This Policy sets out the manner in which Wealthy Genius (“WG“) collects, uses, manages and protects Personal Data (as defined below) in accordance with the provisions of the Personal Data Protection Act 2012 (“PDPA”).
This Policy applies to all persons who are Individuals (as defined below) and who provide WG with Personal Data or whose Personal Data is collected, used and/or disclosed by WG in connection with and/or for the purposes of its business and operations.
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to WG, nor does it affect any rights that WG may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, WG will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide it with the Personal Data or as required for the purposes of providing services to the Individual or by law.
WG may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at www.wealthygenius.com (“website”), and appropriate notifications of any material revisions will be published on the website and may be issued separately to relevant persons such as may be determined by WG. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with WG after any amendments have been introduced and published on the website, Individuals shall be deemed to have accepted the Policy as amended.
For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with WG (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
For purposes of this Policy:
“Individual” means a natural person, whether living or deceased and “Individuals” shall be construed accordingly;
“CCTV” means Closed-circuit Television;
Personal Data means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to WG;
“Personnel” means any Individual engaged under a contract of service with WG, a contract for service with WG, permanent or temporary employees as well as trainees and interns engaged by WG from time to time; and
“Potential Personnel” means any Individual who has submitted an application to be engaged by WG as Personnel.
2. Personal Data collected by WG
WG will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with WG, Personal Data which WG collects, uses or discloses concerning an Individual may variously include but is not limited to the following:
- the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
- the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
- other information which the Individual may provide to WG, from time to time, in the course of such Individual’s interaction with WG.
3. How WG collects Personal Data
Generally, WG may collect Personal Data from an Individual in one or more of the
following ways or circumstances:
- when the Individual interacts with WG’s staff via telephone calls, emails, other correspondence and/or face-to-face meetings;
- when the Individual specifically requests that WG contact him or her or requests to be included in an email or any mailing list maintained by WG;
- when the Individual responds to any request by WG for the provision of Personal Data;
- when WG receives references or referrals from its business partners or other third parties;
- when the Individual attends or participates in any event organized by WG;
- when the Individual submits his or her Personal Data to WG pursuant to a job application;
- when the Individual subscribes to WG’s publication(s) where in print or electronically; and/or
- when the Individual submits his or her Personal Data to WG for any other reason related to WG’s ordinary course of business operations.
4. Purposes of collection, use and disclosure of Personal Data
Generally, WG collects, uses and/or discloses Personal Data from Individuals for one or more of the following purposes: A. Provision of services
- administering and managing the Individual’s relationship with WG;
- providing the Individual with information about WG’s services and/or the services of any external vendor that is providing services or products in partnership or collaboration with WG;
- responding to the Individual’s complaints, queries and/or requests;
- facilitating and/or organizing events;
- informing the Individual of changes and/or updates to WG’s policies, terms and conditions and/or other administrative information;
B. Security measures
- preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned;
C. General business operations of WG
- staff training, quality assurance and performance evaluation;
- legal purposes (including but not limited to the Individual obtaining legal advice and dispute resolution);
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines which are binding on WG (including but not limited to responding to regulatory complaints, disclosure to regulatory bodies and conducting audit checks, due diligence and investigations);
D. Managing Personnel
- administering, managing and/or terminating WG’s relationship with Personnel;
- evaluating the performance of Personnel;
- undertaking staff training and quality assurance activities;
- providing Personnel with services, facilities and/or other benefits being offered or made available by WG to such Personnel as well as information about such services, facilities and benefits;
E. Managing Potential Personnel
- administering and managing WG’s relationship with Potential Personnel;
- evaluating the suitability and eligibility of Potential Personnel to be engaged by WG;
- where WG circulates WG’s publications or marketing information to an Individual or to any person which may be disseminated to an individual relating to services offered by WG (whether by WG or WG’s business partners) which WG thinks is or may be of benefit or interest to him/her via postal mail, electronic transmission to his or her or any email address(es), and/or voice call or phone call and/or fax to his or her or any telephone number(s);
- for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organized, hosted or participated by WG;
- for transfer to third party data intermediaries to facilitate any of the aforesaid purposes;
- for any purposes reasonably related to any of the above purposes; and
- for any other purposes in relation to which WG has specifically obtained the Individual’s consent.
Unless otherwise authorized under the PDPA or any other applicable law, WG will not collect, use or disclose an Individual’s Personal Data without his or her consent.
WG will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
- via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to WG;
- via notifications on WG’s websites;
- in the course of verbal communications;
Where feasible, WG will inform the Individual of purposes that are intrinsic to the relationship between WG or to the provision of services to such Individual, as well as purposes that are optional.
In so far as any purpose(s) are intrinsic to the relationship or provision of services, WG reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to WG’s collection, use or disclosure of his or her Personal Data for such purpose.
d. voluntarily provide their Personal Data to WG for the specified purposes; e. use or access WG’s website(s) or computer network;
g. attend or participate in events or courses organized by WG.
An Individual who provides WG with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, represents to WG that he/she has obtained the consent of the relevant third party to WG collecting, using or disclosing such Personal Data for the relevant purpose.
In so far as WG collects Personal Data of an Individual from any third party(ies), WG will take reasonable steps to inform the relevant third party(ies) of WG’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.
2. Disclosure of Personal Data
In carrying out one or more of the above Purposes, WG may need to disclose Individuals’ Personal Data to the following third parties for one or more of the above Purposes:
- to SU’s third party service providers or agents;
- any external vendor that is providing services or products in partnership or collaboration with SU;
f. enter SU’s premises OR WG partner premises or using any of the facilities
c. to SU’s auditors and professional advisors;
- any person to whom disclosure is permitted or required by any statutory provision or law;
- any permitted assigns;and/or
- to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.
3. Withdrawal of Consent
Any Individual who wishes to withdraw his or her consent to any use or disclosure of his or her Personal Data by WG as set out in this Policy may do so by contacting SU’s Data Protection Officer contact us.
Depending on the extent to which an Individual withdraws consent to the use or disclosure of his or her Personal Data by SU, such withdrawal of consent may result in SU’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between WG and the Individual. SU’s legal rights and remedies are expressly reserved in such event.
4. Verification of Personal Data & Notification of Changes
Where feasible, WG will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to WG is complete and accurate. Information voluntarily provided by an Individual to WG shall prima facie be deemed complete and accurate.
WG will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless responsible for notifying SU, from time to time, of any applicable changes to such Personal Data.
WG shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his or her Personal Data submitted to WG is complete and accurate or who fails to notify WG of any relevant changes to such Personal Data.
5. Protection of Personal Data
WG shall make reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
If WG transfers Personal Data, WG will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy.
WG will ensure that third parties who receive Personal Data from WG protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by SU, by incorporating appropriate contractual terms in its written agreements with these third parties.
WG is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on this website.
6. Contacting SU-Access and Correction of Personal Data Any Individual who:
- has questions or feedback relating to this Policy;
- would like to obtain access to his or her Personal Data held by SU;
- would like to obtain information about the ways in which his or her Personal Data held by WG has been or may have been used or disclosed by WG in the year preceding the request; and/or
- would like to up date or make corrections to his or her Personal Data held by SU,
should contact SU’s Data Protection Officer by contacting us.
Individuals should note that WG is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.
The PDPA allows and WG reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.