Privacy Policy Statement

Overview:
PremierGCS Limited is committed to protecting data privacy.

This Privacy Policy Statement (“Policy”) has been adopted to guide how we collect, use and disclose the personal data acquired in the course of conducting our business and fulfilling our professional responsibilities.

This Policy applies only to the specific web-pages of PGCS. Please be aware that PGCS’s website may contain links to other sites, including sites maintained by PF Group or its member firms that are governed by other privacy statements that may differ somewhat and/or contain information as required under the local law applicable to each member firm. We encourage users to review the privacy policy of each website they visited before disclosing any personal data.

Personal Data:
As a member of the PF Group, we offer a wide range of services and we collect and hold personal information that identifies clients, intermediaries, suppliers and other third parties linked to our clients. The types and amount of information we collect differs – depending on your relationship with us. We only collect the data we need in order to provide the services you have asked for, or that we need in order to fulfill our legal or regulatory obligations in relation to those services. If we need to collect additional information, we will explain why we need it.

You are not obliged to provide any of the information we ask you for, but if you choose not to we may be unable to provide you with services or respond to your enquiries.

Sharing and Transfer of Personal Data:
We share your information with other PF Group companies where it is necessary in order for us to provide you with services or to allow our management to have full oversight of our operations.

To enable PF Group to operate on a global scale, some of our business functions have been amalgamated at group level to provide centres of excellence, allowing our expert staff to provide a high quality, streamlined service. These specialist functions include Accounting Services, Compliance and Data Privacy, Finance and Administration, Portfolio Management as well as Business Development and Marketing. In addition, some specialist services that support our business are also centralized, such as Information Technology (IT) and Internal Audit.

Wherever possible, information provided for Group functions is anonymized, for example, where statistical information is shared to meet group reporting and governance requirements. There are, however, times where we cannot provide the relevant services without using some personal information. In these cases access is only granted to employees who need it in order to provide those services, and the amount of information shared is limited to the minimum that will allow them to fulfil their functions.

Disclosure:
Your personal data will generally be kept confidential and will not be disclosed to any other person without your consent. However, your data will be used and disclosed to third parties for the purposes for which they were collected. We may also have an obligation to share some of your personal information with public authorities in the relevant jurisdictions, such as tax authorities, regulatory authorities, and law enforcement agencies.

In order to comply with the People’s Republic of China (PRC) Cybersecurity Law, PRC Data Security Law and PRC Personal Information Protection Law, as well as any other data protection legislation pertaining to China, we will notify all eligible data breaches to the Cyberspace Administration of China (“CAC”), and all affected individuals as may be necessary and required.

We will never sell or lease your personal information or share it with other organizations outside PF Group for marketing purposes.

Data Security:
In the usual course of our business, we use third party organizations to support the essential delivery of our services. Under these circumstances PF Group remains responsible for the security and privacy of your information and we regularly review all third parties’ security measures to ensure they meet the same standards you expect from PF Group. All third party organizations operate under contracts that restrict their use of your personal information to providing the services we have employed them for.

These external organizations have a legal obligation to comply with privacy and data protection legislation and may also operate under a professional duty of confidentiality due to the type of service they provide. They have their own privacy policies that illustrate how they use your information. You can find out more about the organizations your data has been shared with by contacting the PF Group Data Protection Team.

When we share your information with organizations that are located in different jurisdictions, including other PF Group companies, we ensure they apply equivalent levels of protection or higher, whichever is more appropriate in ensuring that we are fully compliant with the data protection legislation in those jurisdictions. We will also comply with any other restrictions placed on us regarding cross-border transfer of your personal information, and apply appropriate and reasonable data security safeguards and security measures such as contractual confidentiality terms and agreements with the personal information recipients, while ensuring that the applicable countries or regions have equivalent data protection laws that we can comply with. By receiving our services, supplying your personal information to us and also reading this Privacy Policy, you acknowledge and agree on the above mentioned cross- border transfer of your personal information, including your sensitive personal information.

Cookies:
PGCS’s website uses cookies to enable website functions and for tracking performance. PGCS’s policy governing our use of cookies can be found at cookies page.

Collection and use of personal data:
When you visit this website, your personal data may be collected either by your voluntary submission (e.g. your email enquiry) or by technical means (e.g. identification of your IP address).

From time to time, we will send you important notices about the products or services you have asked us to provide, changes to our policies or terms and conditions, or changes to laws or regulations that could affect the services we provide. This is important information that keeps you informed about the products or services you have asked us to provide.

We may also send you emails containing newsletters and articles, information about additional products or services provided by PF Group, or invitations to events we are organising, attending or sponsoring. You can opt out of receiving these messages by contacting us here or by clicking on the unsubscribe link in those emails.

Retention of personal data:
The amount of time we keep your personal information will vary depending on your relationship with PF Group. In some circumstances, there is a legal or regulatory requirement to keep information for a specific amount of time, although this will be extended if there is ongoing legal action that overrides the normal retention period. Where there is no regulatory or legal requirement, we assess how long we reasonably need to keep your information in order to deal with ongoing queries.

When our relationship with you ends, there will be information we cannot delete immediately. Such information will be stored in our physical and/or electronic archives until we no longer have an obligation to keep them. At that point the information will be permanently deleted.

Right of access to or correction of personal data:
Subject to some exceptions, you have the right to know the following, among others:

• Whether PF Group is processing your personal information
• Request a copy of the personal information PF Group holds about you
• Have any inaccuracies corrected or and have incomplete personal data completed
• Have your personal data erased if it is no longer needed
• Ask PF Group to restrict the processing of your data
• Object to PF Group processing your data
• Ask for your data to be transferred to a new service provider
• Object to processing that is carried out in PF Group’s legitimate interests
• Not be subject to a decision based solely on automated processing if it produces legal effects or similarly affects you
• Make a complaint to a data protection supervisory authority or regulator

If you would like to exercise any of your rights please contact the PF Group Data Privacy & Protection Team.

Changes to this policy:
PGCS may update this Policy from time to time in order to bring it up to date with the latest legislative and regulatory requirements.

If you have any concerns about the way we process your personal information we would prefer that you contact us to discuss your concerns. You also have the right to make a complaint to the data protection supervisory authority in the country where the PF Group Company who collected your information is located.

If you are in China and are covered by the data protection legislation pertaining to the country and its natural persons, requests for access, correction, complaints, or other queries relating to how your personal information is processed should be addressed to us via the contact details set out under the heading “Queries, Complaints and Contact Details” above. You may also contact the CAC directly for clarifications (for more details, please refer to the following website in Mandarin: https://www.cac.gov.cn).

If you are in the European Union (EU) and the EU General Data Protection Regulation (GDPR) applies, you can contact the data protection supervisory authority in your location – their contact details can be found on their individual websites. You may also make a complaint to a local EU regulator in the jurisdiction where you are located , if you are not satisfied with how we are processing your personal information.

Do note that we host your data on an Amazon server located in Singapore, and are subject to the prevailing data privacy laws in the country.

Lastly, if you have any questions about this Privacy Policy or any other data protection issues please contact:

PF Group Data Privacy & Protection Team
1 Raffles Place
#39-01 One Raffles Place
Singapore 048616
Email: compliance@premierfiduciary.com