| 1. | ABOUT THIS POLICY | ||||||
| 1.1 | This is the Privacy & Cookies Policy (“Policy”) for Madison Pacific Group. | ||||||
| 1.2 | In this Policy, “we”, “us” or “our” refers to Madison Pacific Group, including but not limited to: | ||||||
| 1.2.1. | Madison Pacific Trust Limited; | ||||||
| 1.2.2. | Madison Pacific Pte. Limited; | ||||||
| 1.2.3. | Madison Pacific Limited; | ||||||
| 1.2.4. | Madison Pacific Corporate Services Limited; | ||||||
| 1.2.5. | MPCSL Nominees Limited; | ||||||
| 1.2.6. | Madison Pacific Agency and Services Pte. Ltd; | ||||||
| 1.2.7. | Madison Pacific Guaranty Limited; | ||||||
| 1.2.8. | Madison Pacific China Holdings Limited; | ||||||
| 1.2.9. | Madison Pacific Finance Holdings Limited; | ||||||
| 1.2.10. | Beijing Madison Consulting Co. Ltd.; and | ||||||
| 1.2.11. | Tricor MP Limited | ||||||
| Please refer to our website at http://www.madisonpac.com for the contact details of each of our entities. | |||||||
| 1.3 | We will only use your personal data where you have given us your consent or where we have other lawful basis for doing so, and in the manner set out in this Policy. | ||||||
| 1.4 | This Policy sets out the manner in which and for what purposes we collect, use, disclose and process your personal data when you access or use our website and/or services or when you otherwise provide us with your personal data, regardless of the medium through which such personal data is provided. If the stated purposes of processing are altered for any reason after we have collected your personal data, we will seek for your consent for such further processing where required by applicable data protection law. | ||||||
| 1.5 | By providing us with your personal data, you acknowledge that our collection, use, disclosure and processing of your personal data will be in accordance with this Policy, including, for the avoidance of doubt, the cross jurisdictional transfer of your data. If you object to how we will collect, use and share your personal data as set out in this Policy, please DO NOT provide any personal data to us. | ||||||
| 1.6 | This Policy supplements but does not supersede or replace any consents you have provided to us, or any other agreements or arrangements that you have with us, in respect of your personal data. | ||||||
| 1.7 | Our website may contain links to websites that are not owned or maintained by us. These links are provided only for your convenience. This Policy only applies to our website and services. When visiting and being redirected to these third party websites or engaging third party services, you should read their privacy policies. We are not liable to you in respect of any data you transfer to these third parties websites or your engagement and use of third party services. | ||||||
| 2. | AMENDMENTS TO THIS POLICY | ||||||
| 2.1 | We may amend this Policy from time to time to reflect changes in applicable laws or the way we handle personal data in a prudent manner. You are encouraged to re-visit our Policy from time to time to keep yourself updated on these changes. The updated Policy will take effect when made available through https://madisonpac.com/privacy-policy/. The updated Policy will supersede earlier versions and will apply to your personal data provided to us previously. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how or why we use your personal data, we will notify you by way of a prominent notice on our website or, if we have your email address, by email. | ||||||
| 3 | COLLECTING PERSONAL DATA | ||||||
| 3.1 | What is personal data. “Personal Data” is data that can be used to identify a natural person. Personal Data we collect and for what purpose will depend on the type of services provided to you and may include: | ||||||
| 3.1.1. | Identification information such as place and date of birth, nationality, ID card details, passport details, gender, photograph/images, country of residence; | ||||||
| 3.1.2. | Contact details such as postal address, email address and phone number; | ||||||
| 3.1.3. | Family information such as marital status, number of children, identity of spouse; | ||||||
| 3.1.4. | Tax information such as tax status, tax residency, and tax ID; | ||||||
| 3.1.5. | Financial information such as bank account information and Central Depository (“CDP”) account information; | ||||||
| 3.1.6. | Information to assess whether you are or if you may represent a politically exposed person or money laundering risk; and | ||||||
| 3.1.7. | Any other Personal Data derived from legal documentation including but not limited to bond, note and other securities related documents, loan documents, Birth Certificates, Death Certificates and Powers of Attorney. | ||||||
| 3.2 | Provision of personal data. We may collect personal data (1) that you voluntarily provide to us or (2) from third parties or (3) through your use of our digital technologies and services (please see Section 4 How We Collect Personal Data for further details). What type of personal data we collect depends on the purposes for which the personal data is collected and what you have chosen to provide. | ||||||
| Where our collection is based on consent, you can choose not to provide us with personal data. You also have the right to withdraw your consent from us to continue collecting, using, disclosing and processing your personal data, by contacting us as outlined in Section 11.1. However, if you do withdraw your consent, it may then not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you require. | |||||||
| 3.3 | Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have brought this Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Policy. | ||||||
| 3.4 | Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide is true, accurate and complete, and to inform us of any changes to your personal data. | ||||||
| 3.5 | Minors. Our website and/or services are not intended to be accessed or used by children, minors or persons who are not of legal age in the relevant jurisdiction. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us. | ||||||
| 4 | HOW WE COLLECT PERSONAL DATA | ||||||
| 4.1 | Personal data you provide. We collect personal data that is relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, such as when: | ||||||
| 4.1.1. | you provide us with your personal data for business/commercial reasons; | ||||||
| 4.1.2. | you authorise us to obtain your personal data from a third party; | ||||||
| 4.1.3. | you enter into agreements with us; | ||||||
| 4.1.4. | you provide us with information for the purposes of due diligence in order for us to meet and comply with our regulatory and legal obligations; | ||||||
| 4.1.5. | you transact with us, contact us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters; | ||||||
| 4.1.6. | you request to be included in an email or our mailing list; | ||||||
| 4.1.7. | your images are captured via CCTV cameras while you are within our premises; | ||||||
| 4.1.8. | your images are captured via photographs or videos taken by us or our representatives when you attend events organised by us; | ||||||
| 4.1.9. | when you attend events or functions organised by us; | ||||||
| 4.1.10. | we seek information about you and receive your personal data in connection with your relationship with us, for example, if you are a client of Madison Pacific Group and we require you to fill up forms and documents in order to provide you with services; and/or | ||||||
| 4.1.11. | you submit an application for employment, internship or secondment, or when you provide documents or information including your resume in connection with the aforesaid application. | ||||||
| 4.2 | Personal data provided by others. Depending on your relationship with us, we may also collect your personal data from third party sources, for example, from: | ||||||
| 4.2.1. | entities in which you (or a party connected to you) have an interest; | ||||||
| 4.2.2. | your advisors; | ||||||
| 4.2.3. | current or previous employers; | ||||||
| 4.2.4. | banks and other financial services providers; | ||||||
| 4.2.5. | our business partners such as third parties providing advertising, marketing and promotional services to us; | ||||||
| 4.2.6. | your family members or friends who provide your personal data to us on your behalf; | ||||||
| 4.2.7. | your referees, educational institutions or previous employers (if you have applied to us for a job); and/or | ||||||
| 4.2.8. | public agencies or other public sources. | ||||||
| 4.3 | Automated Data Collection Technologies. Our website may contain or we may deploy certain technologies (including those described at Section 6 below) that collect data from you, such as your Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, your time spent on our website, unique device identifiers and other diagnostic data. | ||||||
| 5. | WHAT WE DO WITH PERSONAL DATA | ||||||
| 5.1 | What we do. We collect, use, disclose and process your personal data where: | ||||||
| 5.1.1. | you have given us consent; | ||||||
| 5.1.2. | necessary to comply with our legal or regulatory obligations, e.g. responding to valid requests from public authorities; | ||||||
| 5.1.3. | necessary to support our legitimate business interests, provided that this does not override your interests or rights; and | ||||||
| 5.1.4. | necessary to perform a transaction you have entered into with us, or provide a service that you have requested or require from us. | ||||||
| 5.2 | Purposes. We collect, use, disclose and process your personal data for purposes connected or relevant to our business, or to manage your relationship with us. Such purposes would include: | ||||||
| 5.2.1. | carrying out such transactions or taking steps as may be directed by you; | ||||||
| 5.2.2. | verifying and establishing your identity; | ||||||
| 5.2.3. | if you were applying to us for employment, taking steps in connection with your recruitment and on-boarding as our employee; | ||||||
| 5.2.4. | facilitating business asset transactions; | ||||||
| 5.2.5. | providing our products and services; | ||||||
| 5.2.6. | managing the safety and security of our premises; | ||||||
| 5.2.7. | communicating with you and assisting you with your enquiries, feedback, complaints, disputes and requests; | ||||||
| 5.2.8. | resolving any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct; | ||||||
| 5.2.9. | administrative purposes, e.g. accounting, risk management and record keeping, business research, data, planning and statistical analysis, and staff training; | ||||||
| 5.2.10. | security purposes, e.g. protecting our Platforms from unauthorised access or usage and to monitor for security threats; | ||||||
| 5.2.11. | providing and maintaining our website; | ||||||
| 5.2.12. | facilitating your use of our website; | ||||||
| 5.2.13. | monitoring the usage of our website; | ||||||
| 5.2.14. | performing data analytics and related technologies on data, to enable us to deliver relevant content and information to you, and to improve our website; | ||||||
| 5.2.15. | managing and engaging third parties or data processors that provide services to us, e.g. IT services, delivery services, messaging marketing, and other professional services; | ||||||
| 5.2.16. | carrying out our legitimate business interests; | ||||||
| 5.2.17. | such purposes that may be informed to you when your personal data is collected; | ||||||
| 5.2.18. | complying with legal or regulatory obligations; and/or | ||||||
| 5.2.19. | other reasonable purposes related to the above. | ||||||
| Where personal data is used for a new purpose and where required under applicable law, we shall obtain your consent for the new purpose. | |||||||
| 5.3 | Legitimate business We may also collect, use, disclose and process your personal data for the following purposes to support our legitimate business interests, provided that this does not override your interests or rights, which include but not limited to: | ||||||
| 5.3.1. | managing our business and relationship with you, in various transactions; | ||||||
| 5.3.2. | acting as custodian and providing services to our clients; | ||||||
| 5.3.3. | acting in various trustee and agent roles across a multitude of debt related transactions | ||||||
| 5.3.4. | acting as an escrow agent to hold escrow funds or documents holding assets including cash, shares (scriptless and physical), documents and other properties; | ||||||
| 5.3.5. | provision of independent verification of meeting and voting formalities; | ||||||
| 5.3.6. | acting as a process agent to receive notices and service of documents in legal proceedings; | ||||||
| 5.3.7. | assistance of carrying out corporate restructuring plans; | ||||||
| 5.3.8. | protecting our rights and interests and those of our clients; | ||||||
| 5.3.9. | complying with legal or regulatory obligations, internal policies and procedures; | ||||||
| 5.3.10. | enforcing our terms and conditions and obligations owed to us, or protecting ourselves from legal liability; | ||||||
| 5.3.11. | manage our investor and shareholder relations; and | ||||||
| 5.3.12. | process or share your personal data to facilitate acquisitions, mergers or transfers of our business. | ||||||
| 5.4 | Marketing purposes. We may use your personal data for direct marketing. In order for us to market products, events and services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us, or data collected from your interactions with us. However, no marketing, whether direct, jointly, or by a third party, using your personal data would be carried out unless you have provided us with your consent to use your personal data for such marketing purposes (unless we are exempted by applicable law from having to obtain your express consent). In particular, we will not transfer your personal data to a third party for direct marketing, unless you have provided us with your consent.
If you do not want us to use your personal data for the purposes of marketing you can withdraw your consent at any time by sending an email to [email protected]. Your withdrawal will be effective on the date of our acknowledgement of receipt. |
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| 5.5 | Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law. Your personal data may be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete your personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved. | ||||||
| 5.6 | Contacting you. When using your personal data to contact you for the above purposes, we may contact you via e-mail, telephone or any other means. We will not contact you for marketing purposes unless with your express consent, or we are exempted by applicable law from having to obtain your express consent. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us by [email protected]. | ||||||
| 6 | USE OF COOKIES AND SIMILAR TECHNOLOGIES | ||||||
| 6.1 | Cookies. In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device. There are three main types of cookies: | ||||||
| 6.1.1. | Session cookies: specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you don’t have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes; | ||||||
| 6.1.2. | Persistent cookies: record information about your preferences and are stored in your browser cache; and | ||||||
| 6.1.3. | Third party cookies: placed by someone other than us which may gather data across multiple websites or sessions. | ||||||
| 6.2 | How we use cookies. We use cookies for the following purposes: | ||||||
| 6.2.1. |
|
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| We may also automatically collect and store certain information about your interaction with our Website or app including IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps and related data. | |||||||
| 6.3 | Cookies we use. A list of cookies used on our website are as set out below. | ||||||
| Third party cookies | |||||||
| Name of cookie | Why it is used | Company | Third party privacy policies | Expiration | User controls | ||
| Google Analytics | [The information generated by the cookie on your use of the website will be transmitted to and stored by Google on servers in the United States. We have activated the so called “IP-anonymization” which means that your IP address will be truncated within the area of the European Union or the European Economic Area before being transferred to the United States. Only in exceptional cases the entire (i.e. non-truncated) IP address will be transferred to a Google server in the US and truncated there. Google will use this information on our behalf for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website and internet usage. Google does not provide us with data that we may link back to you. Your truncated IP address that is transferred to Google will not be associated with any other data held by Google.] |
Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). | https://policies.google.com/privacy | ongoing. | You may refuse accepting cookies by selecting the relevant settings of your browser. However, please note that if you do so you may not be able to use the full functionality of the website.
You can also opt out from being tracked via Google Analytics with effect for the future by downloading and installing Google Analytics Opt-out Browser Add-on under https://tools.google.com/dlpage/gaoptout . |
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| Where we allow third parties identified above to drop cookies, we have no control over those cookies or the data generated. Please refer to the third party’s privacy policy for information on what information they collect and how they use it. We will not be liable to the application of your data by third parties. | |||||||
| 6.4 | Refusing or deleting cookies. Most internet browsers are set up by default to accept cookies. However if you want to refuse or delete them (or similar technologies) please refer to the help and support area on your browser for instructions on how to block or delete cookies (for example: Chrome, Edge, Firefox, Safari, Internet Explorer, Opera, etc.). Please note you may not be able to take advantage of all the features of our Website, including certain personalised features, if you delete or refuse cookies. | ||||||
| 6.5 | If you are a resident in the EU. For more information on managing cookies, please visit http://www.youronlinechoices.eu which has further information about behavioral advertising and online privacy. | ||||||
| 6.6 | Changes to our uses of Cookies. If we change anything important about this Section 6 on cookies, we will notify you through a pop-up on the website for a reasonable length of time prior to and following the change. You may review this Section by visiting the sites and clicking on the “Privacy Policy” link. | ||||||
| 7. | DISCLOSURE OF PERSONAL DATA | ||||||
| 7.1 | Disclosure to related parties. We may disclose or share your personal data with our Madison Pacific Group affiliates, financial services companies and investment service providers in order to provide our services to you, manage our shareholder and investor returns, for management and compliance purposes and to utilise shared group IT functions. | ||||||
| 7.2 | Disclosure to third parties. We may also disclose your personal data to third parties in connection with purposes described in Section 5, including without limitation the following circumstances: | ||||||
| 7.2.1. | disclosing your personal data to third parties who provide services to us (including, but not limited to, data providers, technology providers, insurance providers, financial institutions, credit card payment processors and auditors); | ||||||
| 7.2.2. | disclosing your personal data to third parties in order to fulfil such third party products and/or services as may be requested or directed by you; | ||||||
| 7.2.3. | disclosing your personal data to third parties that we conduct joint marketing and cross promotions with; | ||||||
| 7.2.3. | disclosing your personal data to third parties that we conduct joint marketing and cross promotions with; | ||||||
| 7.2.4. | disclosing your personal data to regulatory authorities, governments, law enforcement agencies or public agencies; | ||||||
| 7.2.5. | If we are discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality; | ||||||
| 7.2.6. | If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you; and | ||||||
| 7.2.7. | If we are defending a legal claim your information may be transferred as required in connection with defending such claim. | ||||||
| 7.3 | When disclosing personal data to third parties, we will (where appropriate and permissible) enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and/or ensure that they only process your personal data in accordance with our instructions. | ||||||
| 8. | CROSS-JURISDICTIONAL TRANSFERS | ||||||
| 8.1 | Transfers. We may transfer your personal data to different jurisdictions in connection with the purposes described in Section 5: | ||||||
| 8.1.1. | from the jurisdiction where it is collected (or where you are located) to any other jurisdictions that we operate in; and | ||||||
| 8.1.2. | to third parties in other jurisdictions. | ||||||
| 8.2 | Safeguards. Where we transfer your personal data across jurisdictions, we will ensure that your personal data is protected in accordance with this Policy and applicable laws regardless of the jurisdictions they are transferred to, but in any event to a level that is no less stringent than the jurisdiction from which the personal data is transferred. When we transfer your personal data internationally and where required by applicable law we put in place appropriate safeguards including EU Model Clauses or rely on EU Commission adequacy decisions. You may obtain details of these safeguards by contacting us. | ||||||
| 9. | PROTECTION OF PERSONAL DATA | ||||||
| 9.1 | Unauthorised access. While we take reasonable precautions to safeguard your personal data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes. | ||||||
| 9.2 | Vulnerabilities. We do not make any warranty, guarantee, or representation that your use of our website is safe and protected from malware and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk. | ||||||
| 9.3 | Period of retention. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including data analytics, audit, accounting or reporting purposes. The standard retention period is 7 years in accordance with statutory requirements. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may also be retained for longer, e.g. where we are required to do so by law in the relevant jurisdiction. | ||||||
| 9.4 | Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction. | ||||||
| 10. | YOUR RIGHTS | ||||||
| 10.1 | Rights you may enjoy. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain rights under applicable law in relation to our collection, use, disclosure and processing of your personal data. Such rights include: | ||||||
| 10.1.1. | Access: you may ask us if we hold your personal data and, if we do, you may request access to your personal data. This enables you to receive a copy of and information on the personal data we hold about you. | ||||||
| 10.1.2. | Correction: you may request that any incomplete or inaccurate personal data we hold about you is corrected. | ||||||
| 10.1.3. | Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances. | ||||||
| 10.1.4. | Restriction: you may withdraw consent for our use of your personal data, or ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy. | ||||||
| 10.1.5. | Portability: you may request the transfer of certain of your personal data to another party under certain conditions. | ||||||
| 10.1.6. | Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground. | ||||||
| If you wish to exercise your rights, you may contact us to in accordance with Section 11.1 below. We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request. | |||||||
| 10.2 | Limitations. We may be permitted under applicable laws to refuse a request. For example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing. | ||||||
| 10.3 | Complaints. If you are of the opinion that we have not complied with this Policy or we have infringed applicable data protection laws, we encourage you to contact us so that we can resolve your concerns. This does not affect your statutory rights. For example, if the EU GDPR applies to you, you have a right to lodge a complaint with a European supervisory authority, in particular in the Member State in the European Union where you are habitually resident, where you work or where an alleged infringement of Data Protection law has taken place. Under the UK GDPR, in the United Kingdom you can make a complaint to the Information Commissioner’s Office (Tel: +44 0303 123 1113 or at ico.org.uk). | ||||||
| 11. | CONTACT US | ||||||
| 11.1 | Contact Data Protection Officer. If you have any feedback or issues in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact our Data Protection Officer at: | ||||||
| Email : [email protected] | |||||||
| When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond. | |||||||
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