Data Protection Policy
Effective: 5 January 2023
The purpose of this document (“Data Protection Policy”) is to inform you of how Alphalytix Consulting Pte Ltd. and its related corporations (collectively, the "Companies"), and their respective representatives and agents (“Representatives”) (the Companies and Representatives collectively referred to as "Alphalytix", "us", "we" or "our") collect, use and disclose Personal Data. We may update or change this Data Protection Policy by publishing the latest version of our Data Protection Policy on our website (www.Alphalytix.io). This is to ensure that our Data Protection Policy conforms with future developments, industry trends, and changes in legal or regulatory requirements. We may inform you of changes in how we process your Personal Data through appropriate means, such as by posting a notice, or sending you an SMS or email.
Personal Data
- In 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 we have or are likely to have access.
- The Personal Data you provide to us depends on the nature of your interaction with us, and the Alphalytix products and services that you use. Some examples of Personal Data include:
- Your full name;
- NRIC, passport or other identification number;
- Contact details such as telephone number(s), mailing address, email address;
- Your location;
- Customer information;
- Account numbers and transactional data; and
- information relating to any individuals which you provide to us.
-
Collection of Personal Data
-
We will only collect your Personal Data in a lawful manner and when we have a valid reason to do so. Generally, we collect your Personal Data in the following ways:
- when you submit any form, including application, declaration, proposal or referral forms;
- when you enter into any agreement, provide other documentation or information relating to your interactions and transactions with us, or when you use our services;
- when you interact with us (including customer service officers, relationship managers, and our automated systems for example, via telephone calls (which may be recorded), letters, online chat, fax, face-to-face meetings and email);
- when you are within our premises, or attend events hosted by us;
- when you use services provided through our online and other technology platforms, such as websites and apps, including when you set up any online accounts with us;
- when you ask us to contact you, include you in an email or other mailing list, or participate in our promotions and other marketing initiatives;
- when you respond to our marketing representatives and agents and other service providers;
- when you send an employment application, provide documents or information (such as your resume) in connection with any appointment as an officer, director, representative or to any other position, or when you attend interviews with us;
- when you interact with us via our websites and platforms, or use services on our websites and platforms;
- where allowed under applicable law, when we seek information about you regarding your relationship with us and receive your Personal Data (for example, from business partners, public agencies, your ex-employers and the relevant third parties);
- when you respond to a request from us for additional Personal Data;
- from third party sources to which you have given your consent (such as our ecosystem partners) or if collection of your Personal Data is necessary to comply with applicable data protection laws;
- from your mobile device (e.g. location information); and
- when you send your Personal Data to us for any other reason.
- When you browse or use our website and platforms, we may collect information about you. Please see the section below on “Use of Cookies and Related Technologies” for more information.
- If you provide us with any Personal Data of a third party (e.g. information on your customers, spouse, children, parents, and/or employees), you represent that, by sending such information to us, you have obtained the consent of such third party for you to provide us with their Personal Data for the respective purposes.
- You should ensure that all Personal Data sent to us is complete, accurate, true and correct. Failure on your part to do so may prevent us from providing you with products and services you have asked for.
-
We will only collect your Personal Data in a lawful manner and when we have a valid reason to do so. Generally, we collect your Personal Data in the following ways:
-
Purposes for the Collection, Use and Disclosure of Your Personal Data
- It is important that we are transparent in how your Personal Data is used, so that you can trust us with it. Generally, Alphalytix collects, uses and discloses your Personal Data for the following purposes:
- responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
- establishing and verifying your identity;
- managing our administrative and business operations;
- facilitating corporate restructuring processes and business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
- matching any Personal Data which relates to you for any of the purposes listed in this policy;
- requesting feedback or participation in surveys, conducting market research or analysis for statistical, profiling, or other similar purposes. These other purposes include the development, design and improvement of our products and services, and the understanding of customer behavior, preferences, and market trends;
- preventing, detecting, and investigating crime (including fraud and money-laundering or terrorist financing);
- analysing and managing commercial risks;
- managing the safety and security of our premises and services (including carrying out CCTV surveillance, implementing safe distancing measures and conducting security clearances);
- project management;
- providing media announcements and responses;
- marketing offers and promotions in relation to products and services (including co-branded products and services and organising promotional events);
- in connection with any claims, actions or proceedings (including drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and in protecting and enforcing our contractual and legal rights and obligations;
- managing and preparing internal and external reporting;
- training our employees to provide better products and services to you;
- to determine service levels;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and due diligence), internal policies, assisting law enforcement or investigations by relevant authorities, and complying with listing and other requirements or directions of the Singapore Exchange Limited and/or any other relevant securities exchange;
- for contact tracing, deployment of safe management measures and other response measures that are necessary in the event of an emergency, such as during the COVID-19 outbreak; and
- any other purpose relating to or reasonably necessary for any of the above.
- These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).
- In addition, Alphalytix collects, uses and discloses your Personal Data for the following additional purposes which vary depending on the nature of our relationship with you.
-
Prospective Customers
- evaluating your financial and analytics needs and providing recommendations to you;
- assessing and processing any applications or requests made by you for products and services offered by Alphalytix; and
- any other purpose relating to or reasonably necessary for any of the above.
-
Employees, Business Partners, Sole Proprietors, Investors, Corporate Shareholders, Guardians, Directors, Nominee Directors, Chargors, Sureties or Guarantors, Agents or Representatives of an Organization that is a Fund Manager Customer or has a corporate relationship with Alphalytix
- opening or continuation of accounts, and establishing or providing analytical services;
- facilitating the daily operation of services;
- facilitating the continuation or termination of the business relationship (including the closing of accounts);
- managing investment data and analytics ;
- networking to maintain customer relationship;
- providing client servicing (including providing customer satisfaction);
- facilitating and carrying out due diligence checks;
- administering fund services (including the maintenance, management and operation of the services, and communication with investors);
- processing commissions and remuneration for sales representatives;
- administering and facilitating any analysis or other services and the execution of such transactions on a trading system or platform; and
- any other purpose relating to or reasonably necessary for any of the above.
-
Employees, Agents or Owners of a Referrer or other similar intermediaries
- marketing and leads management;
- processing commissions and remuneration; and
- any other purpose relating to or reasonably necessary for any of the above.
-
Employees, officers or owners of an external service provider or vendor outsourced or prospected by Alphalytix, or an independent contractor
- managing project tenders or the supply of goods and services;
- processing and payment of vendor invoices; and
- any other purpose relating to or reasonably necessary for any of the above.
-
Persons who apply for positions with us
This paragraph applies to candidates who send in applications for employment or representative positions, and independent contractors, interns and trainees who apply for (or are put forward for) positions with us.
- conducting interviews;
- processing your application which includes pre-recruitment or pre-engagement checks involving your qualifications and facilitating interviews;
- providing or obtaining employee references and for background screening;
- assessing and evaluating your suitability for employment or engagement in any current or prospective position;
- processing staff referrals;
- verifying your identity and the accuracy of your personal details and other information provided; and
- any other purposes relating to any of the above.
-
Employees, independent contractors, temporary staff, interns and trainees of Alphalytix
This paragraph applies to all persons engaged in a contract of service or contract for service with us (such as independent contractors), and interns and trainees attached to us.
The purposes listed below apply to you during the course of your relationship with us and may continue to apply even when your relationship with us has been terminated or altered in any way.
- performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;
- reviewing salaries, remuneration and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring awards;
- assessing and evaluating your suitability for employment or appointment, or continued employment or employment in any position in Alphalytix, and conducting appraisals and evaluations;
- administrative, human resources related and support processes relating to your employment or relationship with us, including managing and terminating your employment or appointment, staff benefits (including travel, manpower, business continuity and logistical management or support), processing expense claims, administering insurance applications, leave administration, training, learning and talent development, resolving grievances, and planning and organising corporate events;
- investigating any acts or defaults (or suspected acts or defaults), or contraventions of our internal or external compliance obligations;
- providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;
- ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;
- to understand risks in our workplaces, and ensure the safety, health and welfare of persons in our workplaces;
- managing corporate social responsibility projects;
- conducting analytics and research for human resource planning and management, and for us to review, and develop work-related practices, environment and productivity;
- ensuring that Alphalytix's operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed within Alphalytix, your activities on such computer software and hardware, your internet access, your work emails and personal digital and storage devices);
- performing obligations in connection with the provision of our goods or services to our clients;
- contact tracing, operationalising safe management measures and other necessary measures in the event of an emergency, such as during the COVID-19 outbreak;
- administering cessation processes; and
- any other purposes relating to any of the above.
-
Users of Digital Services
- to provide, personalise, facilitate and improve your use of our Digital Services. When you use our Digital Services, you may also be subject to the Data Protection Policies of our various ecosystem partners. Please read through those Data Protection Policies carefully;
- to authenticate and verify your identity;
- to market Alphalytix and our ecosystem partners’ services, events and products; and
- any other purpose relating to or reasonably necessary for any of the above.
-
- It is important that we are transparent in how your Personal Data is used, so that you can trust us with it. Generally, Alphalytix collects, uses and discloses your Personal Data for the following purposes:
-
Contacting Us
- To contact us regarding your Personal Data or on any aspect of our Data Protection Policy (including our reliance on legitimate interests), withdrawing your consent to any use of your Personal Data, or to obtain access and make corrections to your Personal Data records, please contact us at: info@Alphalytix.io or at alphalytix.io
- You may withdraw your consent for the collection, use and disclosure of your Personal Data. If you withdraw your consent, depending on the nature of your request, Alphalytix may not be able to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may result in the termination of any agreements you have with Alphalytix, and your being in breach of your contractual obligations or undertakings. In such an event, we reserve our legal rights and remedies.
- Please note that if a third party provided your Personal Data to us, you should contact such third party directly to make any queries, feedback, and access and correction requests to us on your behalf.
-
Governing Law
- This Data Protection Policy and your use of this website shall be governed by the laws of Singapore.