Privacy Policy

Custody Plus Pte. Ltd. (referred to as the “Custody Plus”, “we”, “us” or “our”) are committed to protecting our stakeholders’ and customers’ personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws.

“Personal data” refers to data 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.

This Privacy Policy applies to websites owned and operated by Custody Plus and as well as all services provided by Custody Plus.

We may from time to time update the Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements or as we deem appropriate. If you continue to access and/or use of our website, our mobile application, our products and/or our services and your submission of any contact details to us through any channel whatsoever, this will constitute your agreement to the Privacy Policy and any revisions thereto.

Data collected from you

Data collected, used, stored and transferred including but not limited to the following:

Applications Form which includes your name, passport or other identification number, mailing address, telephone number, email address, images of your passport or identification document or utility bill.
Financial Statement, which includes information about your financial position, status and history, and banking account details.
Usage data which includes information on your usage of our website, products and/or services, including cookies, IP address, and account details.
Transaction activity which includes transactions to and from your accounts with us.
Technical data which includes details about the devices and technology you use including internet protocol address, your login data, and other technology to access our website, mobile application, products and/or services.

How we obtained data from you

Personal data may be collected from you in various ways, including but not limited to the following:

Website access and usage, mobile application, products and/or services (or part thereof).
Application forms submitted to our website, mobile application and/or any of our products or services.
Interaction with our customer service officers, marketing representatives and agents.
Upon your request that we contact you or include you in an email or other mailing list.
Upon your respond to our promotions and other initiatives.
Upon signing an agreement with us.
As references from business partners and third parties.

Purposes of Collection, Use and Disclosure of Personal Data

Generally, Custody Plus collects, uses and/or discloses personal data, and you consent to such collection, use and/or disclosure by the Custody Plus, for the following purposes:

To provide products and services for the intended purpose of commencing an account with us.
To comply with applicable regulations and law in relation to anti-money laundering, terrorism and tax reporting obligations.
To monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation, and prosecution, and to enforce or defend to report tax-related information to tax authorities in comply with a legal obligation.
To monitor and record calls for quality control, business analysis, training, and related purposes to improve our service delivery.
To update and maintain records and for invoicing.
To conduct statistical analysis and market research.
To provide you with information about products and services which may be of interest to you or your representing institution, and which processing is necessary to perform a relevant contract with you, comply with legal obligations, and/or which is necessary for Custody Plus’s legitimate interests indicated above and/or where the processing is in the public interest; and to retain AML and other records of individuals to assist with the subsequent screening of them or the provision of other services by Custody Plus, to pursue Custody Plus’s and (in some circumstances) its clients’ legitimate interests.

We may share personal information that we collected about our customers, prospects, or formal customers with our related corporations, services providers, agents and other third parties for the purposes set above and any other reasonable ancillary purposes, for legal reasons, or where permitted under PDPA and other applicable laws, such as in response to law enforcement agencies.

In case we transfer personal data to countries outside Singapore, it will be done in accordance with the relevant provisions under Singapore laws and regulations. We will also comply with the relevant laws and regulations in relation to transfers of personal data outside countries where the personal data is collected.

Third Party Data

You warrant that any personal data of other individuals that you disclose to us, you have received consent from such individuals allowing us to collect, use and/or disclose such personal data for:

The relevant purpose for which you made the disclosure or as was notified to you at the relevant time; and
The other purposes as described above in this Privacy Policy.

Marketing Communications

It is in our legitimate interests to process personal data to selectively contact you and/or send you information about our products, services, activities and/or events that may be relevant to you (“Marketing Communications”).

To the extent that our processing of your personal data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by us. Please email compliance@custodyplus.sg if you wish to exercise this right.

You may opt-out of receiving Marketing Communications by contacting us at clientservices@custodyplus.sg.

Cookies

We use cookies to support the website operation. Cookies are small amounts of data that website exchanges with a web browser or application on a visitor’s computer or mobile device. Cookies help us to collect information about visitors to Custody Plus websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Custody Plus cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on a Custody Plus website, or if you delete cookies, you may experience some inconvenience in your use of Custody Plus websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.

Security measures

All personal data is kept confidential. The company ensure that all reasonable measures are taken to protect any unauthorised or accidental access, process, or loss, by implementing appropriate physical, electronic and supervisory controls.

Control of your personal information

If you have any questions or concerns about this Privacy Policy, or the information we maintain, or instruct us to remove your personal information, you may email us at compliance@custodyplus.sg. It is important to understand that we use your personal data to provide you with the products and services for your usage. We comply with various regulatory requirements including the requirements for customer due diligence. Withdrawal of consent for the Custody Plus to collect, use or disclose personal data may result in halting any of these activities. Any missing key personal data, including but not limited to your name, address, email and/or telephone contacts, personal identification numbers or banking information, may cause the company to discontinue providing the relevant products and services to you.

GDPR Data Protection Rights

To ensure that you are fully aware of all your data protection rights, every user is entitled to the following:

Rights to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.
Rights to rectification – You have the right to request that we correct any information if you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
Rights to erasure – You have the right to request that we erase your personal data, under certain conditions.
Rights to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
Rights to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
Rights to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you wish to exercise these rights, or have any questions about these rights, you may email us at compliance@custodyplus.sg or write to us at:

Custody Plus Pte. Ltd.
223 Mountbatten Road #03-10
Singapore 398008

Contacting us

If you have any questions about this Privacy Policy, or our handling of your personal data, please email our Data Protection Officer at compliance@custodyplus.sg.