offers).

    5. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

  4. Disclosure of Personal Data

    1. BOS will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

      1. BOS’s related corporations and overseas branches and offices;
      2. counterparties and their respective banks in relation to transactions for your account including purchasing and selling of securities and investment products, fund transfers, payments, issuance of standby letters of credit, banker’s guarantees or letters of undertaking and drawing of cheques;
      3. third party recipients of reference letters;
      4. companies providing services relating to insurance and/or reinsurance to BOS;
      5. insurers or brokers in relation to the insurance products or services that you have applied for or purchased;
      6. trustees, attorneys and asset managers appointed by you to manage your account held with BOS;
      7. referrers who have referred you to BOS;
      8. any person (1) who provides security or acts as surety for your liabilities and obligations to BOS or (2) for whom you act as surety or third party security provider;
      9. agents, contractors, vendors, installers, or third party service providers who provide administrative or operational services to BOS, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to BOS;
      10. agents, contractors, vendors or other third party service providers in connection with products and services offered by BOS;
      11. credit reporting agencies;
      12. debt collection agencies;
      13. your employers which are financial institution, for their internal surveillance or monitoring purposes;
      14. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
      15. credit card companies and their respective service providers in respect of credit cards held by you;
      16. translators;
      17. our professional advisers such as our auditors and lawyers;
      18. third parties who provide corporate advisory services or due diligence services in connection with you, any Connected Person or your account held with BOS;
      19. relevant government regulators, government ministries, exchange, statutory boards or authorities or law enforcement agencies who have jurisdiction over BOS or any Company or over any transaction entered into by you, such as the Monetary Authority of Singapore, Singapore Exchange Limited, the Accounting and Corporate Regulatory Authority, the Insolvency and Public Trustee Office, the Inland Revenue Authority of Singapore and the Commissioner of Charities, as well as to comply with listing and other requirements or directions of Singapore Exchange Limited and/or any other relevant securities exchange;
      20. any liquidator, receiver, administrator, judicial manager, trustees-in-bankruptcy, custodian or other similar official who has been so appointed, pursuant to bankruptcy, winding-up or insolvency proceedings instituted in Singapore or elsewhere, in respect of you or your assets;
      21. third parties who carry out registration of charge or pledge over the assets that you have pledged or charged to BOS;
      22. corporate service providers or lawyers, who are appointed by you;
      23. surveyors or valuers or other third parties in relation to assets which you will be charging or mortgaging to BOS;
      24. the Central Provident Fund (“CPF”) Board in relation to CPF investment products;
      25. financial institutions, brokerage houses, clearing houses, depository, depository agents, managers, administrators, fund houses, registrars, custodians, external banks, the Central Depository, nominee banks and investment vehicles in relation to asset management and investment product settlement processing;
      26. collection and repossession agencies in relation to the enforcement of repayment obligations for loans;
      27. third parties who organise promotional or marketing events, seminars or trainings;
      28. any actual or proposed assignee of BOS or participant or sub-participant or transferee of BOS’ rights, liabilities or obligations in respect of (1) you or (2) a security provider who provides security or acts as surety for your liabilities and obligations to evaluate the transaction intended to be the subject of the assignment, participation, sub-participation or transfer;
      29. any person to whom BOS or any of the Companies is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to BOS or any of the Companies, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which BOS or any of the Companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of BOS or any of the Companies with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside Singapore and may be existing currently and in the future; and/or
      30. any other party to whom you authorise us to disclose your Personal Data to.
  5. Use of Cookies

    1. When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

    2. Cookies are small text files placed stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

    3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

  6. Data Security

    1. BOS will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and take any necessary precautions.

    2. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

    3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

  7. Third-Party Sites

    1. Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

  8. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

    1. If you:

      1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
      2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
      3. would like to obtain access and make corrections to your Personal Data records, please contact us as follows:
        Email: dpo@bankofsingapore.com
        Call: +65 6559 8000
        Write in: Data Protection Officer
        Bank of Singapore Limited
        63 Market Street
        #22-00 Bank of Singapore Centre
        Singapore 048942
    2. Please note that if your Personal Data has been provided to us by a third party (for example, The Central Depository Pte Ltd), you should contact that such party directly to make any queries, feedback and access and correction requests to BOS on your behalf.

    3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, BOS or any of the Companies may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements you have entered into with BOS or any of the Companies, and your being in breach of your contractual obligations or undertakings, and BOS’s or the Company’s legal rights and remedies in such event are expressly reserved.

  9. Governing Law

    1. This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

The purpose of this document ("Data Protection Policy") is to inform you of how BOS Trustee Limited manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) ("the Act"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any Services (as defined in paragraph 2.1(a) below) offered by us, you agree and consent to BOS Trustee Limited (including its related corporations and business units) (collectively, the "Companies"), as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "BOSTL", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to BOSTL in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.

BOSTL may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website http://www.bankofsingapore.com/Data-Protection-Policy.html. Please check back regularly for updated information on the handling of your Personal Data.

  1. Personal Data

    In this Data Protection Policy, "Personal Data" refers to any 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, including data in our records as may be updated from time to time.

    Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

  2. Collection of Personal Data

    1. Generally, we collect Personal Data in the following ways:

      1. when you submit any forms, for example, application forms or other forms or documents relating to any of our services, including but not limited to trust services or company management / administration services (the "Services");
      2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Services;
      3. when you interact with our BOSTL staff, whether directly or through the relationship managers, marketing associates and wealth planners of the Companies, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and emails;
      4. when your images are captured by us via closed-circuit television cameras ("CCTV") while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;
      5. you request that we contact you, or include you in an email or other mailing list; or when you respond to our request for additional Personal Data;
      6. when we seek information about you and receive your Personal Data from third parties in connection with the Services, for example, from referrers, insurance brokers, any of the Companies, business partners, public agencies or the relevant authorities; and/or
      7. when you submit your Personal Data to us for any other reason.
    2. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, beneficial owners, authorised signatories, directors, shareholders, officers of a company, partners or members of a partnership, settlor, trustees, beneficiaries, protectors or grantors of trust, power of attorney holders, surety, third party security providers, provider of funds, founders, employers, business partners and/or employees, payees of designated payments, representatives, agents or nominees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

    3. 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 the Services you have requested. You agree to inform BOSTL immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue or incorrect and provide any information or documentation as BOSTL may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data.

  3. Purposes for the Collection, Use and Disclosure of Your Personal Data

    1. Generally, BOSTL collects, uses and discloses your Personal Data for the following purposes:

        1. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
        2. verifying your identity and customer due diligence;
        3. managing the administrative and business operations of the Companies and complying with internal policies and procedures;
        4. verifying or confirming trade orders or instructions from you or for your account, including but not limited to instructions on fund transfers or remittances;
        5. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
        6. matching any Personal Data held which relates to you for any of the purposes listed herein;
        7. preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks;
        8. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
        9. managing and preparing reports on incidents and accidents;
        10. providing media announcements and responses, for example, in relation to complaints or law suits;
        11. complying with any applicable rules, laws and regulations, codes of practice or guidelines, obligations, requirements or arrangements for collecting, using and disclosing Personal Data that apply to BOSTL or that it is expected to comply, according to:
          1. any law binding or applying to it within or outside Singapore existing currently and in the future;
          2. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Singapore existing currently and in the future;
          3. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on BOSTL by reason of its financial, commercial, business, or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
        12. to assist in law enforcement and investigations by relevant authorities;
        13. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
        14. archival management (including but not limited to warehouse storage and retrievals); and/or
        15. any other purpose relating to any of the above.

      These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

    2. In addition, BOSTL collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

      1. If you are a prospective customer:
        1. evaluating your needs and objectives and providing recommendations to you as to the type of Services suited to your needs;
        2. assessing and processing any applications or requests made by you for the Services offered by BOSTL; and/or
        3. any other purpose relating to any of the above.
      2. If you are a customer, settlor, beneficiary or a "Trust Relevant Party" as defined under MAS Notice TCA-N03, ultimate beneficial owner, appointed representative (including but not limited an individual having a power of attorney), employee, director, shareholder, guarantor or such other individual related to a trust or company managed/administered by BOSTL:
        1. opening, maintaining or closing of accounts and our establishing or providing the Services;
        2. where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and / or in accordance with the terms and conditions of our agreement with you;
        3. facilitating the continuation or termination of the trust or company management/administration relationship or the daily operation of the Services and providing client servicing (including but not limited to responding to individual requests by customers, and providing customer satisfaction);
        4. facilitating the transfer of funds within banking accounts held with any of the Companies or from such accounts to external banking accounts and vice versa;
        5. administering exceptional approvals, fee adjustments or waivers;
        6. dealing with investment products (for example, bonds, derivatives, equities, funds);
        7. customer outreach and relationship management;
        8. designing services or related products for customers’ use; and/or
        9. any other purpose relating to any of the above.
      3. If you are an employee or agent of a referrer or other intermediary:
        1. marketing services and products;
        2. processing commission remuneration;
        3. performing due diligence and reference checks; and/or
        4. any other purpose relating to any of the above.
      4. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by BOSTL:
        1. managing project tenders or the supply of goods and services;
        2. processing and payment of vendor invoices; and/or
        3. any other purpose relating to any of the above.
      5. If you are a party or a counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):
        1. providing cash, payment and transactional services; and/or
        2. any other purpose relating to any of the above.
      6. If you sit on the BOSTL Board of Directors:
        1. facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);
        2. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);
        3. administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee);
        4. managing insurance programmes; and/or
        5. any other purpose relating to any of the above.
    3. In addition, where permitted under the Act, BOSTL may also collect, use and disclose your Personal Data to send you details of Services either to our customers generally, or which we have identified may be of interest to you (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data).

    4. If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, BOSTL may contact you using such Singapore telephone number(s) (including via voice calls, text , fax or other means) with information about our Services (including discounts and special offers).

    5. In relation to particular Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

  4. Disclosure of Personal Data

    1. BOSTL will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

      1. BOSTL’s related corporations;
      2. counterparties and their respective banks in relation to fund transfers for your account, including fund transfers, payments and drawing of cheques;
      3. third party recipients of BOSTL reference letters;
      4. companies providing services relating to insurance and/or reinsurance to BOSTL;
      5. agents, contractors, vendor, installer or third party service providers who provide operational services to BOSTL, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to BOSTL;
      6. vendors or other third party service providers in connection with the Services offered by BOSTL;
      7. credit reporting agencies;
      8. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
      9. credit card companies and their respective service providers in respect of credit cards held by you;
      10. our professional advisers such as our auditors and lawyers;
      11. lawyers who are appointed by you;
      12. third parties who provide due diligence services in connection with you or any individual in relation to your trust or company;
      13. relevant government regulators, government ministries, statutory boards or authorities or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, Inland Revenue Authority of Singapore, Commissioner of Charities, the Accounting and Corporate Regulatory Authority and the Insolvency and Public Trustee Office, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them, as well as to comply with listing and other requirements or directions of Singapore Exchange Limited and/or any other relevant securities exchange;
      14. surveyors, auctioneers, valuers or other third parties in relation to loans and other credit facilities such as mortgages;
      15. the Central Provident Fund Board ("CPF") and its agent banks in relation to CPF investment products, payment schemes and processing excess payment refunds;
      16. financial institutions, brokerage houses, clearing houses, depository, depository agents, managers, administrators, fund houses, registrars, custodians, external banks, the Central Depository, nominee banks, and investment vehicles in relation to asset management and investment product settlement processing;
      17. Credit Counselling Singapore, and collection and repossession agencies in relation to the enforcement of repayment obligations for loans and other credit facilities;
      18. external business and charity partners in relation to corporate promotional events;
      19. third parties who organise promotional or marketing events, seminars or trainings;
      20. telecommunications companies, the National Trades Union Congress, Singapore Press Holdings and local town councils and any other billing entities in relation to processing the payment of bills;
      21. any person to whom BOSTL or any of the Companies is under an obligation or otherwise required to make disclosure under the requirements of any law binding on or applying to BOSTL or any of the Companies, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which BOSTL or any of the Companies are expected to comply, or any disclosure pursuant to any contractual or other commitment of BOSTL or any of the Companies with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or industry bodies or associations of financial services providers, all of which may be within or outside Singapore and may be existing currently and in the future; and/or
      22. any other party to whom you authorise us to disclose your Personal Data to.
  5. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

    1. If you:

      1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
      2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
      3. would like to obtain access and make corrections to your Personal Data records, please contact BOSTL as follows:
        Email: dpo.sg@BOSTrustee.com
        Call: +65 6818 6478
        Write in: Data Protection Officer
        Data Protection & Governance Office
        BOS Trustee Limited
        63 Market Street
        #14-00
        Bank of Singapore Centre
        Singapore 048942
    2. Please note that if your Personal Data has been provided to us by a third party (e.g. The Central Depository Pte Ltd), you should contact such party directly to make any queries, feedback, and access and correction requests to BOSTL on your behalf.

    3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, BOSTL may not be in a position to continue to provide its Services to you, administer any contractual relationship in place, may also result in the termination of any agreements with BOSTL, and your being in breach of your contractual obligations or undertakings, and BOSTL’s legal rights and remedies in such event are expressly reserved.

  6. Governing Law

    1. This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

Bank of Singapore Limited, Bank of Singapore Limited, Hong Kong Branch (collectively, the “Bank”) and BOS Trustee Limited (the “Trustee”) are committed to protecting your privacy and ensuring the highest level of security for your personal information. This Privacy Notice explains the types of personal information we collect, how we use that information, who we share it with, and how we protect that information.

Please read the following carefully to understand our views and practices regarding your personal information.

  1. Who are we?

    For the purposes of applicable data protection laws, the data controller is Bank of Singapore Limited of 63 Market Street, #22-00 Bank of Singapore Centre, Singapore 048942, Bank of Singapore Limited, Hong Kong Branch of 34/F & 35F One International Finance Centre, 1 Harbour View Street, Central, Hong Kong, and BOS Trustee Limited of 63 Market Street #14-00 Bank of Singapore Centre Singapore 048942, as may be applicable.

  2. What information is covered by this Privacy Notice?

    This Privacy Notice covers all personal information processed by the Bank and the Trustee which means information that (either in isolation or in combination with other information) enables you to be identified directly or indirectly.

  3. What information do we collect from you?

    We may collect information about you from the following sources:

    1. Information we receive from you

      We may collect personal information (such as your name, contact details, financial details, employment and education details, nationality, date and place of birth, marital status, passport or other identification details and details of visits to our premises) that you provide to us when you:

      1. submit applications to open an account or to establish a trust or other entities forming part of the trust assets; and
      2. subsequently correspond with us.
    2. Information we collect about you

      When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

      Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

      Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain parts of our website.

      We may also collect personal data from you when you interact with our staff, including customer service officers, relationship managers, trust officers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email.

  4. How do we use your personal information?

    We process the following information:

    For the following purpose(s):

    Based on the following justification:

     

     

     

    Name, ID Number, Nationality, Passport Information, Tax Details, Date of Birth, Place of Birth, Residential Address, Business Address, Occupation, Signature, Employment History, Education Background, Financial Details, Criminal Records

    To facilitate our account opening process, our trust and other entities establishment process, our customer due diligence process and our vendor due diligence process

    Necessary to perform our contract, to comply with our regulatory requirements and in order to pursue our legitimate interest of managing our administrative and business operations and complying with internal policies and procedures.

    Financial and Transactional (e.g. details about your accounts with us and payments to and from your accounts with us)

    To enable us to process your transactions.  To fulfil our Regulatory Reporting processes. 

    Necessary to perform our contract and to comply with our regulatory requirements.

    CCTV Video images (of visitors to our Office)

    Crime prevention, detection and prosecution, security health and safety

    In order to pursue our legitimate interest in managing the safety and security of our premises and services.

    Telephone Calls

    Monitoring of regulated activities, training and development

    To comply with our regulatory requirements and to pursue our legitimate interest to enhance the quality of our service.

    Fraudulent Activity

    To facilitate fraud case handling and reporting

    To comply with our regulatory requirements and in order to pursue our legitimate interest in preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks.

    Particulars of any complaints

    To facilitate complaints handling and reporting

    To comply with our regulatory requirements and to pursue our legitimate interest of enhancing our products and services

  5. Do we use your personal information for direct marketing?

    With your permission, we may send you carefully selected information about our products and services. You have the right to opt out of receiving direct marketing at any time.

  6. With which third parties do we share your personal information?

    Your personal information are intended for the Bank and the Trustee but may be shared with third parties in certain circumstances:

    The Bank’s group of companies: We may share your personal information among our group of companies, including our branches, subsidiaries, representative offices, parent company Oversea-Chinese Banking Corporation Limited (“OCBC”) and branches and subsidiaries of OCBC, in order to open your account with us, administer our services and products, provide you with customer support, process your payments, understand your preferences, send you information about products and services that may be of interest to you and conduct the other activities described in this Privacy Notice.

    Our service providers: We use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of our services and products to you. We may share personal information with the following categories of service provider:

    1. infrastructure and IT service providers, including for email archiving.
    2. marketing, advertising and communications agencies.
    3. credit reference agencies.
    4. external auditors and advisers.
    5. offsite archival storage providers

    In the course of providing such services, these service providers may have access to your personal information. However, we will only provide our service providers with personal information which is necessary for them to perform their services, and we require them not to use your information for any other purpose. We will use our best efforts to ensure that all our service providers keep your personal information secure.

    Third parties permitted by law: In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities).

    We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.

    Third parties connected with business transfers: We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.

    We will not sell your personal information to third parties.

    Please note our website may, from time to time, contain links to and from the websites of our partners or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal information. You should check the privacy policies of third party websites before you submit any personal information to them.

  7. Do we transfer personal information outside the EEA?

    Your personal information may be transferred to and processed in Singapore, Hong Kong, Dubai, and Philippines by our affiliates and our service providers. This list of jurisdictions may be subject to change.  We will take all steps that are reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Notice as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA (available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en).

  8. What are your rights (EEA residents only)?

    If you are in the European Economic Area, you have the following rights (if applicable):

    1. Access. You have the right to request a copy of the personal information we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
    2. Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
    3. Deletion. You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
    4. Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
    5. Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
    6. Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
    7. Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us.

    You can make a request to exercise any of these rights in relation to your personal information by sending the request by mail to the Operations Manager, of OCBC Bank of The Rex Building, 3rd Floor, 62 Queen Street, London. EC4R 1EB.

    You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

    Telephone:  +44 0303 123 1113

    Email:         casework@ico.org.uk

    Website:     www.ico.org.uk

    Web-form:  www.ico.org.uk/concerns/

    Address:     Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF

    If you are based in, or the issue you would like to complain about took place, elsewhere in the European Economic Area (EEA), please click here for a list of local data protection authorities in the other EEA countries: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

  9. How do we protect your personal information?

    We have implemented technical and organisational security measures to safeguard the personal information in our custody and control. Such measures include, for example, limiting access to personal information only to employees and authorised service providers who need to know such information for the purposes described in this Privacy Notice; adopting security protocols on networks and systems; using email security settings when sending and/or receiving highly confidential emails; applying physical access controls such as marking confidential documents clearly and prominently, storing confidential documents in locked file cabinets; restricting access to confidential documents on a need-to-know basis; using privacy filters; disposal of confidential documents that are no longer needed, through shredding or similar means; using a mode of delivery or transmission of personal data that affords the appropriate level of security (e.g. registered post instead of normal post where appropriate); confirming the intended recipient of personal data as well as other administrative, technical and physical safeguards.

    While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

  10.  How long do we keep your personal information?

    We will only retain your personal data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use personal information, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

  11.  How do we deal with children's privacy?

    We will never knowingly collect personal information from individuals under the age of thirteen (13) years without first obtaining verifiable parental consent. If you are under the age of 13 you should not provide information to us. If we become aware that a person under 13 has provided personal information to us without verifiable parental consent, we will remove such personal information from our files.

  12.  How can you contact us?

    If there are any questions or concerns regarding this Privacy Notice, please contact us as follows:

    1. The Operations Manager, OCBC Bank, The Rex Building, 3rd Floor, | 62 Queen Street, London EC4R 1EB.
  13.  Which version of this Privacy Notice applies?

    This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

    We reserve the right to change our Privacy Notice from time to time. If we decide to change our Privacy Notice we will notify you of these changes.

    25th July 2018