Data Protection Policy Avallis Investments Pte Ltd
Your privacy is important to the company and we value your rights to your own personal data and privacy. Your trust in how the company handles your personal data is important to us.

Our Data Protection Policy outlines how we collect, use, disclose and protect your personal data in accordance to the Personal Data Protection Act (“PDPA”) and we strive to protect the personal data of individuals. Please take a moment to read and understand how we collect, use and/or disclose your personal data.

What is Personal Data?
Personal data refers to any data or information about you which can be identified either,

From that data
From that data and other information to which we have or are likely to have access
Depending on your relationship with us (e.g. prospective or current client, employee or business partner), the personal data about you which we may collect, use and/or disclose include:

Your personal details such as name, passport, identification numbers, contact numbers, address, email;
Your personal details enabling us to evaluate and manage your client, employment or business relationship with us (e.g. work experience, education, date of birth, bank details);
Your personal details enabling us to analyse your situation, determine suitable strategies and execute specific
actions (e.g. family status, financial status, transaction history);

Photos and videos of you from our events or office surveillance; and
Information about your use of our services and website, including cookies and IP addresses.

Purposes for the Collection and Use of your Personal Data
The company collects and use your personal data to provide investment advisory advices, discretionary asset management and fund management services which may include the following non-exhaustive scenarios with you as applicable,

In performance of the contract and/or contractual relationship entered with you;
A legitimate interest to collect and use your personal data;
Managing risks and conforming to regulatory obligations, including but not limited to preventing, detecting and/or
investigating financial crimes including AML/CFT, fraud, corruption or bribery;

Updating you on developments in our services and special happenings such as company events;
Responding to your queries, requests and handling complaints;
Maintain records of our interactions with you, through telephone recordings, documentation (hardcopy or electronic); and
Any other purposes in relation to the purposes set out above.
If the company wishes to collect, use, retain and/or disclose your personal data for any other purposes, we will seek your consent.

Disclosure of Personal Data
All personal data held by the company will be kept confidential and protected to our best efforts. However, the company may provide and/or disclose information to parties to satisfy a purpose for which your personal data is collected,

Any officer or employee of the company and its related companies;
Any agent, representative and/or third-party service provider (and their sub-contractors if applicable) of the company;
Banks, financial institutions and their respective third-party service providers;
Government or regulatory authorities, statutory bodies, competent authorities or enforcement
Any professional advisor or consultant engaged by you or the company in carrying out the purposes laid out in this policy;
Your authorized representative and any other third-party whom you authorize the company to disclose your personal data to;
Any officer or employee of the company and its related companies;
Any agent, representative and/or third-party service provider (and their sub-contractors if applicable) of the company;
Banks, financial institutions and their respective third-party service providers;
Government or regulatory authorities, statutory bodies, competent authorities or enforcement agencies (including foreign authorities and enforcement agencies);
Any professional advisor or consultant engaged by you or the company in carrying out the purposes laid out in this policy;
Your authorized representative and any other third-party whom you authorize the company to disclose your personal data to;
When the company discloses your personal data to third-parties, the company will, to the best of its abilities, exercise reasonable due diligence that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases whereby your personal data is publicly available, where the use or disclosure of your personal data is otherwise legally mandated.

Personal Data Storage Time
The company shall safekeep and store your personal data for as long as necessary to fulfil the purposes for which the data was collected for, regulatory and/or legal obligations of the company as mandated by relevant authorities.

Queries, Access/Correction Requests and Withdrawal of Consent
Should you:

Have queries regarding the company’s data protection policies and processes;
Wish to request access to and/or make corrections to your personal data in the company’s possession; or
Wish to withdraw your consent to our collection, use or disclosure of your personal data;
Please submit a written request with any supporting documents if applicable to the company’s Data Protection Officer:

Avallis Investments Pte Ltd
16 Raffles Quay
#30-04 Hong Leong Building
Singapore 048581

The company’s Data Protection endeavours to respond to you within 30 days of the submission.

Should you choose to withdraw your consent to any or all use of your personal data, depending on the nature of your request and relevant circumstances, the company may not be in a position to continue providing any further services or maintaining further relationships. Such withdrawal may also result in the termination of any agreements or relationships you may have with us in the first place.

Complaints
If you wish to make a complaint regarding the handling and treatment of your personal data, please contact the company’s Data Protection Officer directly. The DPO shall contact you within 5 business days to provide you with an estimated timeframe for investigations and resolution of your complaint.

Should the outcome of the resolution not to be satisfactory, you may refer to the Personal Data Protection Commission (PDPC) for any further resolutions.

Contact Us
Data Protection Officer

Avallis Investments Pte Ltd
16 Raffles Quay
#30-04 Hong Leong Building
Singapore 048581

Tel: 6532 2202
Email: contact@avallis-inv.com