Alternative Capital Enterprises Pte. Ltd. (“ACE”) recognizes the importance and sensitivity of Personal Data and is fully committed to protecting the privacy interests of individuals who provide confidential information to ACE, as we consider privacy to be a fundamental aspect of our relationship with our clients, service providers and business associates.
As required under the Singapore Personal Data Protection Act (“PDPA”) of Singapore, this policy is to inform you how ACE manages Personal Data.
By interacting and corresponding with ACE (via electronic means, telephone or face-to-face meetings), accessing and using ACE’s website, submitting information to ACE, or signing up for any products or services offered by ACE, you agree and consent to ACE collecting, using and disclosing and sharing your Personal Data to ACE’s authorised service providers and relevant third parties in the manner contemplated 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 ACE in respect of your Personal Data, and your consents are additional to any rights which ACE may have at law to collect, use and disclose your Personal Data.
ACE may from time to time update this Data Protection Policy to ensure compliance and consistency with any future developments or changes in legal or regulatory requirements. By continuing to engage ACE’s services, to use ACE’s website () or communicate with ACE subsequent to any updates, you agree to be bound by the updates to 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 the organisation has or is likely to have access. This includes data and information in ACE’s records as may be updated from time to time.
Some examples of Personal Data may include your name or your company name; date of birth; country of birth; NRIC or passport or other identification numbers and documents; signatures; employment details, information relating to your financial circumstances; contact details such as addresses, email addresses, telephone and facsimile numbers; and any other information relating to any individuals which you may have provided to ACE or documents and/or agreements you may have signed with ACE.
Collection of Personal Data
Personal data may be collected by ACE in the following ways:
When you submit any forms to ACE during the course of our relationship;
When you enter into any agreement or provide other forms of documentation or information to ACE in respect of or in connection with engaging or utilizing ACE’s services, or collaborating with ACE;
When you interact with employees of ACE via telephone calls, letters, facsimile, face-to-face meetings and other electronic means;
When you respond to ACE’s request for additional Personal Data; and/or
When you submit your Personal Data to ACE for any other reason.
If you provide ACE with any Personal Data relating to a third party (e.g. information on your spouse, children, parents, and/or employees), you represent to ACE that you have obtained the necessary consent of such third party to you providing ACE with their Personal Data for the respective purposes. You should ensure that all Personal Data is complete, accurate, true and correct.
When you browse ACE’s website, you generally do so anonymously. ACE does not automatically collect Personal Data.
Use of Personal Data
ACE collects, uses and discloses your Personal Data for the following purposes:
Verifying your identity;
Assessing and processing any applications or requests made by you for products and services offered by ACE;
Responding to your queries and requests and handling complaints;
Managing and facilitating the administrative and business operations of ACE and complying with internal policies and procedures;
Complying with applicable anti-money laundering, tax evasion and anti-terrorist financing laws, regulations and rules;
Complying with any legal, governmental or regulatory requirements, codes of practice or guidelines of any relevant jurisdiction;
Complying with the requirements or directions of any competent regulatory authority;
Providing client-related services including dissemination of notices and reports; and
Any other purpose relating to any of the above.
ACE may have also specifically notified you of any other purposes which ACE collects, uses or discloses your Personal Data in relation to specific services or in your dealings with ACE. By doing so, you agree and consent to ACE collecting, using and disclosing your Personal Data for these additional purposes as well.
Disclosure of Personal Data
Subject to the provisions of any applicable law, ACE may be required to disclose your Personal Data for the purposes listed above (where applicable), to the following third parties located in Singapore or overseas:
ACE’s service providers involved in providing, managing or administering services provided to you;
External banks and financial institutions and their service providers in relation to asset management and investment product settlement processing;
ACE’s professional advisors;
Relevant government regulators, statutory bodies or authorities and/or law enforcement agencies;
Your authorised representatives; or
Any other party to whom you authorize ACE to disclose your Personal Data to.
ACE will take reasonable efforts to protect your Personal Data from loss, misuse and unauthorized disclosure. ACE restricts access to information about you to its employees on a need to know basis. To protect information about you, ACE maintains physical, electronic and procedural safeguards according to industry standards and practices which are reviewed on a regular basis. ACE retains your Personal Data to the extent one or more of the purposes for which it was collected remain valid and for other legal or business purposes which retention may be necessary.
While ACE strives to protect your Personal Data, ACE cannot completely guarantee the security of the information transmitted to ACE as no data security measures can guarantee 100% security at all times.
Data Access and Data Correction
would like to obtain access to your Personal Data;
would like for your Personal Data to be corrected or updated; or
would like to withdraw your consent or limit the use of your Personal Data,
You may submit your written request to:
Attn: Cyrille Delval
Alternative Capital Enterprises Pte Ltd
27A Ann Siang
Please note that ACE reserves the right to refuse your requests for any reasons permitted by law. Where permitted by law, you may ask that ACE collect or delete any inaccurate information.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, may result in ACE not being in a position to communicate or correspond with you, to continue providing services to you, or to administer any contractual relationship already in place.
This Data Protection Policy shall be governed by and construed in accordance with the laws of Singapore.