Legal and Compliance

The objective of this data protection policy (“DPP”) is to inform you how Jupiter Wealth Advisors Pte Ltd. (the “Company”) manages Personal Data 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. The DPP governs our purpose, practice and procedures that involve the collection, use and disclosure of Personal Data.

In our interaction and dealings; when submitting information to us, during your term of employment with us, or signing up for any Products and Services offered by the Company, you agree and consent to the Company (including its related entities and business units) (collectively, the “Companies”), as well as their respective representatives and/or agents(collectively referred to herein as “Jupiter Wealth Advisors Pte Ltd.”, “us”, “we” or “our”) collecting, using, disclosing and disseminating within the Companies 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 substitute anyother consents you may have previously provided us in relation to your Personal Data. Consequently, the consents covered here are in addition to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.

The company may update this DPP from time to time so as to ensure that the DPP is consistent with business model, industry practices and takes into account any changes in the legal or regulatory requirements.

By moving forward with your dealing with us, you are consenting to our DPP, and subject to your legal rights, you acknowledge and agree to be bound by the prevailing terms and condition of our DPP as updated from time to time.

1. Personal Data

1. In this DPP, “Personal Data” refers to any data 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.
2. Instances of such Personal Data include (depending on the nature of your personal or business dealings with the Company) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data, next-of-kin information, as well as information relating to any individuals which you have provided us in any forms you may have submitted to the Company in respect of your dealings with the Company.

2. Collection of Personal Data

1. With respect to personal data that the Company collects after the PDPA came into effect, the Company have to get your consent to the collection, use and disclosure of your personal data. To obtain your consent, the Company would inform you of the purpose(s) for the collection, use or disclosure of your personal data. You can ask the Company to provide the contact of a person who can answer, on behalf of the Company, your questions about the collection, use or disclosure of the personal data.
2. The Company generally collects personal data as follows (but not exhaustive or limited to):
   1. when you submit an application form or other forms relating to any ofour business services, including employment purposes (defined below);
   2. when you interact with our service personnel, consultants, for instance, viaemails, telephone calls, letters, social media and face-to-face meetings;
   3. when you utilise our products and services, for instance, our websites and computer applications, including establishing any online accounts with us;
   4. when we contact you, be included in an email or other mailing list;
   5. when you respond to specific information request or to a request for additional Personal Data;
   6. when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, consultant, director, representative or any other position;
   7. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities;
   8. when executing administrative procedures, for instance, payment of salaries, registration for events and application to authorities; and/or
   9. when you submit your Personal Data to us for any other reasons.
3. When you browse our website, we generally do not collect personally identifiable information automatically unless you provide such information or login with your account authorisations.
4. When you provide us with any personal particulars that relate to a third party (e.g. information of your next-of-kin or spouse, children, parents, and/or previous employers), by submitting such information to us, you represent to us that you have obtained the necessary consent of the relevant third party to provide us with their Personal Data for the required purposes.
5. You acknowledge that all Personal Data submitted to us is appropriate, sufficient, accurate, true and correct at the time you submitted the personal data.

3. Collection, Use and Disclosure of Personal Data

1. With respect to personal data that the Company collected prior to the PDPA, the company may continue to use such personal data for the purposes for which it was collected unless you inform the Company that you do not consent to the use of your personal data.
2. Generally, the Company collects, uses and discloses your Personal Data for thefollowing purposes (but not exhaustive or limited to):
   1. responding to your queries and requests;
   2. to verify your identity, assess or perform due diligence searches for business operations purposes;
   3. managing the administrative and business operations of the Company andcomplying with internal policies and procedures;
   4. facilitating business operations and transactions (which may extend to anybusiness promotions, service offerings, consulting engagements or for media cover and publicity) involving any of the Companies;
   5. matching any Personal Data held which relates to you for any of thepurposes listed herein;
   6. resolving complaints and handling requests and enquiries;
   7. preventing, detecting and investigating crime and analysing andmanaging commercial risks;
   8. managing and executing our employment or service-level agreements with you;
   9. providing media announcements and responses;
   10. monitoring or recording phone calls, emails and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
   11. organising promotional events;
   12. legal purposes (including but not limited to obtaining legal advice anddispute resolution);
   13. if you’re an employee of the Company, to facilitate the continuation of employment or resignation and or termination of services;
   14. conducting investigations relating to disputes, billing or fraud;
   15. administering and processing any insurance claims andpayments arising under the respective Company policies;
   16. generating internal reports (including but not limited to annual,operational and employee performance management reports);
   17. processing referral payments and commission fees for our consultants, and or external partners;
   18. administering fee adjustments, refunds and waivers; and
   19. meeting or complying with any applicable rules, laws, regulations, codesof practice or guidelines issued by any legal or regulatory bodies which arebinding on the Company (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
   20. purposes which are reasonably related to the abovementioned.
3. In addition, the Company collects, uses and discloses your Personal Data for the following purposes (but not exhaustive or limited to):
   1. If you are a customer or an employee of an organisation which is aclient of the Company:
      1. maintaining identification and source of wealth records in line with MAS regulations, and for due diligence purpose and account opening;
      2. administering and processing any claims and payments arising under the respective service level agreements;
      3. generating internal audit reports (including but not limited to annual,operational and risk management reports);
      4. processing referral payments and commission fees to our external partners (if any);
      5. administering fee adjustments, refunds and waivers; and
      6. purposes which are reasonably related to the abovementioned.
   2. If you are submit a job application to us for employment purposes:
      1. conducting interviews;
      2. processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
      3. obtaining references and for background screening;
      4. assessing your suitability for the position applied for;
      5. onboarding successful candidates and facilitating human resource planning and management (including but not limited to preparing letters of employment, name cards and building access passes); and/or
      6. purposes which are reasonably related to the abovementioned.
   3. If you are an existing employee of the company:
      1. providing remuneration and staff benefits (including employee share option schemes, leave, and insurance), reviewing salaries, commissions and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring awards;
      2. administrating the employment relationship, its management and termination, including manpower, logistics management, work permit, employment pass or visa applications, providing employee relocation support, processing expense claims, tax clearance and payment to provident funds, facilitating overseas travel arrangements, and reservist management;
      3. training, learning and talent development;
      4. providing you with tools and/or facilities to enable or facilitate the performance of your duties;
      5. business continuity, including compiling and publishing internal directories and emergency contact lists;
      6. conducting analytics, surveys and research for human resource planning and management, and for us to review, develop, optimise and improve work related practices, environment and productivity;
      7. ensuring that the administrative and business operations of the Companies function in a secure, efficient and effective manner;
      8. generating incident reports and handling complaints;
      9. administering cessation processes; and/or
      10. purposes which are reasonably related to the abovementioned.
4. In addition, where allowed under the Act:
   1. The Company may also collect, use and disclose your Personal Data for the following additional purposes:
      1. analytics and tracking, including facilitating the sale of analyticaldata;
      2. conducting market research and surveys to enable us tounderstand and determine client preferences anddemographics to develop new products and services, and marketing programmes in relation to the Company’s stated objectives and aims, and to enhance our quality of service delivery and the customer experience;
      3. offering additional Products and Services and benefits to clients,including a broader more insightful assessment and analysis, with prompt delivery of service at competitive rates without compromising service standards;
      4. matching Personal Data with other data collected for otherpurposes and from other sources (including third parties) inconnection with the provision, marketing or offering of Products andServices by the Company;
      5. leads generation and management for marketing the company’sProducts and Services;
      6. administering contests, competitions and marketing campaigns,and personalising your work experience at the Company;
      7. communicating information involving details of the Company related developments, industry trends, and products and services, either to employees and or to our clients generally, or prospective clients that have expressed an interest in our business offerings;
      8. organising promotional events and corporate socialresponsibility projects; and
      9. purposes which are reasonably related to the abovementioned.
      10. Furthermore, where allowed under the Act and relevant laws, subject to your legal right, your Personal Data may be disclosed, for the Company’s additional purposes, to the vendors or other third party service providers in connection with promotions and services offered by the Company.
   2. 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, the company 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 or those products and services offered by our Companies and preferred partners.
   3. In relation to particular Products and 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. You have a choice to withdraw your consent for receiving marketing orpromotional materials/communication.
   5. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with the Company.
   6. If you have registered in the National DNC registry through voice, text messages or fax, we will not send you marketing messages unless you have expressed a clear and unambiguous consent or have an on-going relationship (for text / fax).

   4. Disclosure of Personal Data

   1. The Company will take all reasonable measures to protect your Personal Data against unauthorised disclosure or use. Subject to the relevant laws and your legal right, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
      1. The Company’s related entities and employees to provide administrative, personnel, management, and consultancy services in relation to your specific concerns; for instance, employment benefits, training, administration of services to managing the compliance requirements of clients of the Company;
      2. companies providing services relating to medical screening and insurance tothe Company;
      3. agents, contractors or third party service providers who provide operational services to the Company, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to the Companies;
      4. third party service providers and vendors in connection with marketingpromotions and services offered by the company or its related entities;
      5. other telecommunications, content or other service providers tofacilitate their provision of content or services, or for interconnection,inter-operability, system operation and maintenance;
      6. any business partner, investor, assignee, transferee (actual orprospective) or authorised agent to facilitate business transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
      7. collection and repossession agencies in relation to the enforcement ofrepayment obligations for debts;
         1. external banks, credit card companies and their respective serviceproviders;
         2. our professional advisers such as auditors and lawyers;
         3. relevant government regulators, statutory boards or authorities or lawenforcement agencies to comply with any laws, rules, guidelines andregulations or schemes imposed by any governmental authority; and
         4. any other party to whom you have authorised for us to disclose your Personal Data according to the applicable laws.

   5. Care of Personal Data

   1. The Company would make reasonable effort to ensure that your personal data is accurate and complete, if your personal data is likely to be used to make a decision that affects you, or is likely to be disclosed to another organisation.
   2. The Company would also make reasonable security arrangements to protect personal data we possess or control, to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
   3. The Company would stop keeping your personal data when it is no longer necessary for legal or business purposes.
   4. The Company may only transfer your personal data outside of Singapore if the Company put in place measures to ensure that the protection provided to the personal data transferred is comparable to the protection under the PDPA, unless exempted by the PDPC.
   5. These rules are subject to exceptions and they are generally purpose-based. For instance, some of these exceptions relate to emergency situations, investigations, national interests, publicly available data or where the personal data is used for evaluative purposes. For more information, please refer to the Second to Sixth Schedules of the PDPA.

   6. Data Security

   1. The Companies 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.
   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 through the use of 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. Withdrawal of Consent, Access and Correction of Personal Data

   1. In relation to access of personal data that the Company possesses or controls. You can also request to be provided with information about the ways in which such personal data has or may have been used or disclosed within the year before the request. However, in certain circumstances or in respect of certain types of personal data, the Company may be prohibited from granting such access or may choose whether or not to provide such access.
   2. You may request the Company to correct an error or omission in your personal data. The Company should also send the corrected data to other organisations (or, with your consent, only to specific organisations) to which your data has been disclosed within a year the correction is made. Unless there are reasonable grounds for a correction not to be made, the organisation should correct your data as soon as practicable.
   3. In relation to your Personal Data and how it relates with our Company, if you have any queries or concerns; or you would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or you would like to access or correct your personal Data records, please contact Jupiter Wealth Advisors Pte. Ltd. as follows:
      • Email: [email protected]
      • Write in: Data Protection Officer, Jupiter Wealth Advisors Pte Ltd.7 Staits View #05-02 Marina One East Tower Singapore 018936
   4. Please note that if your Personal Data has been provided to us by a thirdparty (e.g. a referrer), you should contact that organisation or individual to makesuch queries, complaints, and access and correction requests to Water Dragon Solutions on your behalf.
   5. If you withdraw your consent to us for the use of your Personal Data, subject to the nature of your request, the Company may not be in a position to continue to provide its Products and Services to you, administer any contractualrelationship in place, which in turn may also result in the premature or automatic termination of any undertakings or agreements with the Company, and you may be in breach of your contractual obligations or undertakings. In such event, the Company’s reserves all legal rights and remedies.

   8. Governing Law

   1. This Data Protection Policy shall be governed in all respects by the laws of Singapore.