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Singapore Personal Data Policy Supplement

1.   Introduction

1.1  This Personal Data Policy ("Policy") is applicable to all persons and/or trustees who have opened or who propose to open an account with Bank J. Safra Sarasin Ltd, Singapore Branch (the "Bank"), and/or the Borrower (as defined in the standard General Terms & Conditions) and/or any other persons or entities furnishing security for a loan facility, and/or any party to any Security Document (where all such aforementioned entities or parties shall be collectively, the "Clients", and each of them, the "Client"). This Policy has been prepared pursuant to the enactment of the Personal Data Protection Act (No. 26 of 2012) of Singapore (the "Act"), and explains the type of Personal Data (as defined in the Act)  the Bank collects, and the purposes for which the Bank uses and discloses it. The Client agrees that his/her use or continued use of any of the Bank’s services shall be deemed as acceptance and agreement to be bound by this Policy.
1.2  With effect from 1 August 2014, this Policy will, by way of an amendment to the standard General Terms & Conditions (the "T&C")  in accordance with Clause 20 of the T&C, form part of the T&C governing the Client’s banking relationship with the Bank.

2.   Collection of Personal Data

2.1  From time to time, the Bank will collect from the Client, from third parties who act on behalf of the Client, from third parties including the Client’s family members, friends, beneficiaries, attorneys, shareholders, beneficial owners, persons under any trust, settlors, trustees, partners, authorized signatories and other persons (collectively all the foregoing who are natural persons to be known as "Relevant Persons", and each of them, "Relevant Person"), the following information and data:
a)  Personal Data of the Client and/or Relevant Persons which may include the following:
   i)    Name;
   ii)   NRIC, passport or other identification number;
   iii)  telephone number, address, email address;
   iv)  recorded telephone conversations and e-mail communications;
   v)   employer’s name, income range, job title, job responsibilities, employer’s contact information or financial reference;
   vi)  information from cookies, or other technologies deployed for analysis of visits to websites or the use of any IT application of the Bank; and
   vii) any other information relating to the Relevant Persons which has been provided to the Bank in any forms the Relevant Persons may have submitted to the Bank or via any other form of communications.
2.2  The Client acknowledges that where the Client or any Relevant Person fails to supply relevant data or withdraws consent to the use and/or disclosure of the relevant data as described in this Policy, the Bank may be unable to maintain and continue the provision of financial, banking or other services, products, information, functions and facilities which may be offered or made available by the Bank and/or entered into pursuant to the terms hereunder, including any transaction entered into under the T&C (collectively known as "Banking Services").
2.3  The Client warrants that where any Personal Data of a Relevant Person(s)  have been provided to the Bank, the Client has informed the Relevant Person(s)  of the purposes for which the data was collected, used and/or disclosed and has obtained the Relevant Person(s)’ prior consent for the collection, use and disclosure of such Personal Data by the Bank; or that the Client is authorised by the Relevant Person(s)  to consent on his/her behalf to the Bank’s collection, use and disclosure of his/her Personal Data, and the Client does consent on his/her behalf.

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

3.1  The Client agrees that his/her Personal Data may be collected, used and disclosed for the following purposes (collectively known as "Relevant Purposes"):
a)  Continuation or opening of bank account(s);
b)  provision of Banking Services;
c)  enhancing the Bank’s financial services or procuring, researching or developing new financial services and/or products from time to time;
d)  processing any applications or requests for new financial services and/or products made by the Client;
e)  processing, confirming and fulfilling Client’s requests or instructions regarding any products, services and transactions, and all purposes related to the foregoing (including processing or entering into instructions, orders or trades of the Client or on behalf of or at the instructions of the Client or persons acting on behalf of the Client, and any hedging transactions or other related or incidental transactions);
f)  generating financial, regulatory, management or other related reports and analysis, or issuing confirmations, contract notes, statements of account or other notifications, updates or communications;
g)  providing information and updates of the Bank’s financial services or related products;
h)  maintaining of service quality and staff training using call records and/or email communications;
i)  complying with anti-money laundering, suppression of terrorist financing, suspicious transaction reporting laws and regulations of various jurisdictions (including the jurisdiction in which the Client’s account is opened)  that apply to the Bank or its parent company, all corporations which by virtue of the relevant legislation regulating companies in the relevant jurisdiction in which the Client’s account is opened/maintained (as may be amended, substituted, renamed or replaced from time to time)  which are deemed to be related corporations of the Bank and/or its parent company, and which are otherwise associated or related corporations, as well as branches, offices, subsidiaries and member banks of the Bank wherever they are situated (where the Bank and all such aforementioned entities or parties to be collectively known the "Group Entities");
j)  internal policies applicable to the Group Entities;
k)  risk assessment, statistical and trend analysis and planning purposes;
l)  maintaining and conducting checks on credit worthiness of individuals;
m)  enforcing or defending the rights of the Bank, its employees, officers and directors;
n)  carrying out internal or external audits;
o)  debt collection;
p)  obtaining professional advice from third parties; and
q)  all other incidental purposes thereto and other purposes to which the Client may time to time agree.

4.   Disclosure of Personal Data

4.1  The Client agrees that his/her Personal Data may be used, and disclosed, where permitted by the Act, to the following entities (situated in Singapore or elsewhere)  for the Relevant Purposes:
a)  The Group Entities;
b)  nominated brokers, regulatory, fiscal or other authorities, any relevant stock exchanges, any guarantors, third party pledgors or chargors to the Bank, any share registrars, any listed companies or any of their agents in respect of the Account Holder's beneficial ownership of shares in such listed companies and the Bank's agents, trustees, administrators, custodians, other parties providing trustee, administrative and/or custodian functions, correspondent banks, auditors, legal and other professional advisers and service producers; and
c)  any other person, whether situated in Singapore or elsewhere;
   i)  to (or through)  whom the Bank assigns or transfers (or may potentially assign or transfer)  all or any of its rights and obligations pursuant to any of the Banking Services or proposed Banking Services, or under the account documents or any transaction;
   ii)  with (or through)  whom the Bank enters into (or may potentially enter into)  any participation or sub-participation in relation to, or any other transaction under which payments are to be made by reference to, any facility or proposed facility granted by the Bank;
   iii)  with (or through)  whom the Bank enters into (or may potentially enter into)  any transaction in connection with the purchase or sale of any credit insurance or any other contractual protection or hedging with respect to the Client's obligations under any of the Banking Services or proposed Banking Services or any transaction;
   iv)  with whom the Bank enters into (or may potentially enter into)  any contractual or other arrangement in relation to any of the Banking Services or proposed Banking Services or any facility or proposed facility (including, without limitation, any guarantors, sureties and/or third party security providers);
   v)   to whom the Bank out-sources the performance of operational functions of the Bank, pursuant to the procuring or management of data relating to any of the services or proposed services or any facility or proposed facility or any customer;
   vi)  who is a person, or who belongs to a class of persons, specified in the second column of the Third Schedule of the Banking Act;
   vii)  to whom (including, without limitation, all government agencies and authorities, regulators, exchanges, clearing houses, markets or depositories)  such disclosure is required by law or pursuant to the directives of such entities;
   viii) who is an external asset manager providing services to the Client;
   ix)   to whom the Bank delegates the performance of all or part of the duties of the Bank in connection with the Non-Discretionary Portfolio Advisory Service;
   x)   who is a credit bureau (the Client also agrees to such credit bureau making disclosure of such information to parties to whom such credit bureau is permitted to disclose the same for the purpose of the assessment of the creditworthiness of any persons);
   xi)  to whom the Group Entities, its nominees or agents are required to do so by any applicable laws or pursuant to any order or direction of a competent court or tribunal in any relevant jurisdiction (including any directive, guideline or recommendation of any authority or supervisory committee or body relating to anti-money laundering); and
   xii)  the Bank’s professional advisors including lawyers, auditors and accountants;
   xiii)  the drawee bank providing a copy of a paid cheque to the drawer; and
   xiv)  any counterparty to any transaction, financial institutions, investment services providers, trustees, insurers, administrators, product providers and service providers with whom you have or propose to have dealings.

5.   Inquiries

5.1  Any individual who wants to enquire about the type of Personal Data the Bank holds, to correct any Personal Data, enquire about the Bank’s policies and practices in relation to Personal Data and/or withdraw consent for use of Personal data can submit their request to their Relationship Manager.
5.2  In accordance with the terms of the Act, the Bank has the right to charge a fee for the processing of any Personal Data access request up to Singapore Dollars Fifty (SGD50)  per document.

6.   Miscellaneous

6.1  The Client hereby agrees that the Bank may revise and vary this Policy from time to time by way of notice to the Client in accordance with the T&C.
6.2  The Client acknowledges that nothing in this Policy derogates from the T&C and does not limit or seek to limit the Bank’s rights under the Act.