Xandar Capital ("we" or "us") is the operator of www.xandarcapital.com (the "Website"), and we are committed to safeguarding your personal data. This Privacy Policy (together with our Terms of Use http://www.xandarcapital.com/footer-pages/capital-terms-of-use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Unless restricted by applicable law, you agree that any and all personal data relating to you collected by us from time to time may be used and disclosed for such purposes and to such persons as set out in this Privacy Policy. We may amend this Privacy Policy at any time by posting a revised version on the Website. However, an individual notice will not be sent to you. You will be deemed to have acknowledged and agreed to the amended Privacy Policy if you continue to use the Website after the changes have taken effect. You are reminded to check for updates to this Privacy Policy prior to using the Website.
COLLECTION OF PERSONAL DATA
- You can use and browse the Website without disclosing your personal data. You are not required to provide personal data as a condition of using the Website, except as may be necessary to respond to your requests or in cases where you contact us directly.
- We collect personal data only when you provide it to us, through registration, completion of forms, emails, inquiries and requests and similar situations in which you have chosen to provide the information to us.
information that you provide when contacting us to resolve any issues that you may be facing;
information that you provide for the purpose of subscribing to the services that we are providing on the Website, email notifications, and/or newsletters; and
details of your visits to the Website including, but not limited to traffic data, location data, and the resources that you access.
PURPOSES OF USE
- All information collected, including personal information, may be used by us in the aggregate or individually and may be combined with other information for purposes including but not limited to the following:
administering the Website;
improving your browsing experience by personalising the Website;
enabling your use of the services available on the Website;
providing to you services that you have specifically requested;
responding to and taking follow-up action on complaints;
sending you general (non-marketing) commercial communications;
performing office and operational administrative matters; and
providing third parties with statistical information about our users – but such information will not be used to identify any individual user.
SECURITY
- We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information.
- We will store all the personal information you provide on our secure servers.
- You however understand that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Website; any transmission is at your own risk.
DISCLOSURE OF PERSONAL DATA
- We may disclose your personal data to any member of our group, which means our affiliates and subsidiaries. We may also disclose your personal data in order to: third parties such as our service providers and professional advisors.
- We may also disclose your personal data in order to:
comply with any legal obligation;
to enforce or apply our Terms of Use www.xandarcapital.com/footer-pages/capital-terms-of-use and other agreements;
protect the rights, property, or safety of us and our affiliates and subsidiaries, other users of the Website, or others;
in connection with any legal proceedings or prospective legal proceedings;
IP ADDRESSES
- When you use the Website, we may collect and store information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
COOKIES
- The Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website.
INTERNATIONAL DATA TRANSFERS
- You acknowledge and consent to the fact that we may temporarily store, process or transfer your personal data between any of the countries in which we operate in order to enable us to use your personal data in accordance with this Privacy Policy and our Terms of Use at www.xandarcapital.com/footer-pages/capital-terms-of-use
- We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.
ACCESS AND CORRECTION
- Our privacy officer is responsible for ensuring that requests for access to information and amendment of information are properly dealt with in accordance with the procedures specified herein.
- All requests for information or requests for the amendment of information held by us shall be made by completing our standard Request form, and sending a copy of the duly completed form to us via post or fax at:
- Xandar Capital
- Shenton House
- 3 Shenton Way #24-02
- Singapore 068805
- Attention: Privacy Officer
- Please note that we will only accept and act on requests in the English language that comply with this Privacy Policy. Any request that does not comply with the above will be rejected, and we will not take any action in relation to such rejected requests. We reserve the right to require you to translate any request or any part of the request which is not in the English language before we act on the same OR proceed at our own discretion to translate the language.
- We may refuse to disclose or amend any information for the reasons set out in the Personal Data Protection Act 2012.
- As far as reasonably possible, we will respond to your request within twenty one (21) days from the date of receipt of the request ("Initial Period"). If that is not possible, you will be so notified in writing before the expiry of the Initial Period, together with the reasons why we are unable to do so and what requests we can comply with. In any event, the request will (unless permitted otherwise under the law) be complied with no later than fourteen (14) days after the expiration of the Initial Period.
DISCLAIMER
- We shall not be liable for any voluntary disclosure of personal information by you to other users of the Website.
CONTACT US
- Should you require further information about the treatment of your personal information by us, please do not hesitate to contact us at: dpo@xandarcapital.com
PERSONAL DATA PROTECTION POLICY
Xandar Capital Pte Ltd (“Xandar Capital”) respects the privacy of all our customers and business contacts, and is committed to protecting the personal information you provide to us. Please read this Personal Data Protection Privacy Policy (“Policy”) to learn more about the ways in which we collect, use and protect your personal information.
Glossary
Xandar Capital Pte. Ltd. |
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Personal Data Protection Privacy Policy |
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Singapore Personal Data Protection Act 2012 |
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PDPA |
Personal Data Protection Commission |
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Clients |
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Individual and/or Corporate |
Group |
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Group of Companies of Corporate Client. |
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1. Application of Policy
This Policy is based on the Singapore Personal Data Protection Act 2012 ("PDPA") and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission ("PDPC") of Singapore. Xandar Capital may be subject to different or more restrictive local laws in the jurisdictions outside of Singapore.
By providing your personal data to Xandar Capital by you or through your Company or Group of companies (the”Group”), you agree to the terms of this Policy. Please review this Policy carefully before providing us with any of your personal data.
2. Collection on Personal Data
For the purpose of carrying on Xandar Capital’s business, you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
a) Full Name
b) Mobile Number
c) Residential Address
d) Residential Number
e) Personal Email Address
f) Passport/IC number
g) Bank Account Number
h) Credit History
i) Date of Birth
j) Information on immediate family
k) Marital status
3. Use of Personal Data Collected
Xandar Capital either currently uses or may in the future use your personal data for the purposes you have been notified of and consented to or which are not prohibited by applicable law. This includes the following purposes:
a) For onboarding of clients
b) Conducting customer due diligence including sanctions screening
c) Providing business and financial advisory services related to the proposed listing the Singapore Exchange Limited
d) Maintain client relationship between Xandar Capital and corporate clients
e) Any other purposes which Xandar Capital may inform you of in writing from time to time, but for which Xandar Capital will seek your separate consent
If we wish to use, disclose or process your Personal Data for another purpose we will seek your explicit consent in writing beforehand.
4. Disclosure of Personal Data
All personal data held by Xandar Capital will be kept confidential but Xandar Capital may provide such information to the third parties if it is necessary to satisfy the aforementioned purposes or a directly related purpose.
Xandar Capital also acknowledges and is aware that under the Notices and Guidelines issued by the Monetary Authority of Singapore relating to the prevention of money laundering and countering the financing of terrorism, Xandar Capital may conduct or appoint third parties to conduct relevant customer due diligence to identify any integrity risk on the Group or person(s) acting on behalf of the Group.
For the purpose of such customer due diligence, the Group’s personal data may be given to third parties conducting the due diligence.
The Company is aware that if there are any negative findings from the due diligence report, Xandar Capital reserves its right to stop work for the Group.
Xandar Capital is obligated to report to the relevant authorities on any suspicious transactions and with such reporting being confidential, Xandar Capital is not obligated to give the Group any notice of.
5. Withdrawal of Consent
If you do not wish for us to use or disclose your Personal Data for any of the above purposes, you may withdraw your consent at any time via the consent withdrawal form in this link. Depending on the circumstances and the nature or extent of your withdrawal, the withdrawal of your consent may result in us not being able to provide services to you.
Once you have completed the form, you can either scan and email to our Data Protection Officer (DPO) at dpo@xandarcapital.com or mail the completed hardcopy form to:
Xandar Capital Pte. Ltd.
Shenton House
3 Shenton Way #24-02
Singapore 068805
Attention: Data Protection Officer
6. Access and Correction of Personal Data
If you wish to access, update or otherwise change or remove any information that you provide to us, please contact us at dpo@xandarcapital.com.
7. Accuracy of Personal Data
Xandar Capital keeps personal data as accurate, complete and up-to-date as possible, by taking into account its use and the interests of our customers. The data provided will be validated by making references to generally accepted practices and guidelines. This includes the requests to see original documentation before using your personal data.
8. Protection of Personal Data
Xandar Capital protects personal data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security protection measures which are appropriate to the sensitivity of the personal data.
However, with the existing protection measures in place to protect your personal data, you will appreciate that it is not for us to perfectly secure your personal data from cyber-attacks, such as hacking, spyware and viruses. On that account, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.
9. Retention of Personal Data
Xandar Capital will retain your personal data only for as long as the purposes for which the data is collected or used (as notified to you) continues, or where necessary for our legal or business purposes. Thereafter, Xandar Capital will delete or destroy the personal data, or restrict access to data which can be associated with you.
10. Transfer of Personal Data Outside of Singapore
Xandar Capital does not transfer any personal data outside of Singapore. However, should Xandar Capital be required to transfer any personal data outside of Singapore, we will notify you and seek your explicit consent in writing beforehand.
Changes to Policy
We reserve the right to modify or change this Policy at any time. The Effective Date, as stated above, indicates the last time this policy was materially revised. Please refer to this page for any changes and updates to our Policy regarding our handling of your personal data
Contact Us
If you have further questions about this Privacy Policy or wish to contact us regarding this policy, please do not hesitate to contact us at dpo@xandarcapital.com.