Fisher Investments Singapore Pte. Ltd.
Privacy & Cookie Statement

1. General

This Privacy & Cookie Statement (this “Statement”) sets out how Fisher Investments Singapore Pte. Ltd. (the “Company”) uses Personal Data and complies with the Personal Data Protection Act 2012 (the “PDPA”) and the applicable privacy regulations.

In this Statement, “Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access. The Company uses Personal Data relating to the following natural people (“Individuals”):

  • prospective clients, clients, and their representatives;
  • website users;
  • business contacts working with service providers and vendors, including independent contractors;
  • individuals who agree to participate in market research;
  • employees; and
  • prospective employees.

The Company can be contacted about this Statement using the following details:

Fisher Investments Singapore Pte. Ltd.
Attn: Privacy Office
50 Raffles Place, #15-05/06
Singapore Land Tower
Singapore 048623
privacy@fisherinvestments.sg

2. Types of Personal Data

The Company collects the following types of Personal Data for the following categories of Individuals:

a. Prospective clients, clients, and their representatives:

  • The Company collects the name, address, telephone numbers, email address, and asset level category of Individuals who provide such information at the time that they request the Company’s informational materials, and at the time that they express an interest in services offered by the Company.
  • The Company may also collect the name, address and email address of Individuals provided by third party list vendors to provide offers for the Company’s informational materials. Such Personal Data may come from public sources and/or such vendors’ private databases.
  • When Individuals request that the Company provide personal advice and/or engage the Company as discretionary investment manager, the Company uses the Personal Data Individuals provide directly, including:
    • Information provided in the client profile document;
    • Information provided in the client agreement, account statements, account opening documents for the custodian, and any instruction or mandate form with respect to the Company’s discretionary investment management service; and
    • Information provided to employee representatives of the Company in writing, in-person and by telephone, including information the Company may request from time to time to assist in providing services to the Individual.
  • To provide personal advice to Individuals, the Company uses information provided by Individuals about their mental and physical health (“Client Health Data”), including in the context of conducting a proprietary assessment of an Individual’s life expectancy and any impact on the investment time horizon for the Individual’s assets.
  • The Company is required under applicable anti-money laundering laws and regulations (collectively “AML Laws”) to carry out identity verification, sanctions checks, and anti-money laundering and anti-terrorist financing screens. Accordingly, the Company uses the name, date of birth and address provided by Individuals seeking to become clients of the Company to perform a sanctions and anti-money laundering check using the services of a third party service provider, which may reveal information relating to criminal convictions or offences.

b. Website users:

  • The Company places ads on publishers’ websites or within email content, either directly through the publisher or via a third party. As a result of Individuals interacting with the advertising content, ad server companies will collect Individuals’ domain types, IP address, and clickstream data.
  • The Company’s websites use cookies and other online tracking technologies such as pixels, tags, and web beacons that collect information about Individuals’ internet browsing habits and history, inferences drawn from any personal information, etc. (collectively referred to in this Statement as “cookies”). For more information, please see Section 8.

c. Individuals who agree to participate in market research:

  • When Individuals agree to participate in market research, the Company uses information about Individuals’ marketing, investment and servicing preferences. Such information is provided directly by Individuals to the Company or to a third party service provider engaged by the Company to conduct such market research.

d. Prospective employees:

  • The Company processes the following types of Personal Data for prospective employees:
    • records of work history (including internal and external work history and references), education and qualifications (including information provided on an application or CV);
    • contact details (e.g. name, address, email address, telephone number);
    • date of birth;
    • identification numbers;
    • background check information, which may reveal information concerning criminal convictions or offences;
    • other information that the Individual provides to the Company or its affiliates (collectively, the “ Fisher Group”).
  • Personal Data is collected mainly from prospective employees themselves. In addition, the Company collects reference check information from previous employers of (or companies to which services were provided by) prospective employees. Background check information, which may reveal information concerning criminal convictions or offences, is collected from a background checking firm that collects Personal Data from both public and private sources with consent of the Individual.

e. Employees:

  • The Company collects Personal Data about employees for purposes managing the employment relationship with the Company. The type of personal information that the Company may collect and hold about its employees includes (but is not limited to) the personal information listed at paragraph 2(e) above, personal preference payment details, performance information, relevant medical information and information relating to employees’ day-to-day work.

3.Use and Disclosure of Personal Data

  • The Company uses and discloses Individuals’ Personal Data for the purposes for which it was collected, as reasonably necessary to provide services requested, and for internal business reasons. Examples of these purposes include the following:

    • To provide personal advice and discretionary investment management services, which includes using Client Health Data collected with the Individuals’ consent;
    • To offer and coordinate third party products or services that supplement the Company’s services;
    • To carry out direct marketing, including direct marketing with Individuals’ consent by opting in;
    • To optimise our marketing, including analysing and improving marketing campaigns and enabling service providers to display the Company’s advertisements on third party websites and social media platforms;
    • To conduct market research, optimise marketing, and improve the Company’s services;
    • To contact Individuals referred to the Company;
    • To calculate portfolio performance;
    • To meet the Company’s obligations under applicable law, which includes verifying a client’s identity under AML Laws;
    • To supervise employees, including monitoring the advice process and recording and monitoring certain telephone calls;
    • To suppress Individuals from being contacted;
    • To engage with service providers and vendors;
    • To recruit and hire prospective employees;
    • To keep records; and
    • To share information with regulators and law enforcement officials; and
    • To share information with courts and tribunals.
    • To strengthen the security of the Company’s facilities through video surveillance.

    The Company may combine Personal Data collected.

4. Sharing of Personal Data

  • The Company will not sell or lease Individuals’ Personal Data to third parties.

    For the purposes listed in Section 3 above, the Company may share Individuals’ Personal Data with:

    • Fisher Group companies, including Fisher Investments, the Company’s parent company in the United States, which acts as a service provider for investment management, research, trade execution and allocation, and operational support.
    • Company-authorised vendors, service providers, contractors and representatives. These organisations are as follows:
      • Custodians that hold client assets managed by the Company, as well as custodians, brokers and dealers that execute trade order instructions for clients of the Company. The custodians holding client assets will also have a direct contractual relationship with each client.
      • Service providers that carry out the sanctions and anti-money laundering checks on behalf of the Company.
      • Information technology and security providers, such as communications, internet firewall and malware detection providers.
      • Direct marketing contractors and service providers, including website host companies that collect Personal Data on behalf of the Company from Individuals interested in the Company’s informational materials, merge-purge service providers that ensure mailing lists are accurate, and mailing service providers that send mail to Individuals on behalf of the Company.
      • Providers of third party professional advice, such as lawyers and auditors.
    • Courts and tribunals.
    • Regulators (including the relevant financial regulators), tax authorities, other government agencies, and law enforcement organisations.
    • If the Company sells, transfers or merges part or all of its business, or attempts to do so, then third parties may receive Personal Data.

    If the Company sends Personal Data outside of Singapore, the Company will protect the Personal Data via contractual and other safeguards comparable to those provided in this Statement, the PDPA and applicable regulations.

5. Consent

By providing Personal Data to the Company, an Individual consents to the Company collecting, holding, using, and disclosing the Personal Data in accordance with and for the purposes specified in this Statement. Individuals may withdraw that consent at any time. Where the Company requests Personal Data and the Individual does not provide such information, the Company may not be able to provide services and may need to cancel the contract. For example, if an Individual does not consent to providing Client Health Data, the Company may not be able to provide services and may need to cancel the contract. In the case of a prospective employee, failure to provide Personal Data to the Company, in whole or in part, could make it impossible for the Company to fulfil some or all of its obligations towards the Individual, such as payment of compensation, calculation of withholdings, or consideration of an employment application.

Individuals may unsubscribe from direct email marketing via the Company’s online form here or using the details set out in Section 1 above. When doing so, Individuals should ensure that a full name and address and/or email address is provided in exactly the form in which it was originally provided to the Company to avoid any possible confusion with a different Individual. Existing clients should contact their Investment Counsellor directly when making such a request.

6. Individuals’ Rights

In accordance with the PDPA, Individuals may exercise the following rights in relation to the Personal Data that the Company holds about them:

  • Individuals have the right to access their Personal Data.
  • Individuals have the right to ask the Company to correct Personal Data about them that they think is inaccurate.

To exercise these rights or to complain about how the Company handles Personal Data, Individuals should contact the Company using the details set out in Section 1 above. In such case, Individuals should ensure that the full name and address and/or email address are provided in exactly the form in which they were originally provided to the Company to avoid any possible confusion with a different Individual. The Company will provide a response within a reasonable period of time.

7. Security

The Company is committed to ensuring that Personal Data is secure. In order to prevent unauthorised access or disclosure, the Company has put in place technical and organizational measures to safeguard and secure Personal Data collected. The Company also uses encryption when collecting or transferring sensitive information.

8. Cookies

A cookie is a small text file with an identification tag that is created and downloaded to a user’s computer (or other device) when accessing websites that use cookies. Cookies allow a website to, among other things, store and retrieve information about a user’s online activity and browsing habits. Depending on the information they contain and user behaviour, cookies may be used to identify the user.

Cookies can be categorised by who places them:

  • First-party cookies: These cookies are downloaded to a user’s computer (or other device) by the publisher of the website whose service the user is requesting.
  • Third-party cookies: These cookies are downloaded to a user’s computer (or other device) by another entity that may be seeking information obtained through cookies.

Cookies can also be categorised by their duration:

  • Session cookies: These cookies are designed to collect and store information while the user accesses a website. They are often used to store information for the duration of a visit to the website (e.g. what account user is logged into). Once a user leaves the website, the session cookie is deleted.
  • Persistent cookies: These cookies store information on the user’s computer (or other device) for the duration period set within the cookie’s file, which is determined by the entity controlling the cookie and can range from a few minutes to several years, or until the user manually deletes them.

Lastly, cookies can be categorised by the function they serve. The Company uses the following types of first- and third-party cookies:

  • Required: Required cookies are necessary to enable the basic features of this site to function. They keep track of whether or not a user has consented to have other types of cookies placed on their computer (or other device). Required cookies do not collect Personal Data. Required cookies may also include authentication cookies.
  • Statistical: Statistical cookies analyse anonymised site statistics. They enable measuring the number of visitors and analysing how users interact with the website. This information is used to improve the website and the products or services offered.
  • Marketing: Marketing cookies are used to understand user interests, provide relevant ads, and make a user’s online experience more enjoyable. They can be used to build a user profile to provide users with content more relevant to their interests. They adapt advertising and the content users see on other websites based on their website browsing habits, as well as how users interact with internet advertising.
  • Preferences: Preferences cookies allow the website to personalise website content, such as the language selected for viewing the page. These also save a user’s cookie preference settings.

The Company uses first- and third-party required, statistical, marketing and preferences cookies. The following vendors load cookies on this website:

  • Sitecore

Some browsers have a “Do Not Track” setting that allows users to send a signal to the websites they visit that the user does not wish to be tracked. The Company’s website does not respond to these signals.

The websites used by the Company for job postings and submitting applications have their own privacy and cookie policies, which are listed below:

9. How Long Data Will Be Kept

If Personal Data the Company holds is no longer needed for any purpose for which it may be used or disclosed, the Company will take steps that are reasonable in the circumstances to dispose of or anonymise such Personal Data.

10. Social Media

The Company maintains a presence on various social media platforms. The terms and conditions set by the operators of the various platforms apply to the Company and any Individuals who interact with the Company through the platforms. More information about each of the various platforms is available below including information about interest-based advertising.

11. Changes to Privacy & Cookie Statement

From time to time, the Company may update this Statement, in which case the Company will post the changes to https://fisherinvestments.com/en-sp/privacy. If the Company collects, uses, or discloses Personal Data for a new purpose, the Company may identify Individuals by posting an updated Statement and sending a notification to Individuals.