PRIVACY POLICY

In this Privacy Policy, "we," "us," "our," or "Silver Bullion" refers to Silver Bullion Pte Ltd, and "you," "your," or "yours" refers to individuals subject to this policy.

We are committed to safeguarding your personal data and have implemented robust security measures to protect it. This policy explains how we collect, use, disclose, process, and manage your personal data in compliance with the Personal Data Protection Act (PDPA) of Singapore.

This Privacy Policy applies to all personal data within our possession or control, including information collected through interactions with our websites, services, and physical premises.

COLLECTION OF PERSONAL DATA

"Personal data" refers to information that identifies an individual. We may collect personal data required to provide our products and services, and to comply with 'Know-Your-Customer' (KYC) regulations essential for providing these products and services. The types of personal data we may collect include, but are not limited to:

1. Personal Particulars: Name, residential address, date of birth, nationality.
2. Identity Verification Information: Images of government-issued identification, such as a passport, NRIC, or driver’s license.
3. Contact Information: Mobile number, phone number, email address.
4. Employment Details: Positions held in companies, including directorships and trusteeships.
5. Financial Information: Bank names and account numbers.
6. Personal Feedback: Opinions or responses provided in surveys or feedback forms.
7. Appointment Booking Information: When customers book appointments to visit the Silver Bullion office at The Reserve building, we collect first and last names and email addresses. This appointment information is forwarded to the building security team for security purposes and to facilitate entry into the building by appointment.

USE OF PERSONAL DATA

We may use your personal data for a variety of purposes necessary for our core business operations and to enhance your experience with our products and services. These purposes include, but are not limited to:

1. To develop, provide, and manage our products and services, including:
   • Processing buy and sell orders,
   • Handling borrowing requests and lending offers,
   • Executing related transactions,
   • Verifying your identity when collecting orders or during bullion withdrawals,
   • Conducting research, planning, and statistical analysis, and
   • Performing analytics to improve our products, services, security, service quality, and marketing strategies.
2. To assess and process applications, instructions, or requests from you.
3. To communicate with you about changes to our products and services, including any additions, modifications, or updates to terms and conditions.
4. To manage our business operations and infrastructure, ensuring compliance with internal policies and procedures.
5. To respond to queries, feedback, complaints, and requests.
6. To verify your identity as required for providing products or services, including screenings or due diligence checks mandated by applicable laws or regulations.
7. Processing insurance loss claims and issuing loss payee certificates where applicable, which may require disclosing personal data to our insurers or their agents.
8. To comply with legal and regulatory requirements applicable to us.
9. To monitor and review products and services provided by or made available through us, ensuring they meet high standards of quality and security.
10. For financial reporting, audits, and maintaining accurate records.
11. To enforce obligations owed to us and seek professional advice, including legal advice, as needed.
12. Utilizing appointment booking information to facilitate entry to the Silver Bullion office at The Reserve building, ensuring security and efficiency in managing visitor access.

We may also use your personal data for purposes outlined in the terms and conditions governing our relationship with you or as required by applicable laws and regulations.

MARKETING COMMUNICATIONS

If you have subscribed to our newsletter, we may use your personal data to send you updates, offers, and promotions related to products and services from Silver Bullion or its affiliates. These communications will be sent in compliance with the Singapore Personal Data Protection Act (PDPA) and other applicable data protection laws, such as the European Union General Data Protection Regulation (GDPR).

You may opt out of receiving marketing communications at any time by unsubscribing from our newsletter or contacting us directly.

DISCLOSURE OF PERSONAL DATA

We may disclose your personal data in compliance with all applicable laws on data privacy, in response to legal orders from Singapore courts, requests from Singapore regulatory authorities, or to our insurers or their agents solely for the purpose of processing claims related to the loss of goods or issuing loss payee certificates. When we disclose personal data to such parties, we ensure that confidentiality and security are maintained.

Silver Bullion does not sell personal data to third parties. We are fully compliant with all confidentiality obligations as required by applicable agreements, governing terms and conditions, and relevant laws.

COOKIES AND RELATED TECHNOLOGIES

Our website uses cookies, which are small text files placed on your computer or mobile device when you visit a website. Cookies collect information about users and their interactions with the website, such as their Internet Protocol (IP) address, how they arrived at the site (e.g., via a search engine or a link from another site), and how they navigate within the site. We use cookies and similar technologies to facilitate your internet sessions, provide products and services according to your preferences (e.g., preferred currency), track website usage, and compile statistics on site activities.

You may configure your web browser to block cookies, which will prevent the website from tracking your visit. You can also delete cookies stored on your computer or mobile device. However, blocking cookies may disable certain features and functions of our website.

LINKS TO EXTERNAL WEBSITES

Our website may contain links to external sites that are not operated or maintained by Silver Bullion.

Once you leave our website, the privacy policies of these third-party sites will govern any data you provide or that is collected during your visit. We are not responsible for privacy practices, security measures, or content on these sites.

We encourage you to review the privacy policies of any external websites you visit to understand their data collection, usage, and protection practices.

RETENTION OF PERSONAL DATA

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, such as providing our products and services or meeting legal, regulatory, and business requirements.

Once your personal data is no longer needed for these purposes or when it no longer meets retention requirements under applicable laws or regulations, we will securely delete it. Our retention policies ensure that we store personal data only as long as it is relevant to our operations, with periodic reviews to maintain compliance.

ACCESS, CORRECTION, AND DATA RIGHTS

You have the right to request access to, correction of, or information on how we process your personal data.

For individuals under the GDPR, additional rights include requesting data in electronic format, transmitting data to third parties, objecting to or restricting data processing, and requesting data erasure in specific circumstances. These rights are subject to applicable legal obligations.

HOW TO CONTACT US

For inquiries regarding this Privacy Policy or to exercise your data protection rights, please contact our Data Protection Officer (DPO) at [email protected].

AMENDMENTS TO THIS POLICY

We may update this Privacy Policy periodically to reflect changes in legal or regulatory requirements.

The latest version will be available on our website (https://www.silverbullion.com.sg/privacy). All interactions will be governed by the policy in force at the time.