Last revised on 9 Feb 2021
Our commitment to you
UTI International is committed to use, store, process and handle personal information in accordance with all applicable privacy and data protection laws. We will act responsibly and are committed to maintain the confidentiality, security and integrity of your personal information.
Applicable Data Protection Laws, as amended or replaced
|Singapore||:||Personal Data Protection Act (“PDPA”)|
|United Kingdom||:||Data Protection Act (“DPA”)|
|DIFC, United Arab Emirates||:||Data Protection Law (“DIFC Law No. 5 of 2020”)|
|European Union||:||General Data Protection Regulation (“GDPR”)|
Personal information collection and usage
Personal information is the information relating to an individual, which can be used either alone or with other sources of information to identify that individual. Personal information does not include information where the identity of the individual or the specific detail of the information has been removed and is therefore anonymous.
- Personal and contact details, such as title, full name, gender, date of birth, passport details, national identification number, signature, nationality, postal address, email address, telephone, mobile and fax numbers
- Professional and financial data, such as bank account number, your employer or business details including your position/job title
- Records of your communication with us, such as calls on recorded line(s) or video conferences, emails, notes of meetings, IP/MAC address and cookies when you visit our website(s)
We collect your personal information in several ways, including:
- When you provide it to us in connection with a product or service offered by us, such as a completed investment application form or account opening form, or in the course of on-going customer service
- From public sources including public profiles on social media and other websites
- From third parties such as credit reference agencies, fraud prevention agencies, banks and other financial institutions, third-party verification service providers and the providers of public registers
- From visits to our website(s)
We use your personal information primarily to respond to your inquiries or requests; to maintain and protect your accounts; to process transactions; to fulfil our contractual and legal obligations; for research and analytical purposes; and to develop and provide the financial products and services that we offer or sponsor.
Unless we otherwise indicate that the provision of specific personal information is optional, any personal information we request is necessary for us to provide you or your company with the products and services requested. If you do not provide the personal information requested, we may not be able to provide those products and services.
Sensitive Personal Information
Sensitive personal information is a sub-category of personal information, which includes data such as race, ethnicity, religions, sexual orientation, political opinions, trade union membership, health, genetic and biometric data.
We do not require sensitive personal information for the course of our business, hence we neither request nor process such sensitive personal information.
Legal basis for processing personal information
We process your personal information on the following basis:
- Performance of a contract, and in accordance with our Terms and Conditions
- Legal, regulatory or juridical obligation
- Legitimate interests, such as
- To ensure that we do not accept the proceeds of crime or assist in fraudulent or any unlawful or terrorism activities
- To ensure that we provide you with the best client services and visitor services that we can offer
- To secure and process payment of any fees and charges
- To maintain our relationship with you, such as contacting you to notify you important changes to our terms of business
- To respond to any court orders, governmental, regulatory, audit request and reporting
- To improve our client services and expand our business, such as inviting you to our workshops, seminars and other events; sending you survey and feedback forms; sending you marketing materials, communications and services updates and to conduct research and statistical analyses
- Consent for a specific purpose
Disclosure of personal information
In connection with one or more of the legal basis outlined in the previous section, we may disclose your personal information in any jurisdiction:
- To competent national and/or international authorities or their agents where UTI International is required or allowed to disclose the information under the applicable law, regulation or court order
- To credit reference agencies or other organisations that assist us to conduct AML/CFT checks, detection of potential fraud and other criminal activities, and to conduct relevant due diligence and background checks
- To goods and services providers (including providers of fund administration services, marketing services), intermediaries, brokers, and other individuals and entities that partner with us;
- To a potential buyer, transferee, merger partner or seller and their advisers in connection with any actual or potential transfer or merger of part or all of UTI International’s business or assets, or any associated rights or interests, or to acquire a business or enter into a merger with it
- To professional advisors, third parties, agents or contractors that provide services to us, such as IT system providers, platform providers, financial advisors, brokers, lawyers, accountants,
- To other service providers who create, maintain or process databases (whether electronic or not), offer record-keeping services, email transmission services, messaging services or similar services which aim to assist us to collect, storage, process and use your personal information or get in touch with you or improve the provision of our services or activities under the Agreement between us
- Where necessary for us to defend or exercise our legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority
- To other members of UTI International
- At your request or with your consent
- To any person whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument.
Transfer of personal information internationally
To provide global services and in the course of running our business, we may transfer your personal information to a location outside of the country where you or your employer/business reside or where services are provided to you. Although the country to which personal information may be transferred may not have the same level of privacy and data protection laws as your home country, we have implemented appropriate cross-border transfer solutions and safeguards to protect the transfers of your personal information in accordance with applicable data protection laws. By using our service and providing us with your personal information, you consent to the international transfer of information about you when required.
To fulfil our contractual, legal and regulatory obligations, we may make direct contact with you by telephone, fax, email or post.
If you have consented, we or any of our affiliates or partners may contact you for marketing purposes to bring to your attention products or services that may be of interest to you or to conduct market research.
Exercising your right to opt-out of direct marketing
We do not share or sell your personal information to third parties for these third parties’ own marketing or other purposes.
Retention of personal information
We will process your personal information for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defence of legal claims. We may also retain some of your information in an anonymised and aggregated form to support the development and improvement of our services and products.
Measures to safeguard personal information
We utilise several physical, electronic and managerial measures to safeguard your personal information, including:
- Storing your personal information on secured servers, with segregation of networks
- Technological security measures, including firewalls, encryption, and anti-virus and anti-malware softwares
- Limiting access to your personal information to only those employees or partners who need to know the information in order to fulfil contractual, legal or juridical obligations
- Limiting the storage of your personal information to the minimum duration of the mandatory retention period in accordance with applicable laws
- Education and training of our employees to ensure awareness of our privacy obligations when processing personal information
- Training and periodic reminders to our employees on cybersecurity, including topics such as social engineering, phishing, and cyber attacks
- Procedures to request our affiliates and vendors to maintain the confidentiality of personal information
While we will take all reasonable efforts to safeguard your personal information, you acknowledge that the security of data transmitted over the internet (including by e-mail) cannot be guaranteed and carries the risk of access and interception. We endeavour to protect personal information but cannot guarantee the security of data transmitted to us or by us.
You have certain rights available to you based on how and why we are collecting and processing your personal information, as summarised below. You may exercise your rights at any time by reaching out to us. We may need to request specific personal information from you in order for us to confirm your identity. We will respond to any legitimate requests within a reasonable time frame, and will notify you if we need to take longer if your request is particularly complex or if you have made a number of requests.
Inform and Access
You may request for a copy of the personal information that we process concerning you and to be informed about how we use and share your personal information.
Correction and Rectification
You may request us to update the personal information that we process concerning you, if it is incorrect, incomplete or outdated.
You may request us to delete the personal information that we process concerning you where we do not or no longer have the legal or regulatory obligation or other valid reasons to continue to process it
You can request us to stop processing your personal information or restrict how we process your personal information
This is the ability to request for the personal information we hold about you in a format that would allow it to be moved to another service provider. If requested, we will provide the applicable personal information in a reasonable format.
The is the right to object to the processing of your personal information if (i) we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling), or (ii) if we are processing your personal information for direct marketing purposes. Refer to the above section on exercising your right to opt-out of direct marketing.
We will consider several factors when assessing an objection. If your objection is upheld, we will cease to process your personal information for the stated purpose(s) unless we have compelling legitimate grounds, legal or regulatory reasons to continue.