Privacy Policy

1. Introduction

ScadiSolfu Pte Ltd ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website scadisolfu.com or use our services.

This Privacy Policy complies with the Personal Data Protection Act 2012 (PDPA) of Singapore and other applicable privacy laws and regulations.

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

• Contact Information: Name, email address, phone number, mailing address
• Financial Information: Income details, financial goals, investment preferences (only when you engage our services)
• Identification Information: NRIC/FIN number, date of birth (for client verification)
• Communication Records: Records of your communications with us, including emails, phone calls, and meeting notes

2.2 Non-Personal Information

We automatically collect certain non-personal information when you visit our website:

• Usage Data: Pages visited, time spent on site, click patterns, referral sources
• Device Information: IP address, browser type, operating system, device type
• Location Data: General geographic location based on IP address

2.3 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your browsing experience. For detailed information about our cookie usage, please refer to our Cookie Policy.

3. How We Use Your Information

3.1 Primary Purposes

We use your personal information for the following purposes:

• Service Provision: To provide financial advisory services, consultations, and educational content
• Communication: To respond to your inquiries, send newsletters, and provide customer support
• Account Management: To create and manage your account, process transactions, and maintain service records
• Legal Compliance: To comply with regulatory requirements, including KYC (Know Your Customer) and AML (Anti-Money Laundering) obligations

3.2 Secondary Purposes

With your consent, we may also use your information for:

• Marketing: To send you promotional materials, market research surveys, and information about our services
• Website Improvement: To analyze website usage patterns and improve our online services
• Research: To conduct market research and develop new financial products or services

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: When you provide explicit consent for specific processing activities
• Contract Performance: To fulfill our contractual obligations when you engage our services
• Legal Obligation: To comply with applicable laws and regulations
• Legitimate Interest: For business operations, fraud prevention, and service improvement

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in:

• IT services and website hosting
• Payment processing
• Marketing and communication services
• Legal and compliance services
• Data analysis and research

These service providers are contractually obligated to protect your information and use it only for specified purposes.

5.2 Regulatory Authorities

We may disclose your information to regulatory authorities, including:

• Monetary Authority of Singapore (MAS)
• Commercial Affairs Department (CAD)
• Other relevant government agencies

Such disclosures are made to comply with legal obligations and regulatory requirements.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity, subject to appropriate safeguards and notifications.

5.4 Legal Requirements

We may disclose your information when required by law, court order, or to:

• Protect our legal rights and interests
• Prevent fraud or criminal activity
• Ensure the safety of our employees and clients
• Comply with law enforcement requests

6. Data Security

6.1 Security Measures

We implement comprehensive security measures to protect your personal information, including:

• Encryption: Data transmission and storage encryption using industry-standard protocols
• Access Controls: Strict access controls and authentication mechanisms
• Security Monitoring: Continuous monitoring for unauthorized access or security breaches
• Employee Training: Regular security awareness training for all staff members
• Secure Facilities: Physical security measures for our offices and data storage facilities

6.2 Data Breach Response

In the unlikely event of a data breach, we will:

• Immediately assess and contain the breach
• Notify relevant authorities within 72 hours (if required by law)
• Inform affected individuals promptly
• Take necessary remedial actions
• Conduct a thorough investigation and implement preventive measures

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law.

7.1 Retention Periods

• Client Records: 7 years after the end of our business relationship (MAS requirement)
• Marketing Communications: Until you unsubscribe or withdraw consent
• Website Usage Data: 2 years from collection
• Financial Transaction Records: 5 years from the transaction date

7.2 Data Disposal

When personal information is no longer needed, we securely delete or destroy it using appropriate methods to prevent unauthorized access or reconstruction.

8. Your Rights and Choices

8.1 Access Rights

You have the right to:

• Request information about the personal data we hold about you
• Receive a copy of your personal data in a structured, commonly used format
• Request information about how your data is being used

8.2 Correction Rights

You may request correction of:

• Inaccurate personal data
• Incomplete personal data
• Outdated personal data

8.3 Withdrawal of Consent

Where processing is based on consent, you have the right to:

• Withdraw consent at any time
• Opt-out of marketing communications
• Refuse certain types of data processing

Note that withdrawal of consent may affect our ability to provide certain services.

8.4 Do Not Call (DNC) Registry

We respect Singapore's Do Not Call Registry. If you are registered with the DNC, we will not send you marketing communications unless you have provided explicit consent or we have an existing business relationship.

9. International Data Transfers

We primarily process and store your data within Singapore. However, some of our service providers may be located outside Singapore. When we transfer data internationally, we ensure:

• Adequate protection through contractual safeguards
• Compliance with applicable data protection laws
• Regular monitoring of data processing activities

10. Children's Privacy

Our services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take immediate steps to delete such information.

11. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• Changes in our business practices
• Legal and regulatory updates
• Improvements to our services
• Feedback from users and stakeholders

We will notify you of material changes by:

• Posting the updated policy on our website
• Sending email notifications to registered users
• Displaying prominent notices on our website

12. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

13. Governing Law

This Privacy Policy is governed by the laws of Singapore. Any disputes arising from this Privacy Policy shall be subject to the exclusive jurisdiction of the Singapore courts.

14. Language

This Privacy Policy is written in English. In case of any translation into other languages, the English version shall prevail in case of any inconsistency or discrepancy.