Last Updated: December 2024
Sterling Harbour is committed to protecting the privacy and confidentiality of client information. This policy explains how we collect, use, store, and safeguard personal data in accordance with the Personal Data Protection Act 2012 (PDPA) and related Singapore regulations governing financial advisory services.
We recognize that individuals who engage our investment consulting services entrust us with sensitive financial and personal information. This responsibility guides our data protection practices and informs our commitment to maintaining rigorous security standards.
We collect information necessary to provide professional investment advisory services. The specific data collected varies by service type but typically includes the following categories:
This includes your name, email address, phone number, residential address, and identification documents as required for regulatory compliance purposes. We collect this information through initial inquiry forms, engagement agreements, and during the advisory relationship.
To provide appropriate advisory services, we collect information about your current investment holdings, asset allocation, income sources, employment status, investment objectives, risk tolerance, time horizon, and related financial circumstances. This information allows us to develop suitable recommendations aligned with your situation.
We maintain records of communications between you and our advisory team, including emails, meeting notes, phone conversation summaries, and written correspondence. These records support service quality, regulatory compliance, and continuity of advice.
When you visit our website, we collect standard technical information including IP address, browser type, device information, pages viewed, and interaction patterns. This data helps us improve website functionality and understand how visitors use our online resources.
We process personal data on the following legal bases:
Consent: You provide explicit consent when submitting inquiry forms, engaging our services, or opting into specific communications.
Contract Fulfillment: Processing is necessary to deliver advisory services outlined in our engagement agreements.
Legitimate Interests: We process data to improve services, ensure security, prevent fraud, and maintain business operations where such processing does not override your privacy rights.
Legal Obligations: Certain data processing is required to comply with Singapore financial services regulations, including record-keeping requirements established by the Monetary Authority of Singapore.
Personal information collected is used for the following purposes:
Service Delivery: Providing investment advisory services, conducting analysis, developing recommendations, and supporting implementation as requested.
Client Communication: Responding to inquiries, scheduling meetings, sharing advisory deliverables, and maintaining ongoing dialogue during active engagements.
Service Improvement: Analyzing feedback, identifying enhancement opportunities, and refining our advisory methodology based on client experiences.
Regulatory Compliance: Meeting documentation, reporting, and record-keeping requirements established by MAS and other relevant authorities.
Security and Fraud Prevention: Protecting our systems, detecting unauthorized access attempts, and safeguarding client information from security threats.
We retain personal information for periods determined by regulatory requirements and business necessity. Specific retention periods include:
Client Records: Advisory files and related documentation are maintained for seven years following engagement completion, consistent with MAS record-keeping requirements.
Communication Records: Email correspondence and meeting notes are retained for the duration of the advisory relationship plus seven years.
Inquiry Data: Information from individuals who contact us but do not proceed with services is retained for two years to facilitate follow-up if interest resumes.
Website Analytics: Technical information collected through website visits is typically retained for two years or as specified in our cookie policy.
Data deletion procedures ensure secure removal of information no longer required for business or regulatory purposes. Backup systems maintain deleted data for additional periods as necessary for system recovery purposes.
We implement comprehensive security measures to protect personal information from unauthorized access, disclosure, alteration, or destruction:
Encryption: Data transmission between your devices and our systems uses industry-standard encryption protocols. Sensitive information stored in our systems is encrypted at rest.
Access Controls: Personal information access is restricted to authorized personnel on a need-to-know basis. Multi-factor authentication requirements apply to system access. Regular access reviews ensure appropriate authorization levels.
Physical Security: Our office premises maintain controlled access systems. Physical documents containing client information are stored in secured locations with limited access.
Incident Response: We maintain documented procedures for identifying, responding to, and reporting data security incidents. In the event of a breach affecting personal information, we will notify affected individuals and relevant authorities as required by Singapore law.
Vendor Management: Third-party service providers with access to client information are contractually bound to maintain equivalent security standards. We regularly assess vendor security practices.
Under Singapore's Personal Data Protection Act, you have specific rights regarding your personal information:
Right to Access: You may request copies of personal information we hold about you. We will provide this information in a commonly used format within a reasonable timeframe.
Right to Correction: If you believe information we hold is inaccurate, incomplete, or outdated, you may request corrections. We will update records upon verification of the corrected information.
Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. This does not affect the lawfulness of processing conducted before withdrawal.
Right to Object: You may object to processing based on legitimate interests where such processing affects your rights and freedoms.
Right to Data Portability: You may request transfer of certain personal information to another service provider in a structured, commonly used format where technically feasible.
To exercise these rights, contact us at [email protected]. We will respond to requests within the timeframes required by Singapore law, typically within 30 days.
We engage certain third-party services to support our operations. These providers may have access to personal information for specific purposes:
Analytics Providers: We use website analytics services to understand visitor behavior and improve our online presence. These services collect technical information as described in our cookie policy.
Communication Tools: Email and video conferencing platforms facilitate client communication. These providers process communication content and metadata according to their privacy policies.
IT Infrastructure: Cloud hosting and data storage providers maintain the technical infrastructure supporting our systems. These providers implement security measures consistent with industry standards.
We do not sell, rent, or trade personal information to third parties for their marketing purposes. Information sharing occurs only as necessary for service delivery or as required by law.
Some third-party services we use may store or process data outside Singapore. Where this occurs, we ensure appropriate safeguards are in place, including standard contractual clauses, adequacy determinations, or other approved transfer mechanisms. The level of data protection in destination jurisdictions may differ from Singapore standards, but contractual protections require service providers to maintain security measures consistent with Singapore requirements.
Our website uses cookies and similar technologies. Detailed information about cookie usage, types deployed, and management options is available in our Cookie Policy. You can control cookie preferences through your browser settings or our cookie management interface.
Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that information from someone under 18 has been collected, we will take steps to delete that information promptly.
This privacy policy may be updated periodically to reflect changes in our practices, legal requirements, or service offerings. Material changes will be communicated through our website and, where appropriate, via direct communication with active clients. The "Last Updated" date at the top of this policy indicates when changes were last made. Continued use of our services following policy updates constitutes acceptance of the revised terms.
Questions, concerns, or requests regarding this privacy policy or our data protection practices should be directed to:
Email: [email protected]
Phone: +65 6482 7159
Address: Sterling Harbour, 12 Marina Boulevard, #17-05 Marina Bay Financial Centre Tower 3, Singapore 018982
We aim to respond to privacy inquiries within five business days. Complex requests may require additional time, in which case we will inform you of the expected timeline.
Our data protection practices are subject to oversight by the Personal Data Protection Commission of Singapore. If you believe we have not addressed your privacy concerns adequately, you may file a complaint with the PDPC through their official channels.