Privacy Policy

Privacy Policy

Privacy & personal data protection policy

1. About our policy 

1.1 We at Fiera Capital (Asia) take our responsibilities to our clients and investors seriously. We also recognize the importance of your privacy and the personal data that you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal information and data.

1.2 Our Privacy & Personal Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal information and data that you have previously provided to us, as well as to assist you in making an informed decision before providing us with any of your personal information and/or data in the future.

1.3 If you, at any time, wish to: 

  • send us any queries about this Policy or on how we may manage, protect and/or process your personal information and data;
  • withdraw your consent for us to collect, use and/or disclose your personal information or data; and/or 
  • exercise your statutory rights under applicable law in relation to access or correction of your personal information or data in our control or possession, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:
    • E-mail: DPO@FIERACAPITAL.COM – Attention: ‘Data Protection Officer’
    • Office address: c/o Fiera Capital (Asia) Singapore Pte. Ltd., Suite 38-03, Suntec Tower Four, 6 Temasek Boulevard, Singapore 038986 – Attention: ‘Data Protection Officer’

2. What our policy covers

2.1 ‘Personal Data’ is data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access. Common examples of personal data could include your name, identification numbers, contact information, birth date, account and other financial information, information specific to your family and personal affairs, and similar such matters. 

2.2 We will collect your personal information and data in accordance with applicable law in the jurisdictions in which we do business. We will notify you of the purposes for which your personal information and data may be collected, used, disclosed and/or processed.  We will also obtain your consent for the collection, use, disclosure and/or processing of your personal information and data for the intended purposes, unless applicable law permits us to collect and process your personal information and data without your consent. 

2.3 By responding to requests for your personal information and data and providing such information and data without objection or restriction, you will be deemed to have consented to the collection, use, disclosure and processing of such information and data in accordance with this Policy.

3. Purposes for collection, use, disclosure and processing of personal information and data 

3.1 Personal information and data which we collect from you may be obtained, used, disclosed and/or processed for various purposes depending on the circumstances for which we may/will need access to such personal information and data, including but not limited to: 

  • complying with or as required by any request or direction of any governmental authority or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to the United States Securities and Exchange Commission, the United States Commodity Futures Trading Commission, the Securities and Futures Commission of Hong Kong, the Monetary Authority of Singapore and the Cayman Islands Monetary Authority). For the avoidance of doubt, this means that we may/will disclose your personal information and data to the aforementioned parties upon their request or direction; 
  • conducting appropriate due diligence with respect to transactions in the ordinary course of business and ensuring ‘know your customer’ and applicable anti-money laundering and counterterrorist financing laws are complied with;
  • storing, hosting, and backing up (whether for disaster recovery or otherwise) your personal information and data, whether within or outside the United States, Hong Kong, Singapore, the Cayman Islands, or any other location where we maintain office locations or conduct business; 
  • sending you information about any administrative changes, updates and/or amendments to our policies, terms and conditions; 
  • otherwise communicating with you in the ordinary course of business; 
  • responding to complaints, queries and/or requests; 
  • as part of recordkeeping and retention; and/or
  • any other purposes which we notify you of at the time of obtaining your consent (collectively, the “Purposes”). 

As the Purposes for which we may/will collect, use, disclose or process your personal information and data depend on the circumstances at hand, such Purposes may not be listed specifically above. However, we will notify you of such other Purposes at the time of obtaining your consent, unless collecting, using, disclosing and/or processing of your personal information and data without your consent is permitted under applicable law.

3.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal information and data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties regardless of where sited for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties will be processing your personal information and data, whether on our behalf or otherwise, for one or more of the above-stated Purposes.

4. Disclosure of personal information and data to third parties 

4.1 We respect the confidentiality of the personal information and data that you provide to us. 

4.2 We will not generally disclose your personal information and data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal information and data to third parties without first obtaining your consent in certain situations to the extent permissible under applicable law and as otherwise specified in this Policy. 

4.3 Where we disclose your personal information and data to third parties, whether with or without your consent, we will employ our best efforts to require such third parties to properly protect such personal information and data.

5. Administration and management of personal information and data

5.1 We will undertake reasonable efforts to ensure that your personal information and data is accurate and complete if your personal information and data is likely to be used by us to make a decision that affects you or is disclosed to another organisation. However, this means that you must also update us of any changes in your personal information and data that you had initially provided to us. We cannot be responsible for relying on inaccurate or incomplete personal information or data when you do not notify us of such changes. 

5.2 We have put in place reasonable security arrangements to ensure that your personal information and data is adequately protected and secured.  This includes appropriate security arrangements to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal information and data. However, we cannot assume responsibility for any unauthorized use of your personal information and data by third parties which are wholly attributable to factors beyond our control.

5.3 We have also put in place measures such that your personal information and data in our possession and control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the Purposes for which that personal information and data was collected are no longer being served by the retention of such information and data, and (ii) retention is no longer necessary for any other legal or business purposes. 

5.4 Where your personal information and data is to be transferred out of the country in which it was originally collected, we will comply with applicable law in doing so. This may include us obtaining your consent, unless an exception under applicable law applies, as well as taking appropriate steps to ascertain that the foreign recipient organisation of the personal information and data is bound by legally enforceable obligations to protect such personal information and data under a standard that is at least as comparable to the originating country. This may also include us entering into an appropriate contract with the foreign recipient organization addressing the personal information and data transfer or permitting such transfer extra contractually if applicable law allows us to do so.

6. Your rights with respect to your personal information and data

6.1 You have the right to access and correct any inaccurate personal information or data we possess about you, including the right to have incomplete data completed by furnishing us with additional or supplementary information;

6.2 You have the right to be forgotten when your personal information and data is no longer necessary for the Purposes and there is no other lawful premise upon which your personal information and data should continue to be retained or processed;

6.3 You have the right to restrict further use and processing of your personal information and data in circumstances where the accuracy of the personal information and data is in doubt, use and processing no longer serves any of the Purposes, such further use and processing breaches applicable law, and other legitimate reasons;

6.4 You have the right to receive your personal information and data in a structured, commonly used, and machine readable format in order to transmit or further process such information and data, whether through another organization or otherwise, at your discretion;

6.5 You have the right to object to the use and processing of your personal information and data for specific Purposes and withdraw any consent previously provided to us for such use and processing; and

6.6 You have the right to contest the use of your personal information and data for decision-making based on automated processing unless otherwise necessary to carry out the Purposes.

7. Complaint process 

7.1 If you have any complaint or grievance about how we are handling your personal information or data or complying with applicable privacy and data protection laws, we welcome you to contact us with your complaint or grievance.

7.2 Please contact us through one of the methods outlined in paragraph 1.3 above with your complaint or grievance.  We will endeavor to respond to any complaint or grievance that you may have speedily and fairly. 

7.3 You also have the right to lodge your complaint or grievance with applicable government authorities charged with supervising compliance with personal privacy and data protection laws.

8 Updates to our privacy & personal data protection policy 

8.1 As part of our efforts to ensure that we properly manage, protect and process your personal information and data, we will be reviewing our policies, procedures and processes from time to time. 

8.2 We reserve the right to amend the terms of our Privacy & Personal Data Protection Policy in our absolute discretion.