INTRODUCTION

Raffles Family Office Limited (‘we’, ‘us’, ‘our’ or ‘RFO) complies with applicable privacy and data protection laws when dealing with personal data. Personal data means data about an individual who can be identified from that data. This policy sets out how RFO will collect, use, disclose and protect personal data that you provide to us when you access and use this mobile application (APP), website and any services offered by us through this website or mobile application. This policy does not limit or exclude any of your rights under applicable laws.

CHANGES TO THIS POLICY

We may change this policy by uploading a revised policy onto this page. The change will apply from the date that we upload the revised policy. This policy was last updated on 3 May 2021

WHO DO WE COLLECT YOUR PERSONAL DATA FROM

We collect personal data about you from:

• you, when you provide that personal data to us, including via this mobile application, website and any related services, through any registration process, through any contact with us or when you buy or use our service; and/or
• third parties where you have authorised us, or where information is publicly available.

WHAT PERSONAL DATA DO WE COLLECT

Whenever you access or make use of this mobile application, website or any of our services, we may collect the following types of personal data from you:

(a) personal data that you provide directly to us, including but not limited to:

• when you create an RFO Company and Member account, your name, address, phone number and email address;
• when you make a booking, your email address, name, phone number and/or any other personal data required by our third-party suppliers;
• if you ask to receive information about us or our services, your email address, name, phone number and/or any other personal data;
• information about your transactions with us and our business partners;
• information contained in your correspondence with us, for example when you send us an email; and
• any other information required to facilitate our providing services to you;

(b) personal data collected during the course of your use of this website and/or our services, including but not limited to the usage data such as the IP address of your computer and the URLs of the website pages you visit;

(c) personal data collected from third parties where you have authorised this or the personal data is publicly available;

(d) information collected through our use of cookies or similar technologies; and

(e) any other personal data we deem necessary to provide, maintain, deal with (in any kind) any services for you.

HOW WE USE YOUR PERSONAL DATA

(a) We use the personal data provided directly by you:

• to provide the mobile application and our services to you;
• to verify your identity;
• to market our services and products to you, including electronic communications (e.g. text messages or emails) that you may opt in to receive. You can discontinue receiving our promotional emails or service-related communications by following the unsubscribe instructions included in those communications or informing us by email at email address;
• to improve our mobile application and services that we provide to you;
• to respond to communications from you;
• to extend any invitations to you for any events we may have;
• to combine any information that we collect from you or otherwise obtain with information we obtain from our trusted partners; and
• to deal with (if any) any complaint, investigation, enquiry, regulatory/legal proceedings, whether triggered from you or any other third party, in relation to any services will be/is being/had been provided by RFO to you.

(b) We use information generated by your access or use of our mobile application, website or our services:

• to monitor the performance of our mobile application or our services and ensure that these perform;
• in the best manner possible; and
• for security and system integrity purposes

We may also combine information we collected (aggregate) and removed personally identifiable (anonymous) information to conduct research and statistical analysis. This privacy policy does not apply to our use of such aggregated or anonymous information.

(c) We may also use your personal data:

• to protect and/or enforce our legal rights and interests, including defending any claim;
• for any other purpose authorised by you or applicable law;
• to respond to lawful requests by public authorities, including to meet law enforcement requirements; and
• to transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

DISCLOSING YOUR PERSONAL DATA

We do not rent, sell, or share personal data about you with third parties or non-affiliated companies except to provide products or services that you have requested, when we have your authorisation or under the circumstances outlined in this privacy policy. We may disclose your personal data to:

• our related companies;
• if you make a request on our mobile application;
• any business that supports our services and products, including any person that hosts or maintains any underlying IT system;
• data centre that we use to provide this website or our services or to process payments and our trusted third-party partners; and
• Important third parties that support this mobile application, website or our services that may, from time to time, engaged by RFO;
• our professional advisers e.g. accountants, lawyers, auditors;
• any other person authorised by you; and
• any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

We may disclose research and statistical analysis on an anonymised basis derived from your personal data to third parties. We may also disclose information we hold about you if we believe that such disclosure is necessary to:

• comply with legal requirements or process;
• protect our rights or property; and
• enforce this privacy policy or any other agreement that we may have with you.

We share information about your use of this website with our trusted social media, advertising and analytics partners through the use of cookies, web beacons and similar storage technologies.

PROTECT YOUR PERSONAL DATA

We take reasonable steps to keep your personal data safe from loss, unauthorised activity, or any other kind of misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing personal data. You can play an important role in keeping your personal data secure by maintaining the confidentiality of any password used in relation to our products and services. Please do not disclose your password to third parties. Please inform us immediately if there is any unauthorised use of your account or any other breach of security.

ACCESS AND CORRECT YOUR PERSONAL DATA

Subject to certain grounds for refusal set out in the applicable law, you have the right to access your readily retrievable personal data that we hold and to request a correction to your personal data. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal data relates. In respect of a request for correction of personal data, if we believe the correction is reasonable and we are reasonably able to amend the personal data, we will make the amendment. If we do not make the amendment, we will take reasonable steps to note on the personal data that you requested the amendment. If you want to exercise either of the above rights, email us at contactus@rafflesgroup.co. It is also your responsibility to provide us with the updated personal data for your safety purposes.  Your email should provide evidence of who you are and set out the details of your request (e.g. the personal data or the correction that you are requesting).

INTERNET USE

While we take reasonable steps to maintain secure internet connections, if you provide us with personal data over the internet, the provision of that information is at your own risk. If you follow a link on our website to another site, the owner of that site will have its own privacy policy relating to your personal data. We suggest you review that website’s privacy policy before you provide personal data.

CONTACT US

If you have any questions about this privacy policy, our privacy practices, or if you would like to request access to, or amendment of, your personal data, you can contact us via email at: contactus@rafflesgroup.co.