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On 2 July 2014, the data protection provisions of the Personal Data Protection Act, 2012 (“PDPA”) take effect. We take this opportunity to share with you the enclosed Personal Data Protection Policy which outlines how iFS manages your personal data including the purposes for which your personal data may have been or may be collected, used and/or disclosed. Our Commitment We, International Financial Services (S) Pte Ltd (Company Registration No. 200302762C), believe in protecting your privacy. We ask that you read this Personal Data Protection Policy carefully as it contains important information about what to expect when we collect personal data about you and how we will use your personal data. (1) Types Of Personal Data Generally, we collect personal data that is linked to an individual. For example, an individual’s name, address, phone number and email address. This is not an exhaustive list and we may collect other types of personal data from you. Apart from personal data, we may collect other types of information which is not linked to an individual and which is anonymous. For example, the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our customer services. (2) Purpose for Collection, Processing And Disclosure Of Personal Data Collection Generally, personal data is collected for the following purposes: - providing a service and / or a product to you; and - legal compliance on our part under applicable laws. Processing and disclosure We may process and disclose personal data with and to group companies or business partners or third party service providers, for the purposes stated above. In addition, there may be circumstances under applicable laws where we are permitted to collect, process and disclose personal data without your consent. (3) Transfer Of Personal Data Overseas To the extent that we may need to transfer personal data outside of Singapore, whether to our group companies or business partners or third party service providers or simply to data storage facilities, we shall do so in accordance with the Personal Data Protection Act, 2012 (“PDPA”) to ensure that we provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA. (4) Consent Generally, when we request for personal data in the course of providing you a service and / or product and you provide use with such personal data, there is implied consent that you agree to provide us with personal data in order for us to provide you with the requested service and /or product. In some circumstances and as required by applicable laws, we will seek your express consent when collecting your personal data. For example, where there are new purposes for the use of your personal data, we will seek your fresh consent. In addition, you are able to withdraw your consent at any time by contacting us (see Section 14). Please also read Section 7 as this may terminate your relationship with IFS. (5) Situations Not Requiring Consent We will not sell, rent or otherwise disclose your personal data to any third party, without your consent except in the following circumstances: - we may share non-personal, non-individual information in aggregate form with third parties for business purposes, for example with advertisers on our website or we may tell our business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions; and / or - as permitted under the laws of Singapore. (6) Access and Correction You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us (see Section 14). We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to process your request. For a request to correct personal data, once we have sufficient information from you to process the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. In exceptional circumstances, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws. (7) Withdraw Consent You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control. We will process your request within 30 days from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request. (8) Retention Personal data will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for legal or business purposes. (9) Accuracy In order to ensure that your personal data is current, complete and accurate, please update us by contacting us (see Section 14). (10) Security Safeguards We have put in place the following security procedures and technical and organizational measures to safeguard your personal data: provide details of security measures in relation to the personal data processed, e.g. firewalls, browser certification technology, encryption, limited access, use of passwords etc. as appropriate. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet. (11) Updates to The Personal Data Protection Policy As part of our efforts to ensure that we properly manage, protect and process personal data provided to is, we will be reviewing our policies, procedures and processes from time to time. We reserve the right to amend the terms of our Personal Data Protection Policy at our absolute discretion. Any amended Personal Data Protection Policy will be posted on our website www.interfs.com. Such amendments to our Personal Data Protection Policy shall apply from the time that we post the same on our website. You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. Your continued use of our website will be taken as acceptance of the updated Personal Data Protection Policy, but we will seek your fresh consent before we collect more personal data from you or we wish to use or disclose your personal data for new purposes. (12) Prevailing Terms If you have agreed to our Terms of Business or Account Application Form, as the case may be, in the event of inconsistency between such General Terms & Conditions or Account Application Form and this Personal Data Protection Policy, such Terms of Business or Account Application Form shall prevail. (13) Governing Law Note that as we are a Singapore registered company, this Personal Data Protection Policy has been drafted solely in accordance with the laws of Singapore. We do not represent or warrant that this Personal Data Protection Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Personal Data Protection Policy as such. (14)Feedback Process If you any feedbacks or questions regarding how we are handling the personal data you have provided, please contact our Data Protection Officer through one of the following modes: Email: dataprotection@interfs.com Mailing Address: 6 Shenton Way, OUE Downtown 2, #21-11/12, Singapore 068809 (please attention it to the Data Protection Officer) Note: Any product we recommend with an investment component has a value which may go down in line with the performance of the underlying markets into which your funds are invested. Further information and warnings about the risks of investing will be provided to you at the time of our recommendation.
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Sukladno Zakonu o zaštiti osobnih podataka ( Narodne novine broj 103/03, 118/06, 41/08, 130/11 i 106/12 ) društvo Usluga Poreč d.o.o. imenovalo je službenika za zaštitu osobnih podataka. Službenik za zaštitu osobnih podataka vodi brigu o zakonitosti obrade osobnih podataka i ostvarivanju prava na zaštitu osobnih podataka na način da: - vodi brigu o zakonitosti obrade osobnih podataka u smislu poštivanja odredbi Zakona o zaštiti osobnih podataka i ostalih propisa koji uređuju pitanja obrade osobnih podataka; - upozorava voditelja zbirke osobnih podataka na nužnost primjene propisa o zaštiti osobnih podataka u slučajevima planiranja i radnji koje mogu imati utjecaj na pitanje privatnosti i zaštitu osobnih podataka; - upoznaje sve osobe zaposlene u obradi osobnih podataka s njihovim zakonskim obvezama u svrhu zaštite osobnih podataka; - brine o izvrsenju obveza iz clanka 14. i Zakona o zaštiti osobnih podataka; - omogućava ostvarivanje prava ispitanika iz clanka i 20. Zakona o zaštiti osobnih podataka; - surađuje s Agencijom za zastitu osobnih podataka u vezi s provedbom nadzora nad obradom osobnih podataka. Službenik za zaštitu osobnih podataka dužan je čuvati povjerljivost svih informacija i podataka koje sazna u obavljanju svojih dužnosti. Ova obveza traje i nakon prestanka obavljanja dužnosti službenika za zaštitu osobnih podatka. Kontakt podaci službenika za zaštitu osobnih podataka : Usluga Poreč d.o.o., Mlinska 1., Poreč E-mail: tijana.belac @usluga.hr