Privacy Notice | Sumitomo Mitsui DS Asset Management SG

Privacy Notice

You are advised that by using or accessing the website at www.smd-am.sg or any of its sub-domains (collectively, the “Site”), you have read and agree to the terms of this Privacy Policy (the “Privacy Policy”) set out below. If you do not agree to the terms and conditions of this Privacy Policy, do not use, access or browse the Site.

The purpose of this Privacy Policy is to inform you of how we handle, use, collect, process or disclose your Personal Data in accordance with, and as defined in, the Personal Data Protection Act 2012 (the “Act”) and other applicable laws.

Please note that this Privacy Policy is to be read in conjunction with the terms of use of the Site, available online in this page, the contents of which are adopted and incorporated by reference. For the purposes of this Policy, “SMDAM”, “we”, “us” and/or “our” means Sumitomo Mitsui DS Asset Management (Singapore) Pte Ltd.

In addition, we highlight that we may amend this Privacy Policy from time to time at our sole and absolute discretion to ensure that the Privacy Policy is updated and/or consistent with app applicable laws, regulatory requirements and/or our business needs.

You agree to be bound by such amendments and/or revisions to the published Privacy Policy and are encouraged to review the Privacy Policy from time to time to ensure that you are well informed of our latest amendments or revisions (if any) to the same.

Date of Policy Publication: 10 April 2025
Date Last Amended: 10 April 2025

A. Personal Data & Scope of Privacy Policy

1. As defined in the Act, “Personal Data” refers to any data or information about you from which you can be identified 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 which you may provide to us include (depending on the nature of your interaction with us):

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you; and

(b) information about your use of our Site and services, including cookies, IP address, subscription account details and membership details, but only to the extent that we may identify you from such information.

2. As stated above, this Privacy Policy sets out the general principles and specific measures we take or adopt in using, disclosing, collecting and/or storing any Personal Data you share with or provide to us. In addition, this Privacy Policy covers the access, correction, accuracy, protection, retention and transfer of your Personal Data and the withdrawal of your consent to our use, disclosure or collection of the same.

B. Consent

3. By using, accessing and/or browsing the Site, interacting with us, submitting information to us or signing up for any services offered by us, you agree and consent to SMDAM and its related corporations and affiliates collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner and for any one or more of the Purposes set forth in this Privacy Policy as described in paragraph 7 below.

4. In addition to the matters set forth herein, subject to and in accordance with applicable law, you shall be deemed to have consented to our collection, use, disclosure and/or sharing of your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:

(a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s);

(b) where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy; and/or

(c) where we have brought to your attention our intention to collect, use or disclose your Personal Data for identified purposes, and you have not taken any action to opt-out within the period specified in our notices.

5. For more information on the situations or scenarios where we may disclose your Personal Data without your consent, please see the First and Second Schedules of the Act, which are publicly available here https://sso.agc.gov.sg/Act/PDPA2012.

6. This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us nor does it affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.

C. Collection, Use, Disclosure and Security of Personal Data

7. Generally, we collect your Personal Data when you apply, register for and/or access any of the services made available, whether by subscription or otherwise, on or via this Site. The information you provide to us, including Personal Data, may be used for any one or more of the following purposes (the “Purposes”):

(a) to communicate with you and to respond to your requests and queries;

(b) to verify and process your personal particulars;

(d) for user profile and statistical analysis;

(e) to send you information, notifications, updates and reports in relation to the requested services;

(f) for legal compliance purposes, the requests of law enforcement and regulatory officials, or orders of court;

(g) for account opening, or entering into a relationship at your request, including performing anti-money laundering, anti-terrorism, sanction screening, fraud and other due diligence checks;

(h) to deliver the services you have requested, including liaising with third parties;

(i) to manage payments, fees, and charges;

(j) to manage the relationship with you which will include notifying you about changes to our terms of business or this privacy notice;

(k) to manage and protect our business, including improving data security, troubleshooting data and systems, system maintenance and testing, data hosting, managing our offices and other facilities;

(l) to manage and improve our products and services with relevant and up-to-date information.

(m) for marketing communications and service updates; and

(n) for any other purposes for which we have obtained your consent.

8. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the any one or more of the Purposes to the following third parties, whether they are located overseas or in Singapore:

(a) our affiliates and related companies and/or corporations;

(b) agents, contractors or third-party service providers who provide operational services to us;

(c) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

(d) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions;

(e) anyone to whom we transfer or may transfer our rights and duties;

(f) our professional advisors such as our auditors and lawyers;

(g) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and/or

(h) any other party to whom you authorise us to disclose your Personal Data.

9. We will take all reasonable steps to protect your Personal Data from unauthorised access, use or disclosure. We store the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. Save as expressly provided in this Policy, we will not share your personal information with third parties without your permission, except if required by law or a court order to do so.

10. Please be aware that no method of transmission or storage is completely secure. While security cannot be guaranteed, we strive to protect your Personal Data by implementing appropriate security measures. Should we become aware of any unlawful or unauthorised access, use or disclosure of your Personal Data, we will notify you if and as required under Singapore data protection laws, as well as take reasonable steps to mitigate the effects of any data breach.

11. To the extent that we may need to transfer Personal Data outside of Singapore for any of the purposes stated in this Privacy Policy, whether to our parent company, group companies, business partners or third party service providers or to data storage facilities, we shall do so in accordance with the Act and ensure that the standard of protection provided to Personal Data so transferred is comparable to the protection required under the Act.

12. Please note that the Site may contain hyperlinks to other websites, the data protection and privacy practices of which may differ from this Privacy Policy. We are not responsible for the content and privacy practices of such websites and encourage you to consult the privacy notices of any such sites.

D. Retention, Access, Correction and Withdrawal of Consent

13. We will store your Personal Data only to the extent necessary for legal and our business purposes, including the Purposes described above, except as provided otherwise by applicable laws. When there is no longer any business or legal purpose for retaining your Personal Data or the statutory retention period expires according to applicable laws, we will delete or anonymize your Personal Data.

14. You have the right to request for access to your Personal Data held by us and to request correction of the same, except when such access is prohibited by any law or in relation to any order or judgment of a court.

15. You may submit a written request to access, correct or withdraw consent to the use of your Personal Data. Any such written requests should be submitted to our data protection officer(s) via email (“DPO”), whose details are as follows:-

(a) Data Protection Officer
Chief Executive Officer
akihiro_sato@smd-am.co.jp

(b) Alternate DPO
Chief Compliance Officer
eric_ng@smd-am.co.jp

16. The DPO is responsible for ensuring that measures stated in this Privacy Policy are implemented and appropriately executed so that we comply with the principles of data protection at all times. The DPO is also responsible for responding to:-

(a) any questions or feedback or requests for further information relating to our Privacy Policy

(b) any requests to withdraw consent to any use of your Personal Data;

(d) any waivers/deviations from this Privacy Policy; and

(e) any complaints or grievances you may have regarding the handling of your Personal Data.

17. Where you submit any written requests to the DPO, the DPO shall process your request and respond within a reasonable time from when the relevant request is made.

E. Governing Law

18. This Privacy Policy is governed in all respects by the laws of the Republic of Singapore.