This Privacy Notice relates to the collection, use and disclosure of personal data, including special or sensitive personal data, by Libeara (Singapore) Pte. Ltd. (UEN 202302950G) (“we”, “us”, “our”).

1.     What Personal Data We Collect

1.1. Personal Data is information relating to an individual (“you” or “your”) and comprises of all the details that we hold or collect about you, directly or indirectly, through your interactions and dealings with us, which includes your use of our Platform (which includes our websites, mobile applications, browser plug-in, software and updates as made available from time to time), and any application you may make to us in respect of career opportunities or to manage your employment relationship with us. You agree to, and consent to, our use of your Personal Data as set out in this Privacy Notice.

2.     How We Use Personal Data

2.1. We collect your Personal Data so that we can provide you with our products and services, manage our relationship with you, and operate our business. We will generally process your personal data with your consent where required by law, or whether otherwise permitted or required by applicable law.

2.2. Our Platform may collect and store certain information automatically when you access and use our Platform. We may also collect Personal Data collected through cookies and similar technology. The information may include internet protocol (“IP”) addresses, the region or general location where your computer or device is accessing the internet, browser or application type, operating system and other usage information about your use of our Platform, including a history of the pages and/or tabs you view. We use this information to help us design our Platform to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information for analytical purposes.

2.3. When visiting our Platform and/or utilising our services, you may also choose to provide Personal Data, such as your name, identification details, contact details, and financial information, to us. We may not be able to offer or provide you with our services if you do not provide us with or do not permit us to process the Personal Data that we require to meet our legal and regulatory obligations.

2.4. We may process your Personal Data for the following purposes:

2.4.1. for you to access and use our Platform to perform and/or receive certain services and content relating to your intended participation and investment in certain investment products (the “Investment-related Services”) and delivery to you of other related services, provided by licensed fund managers, issuers, support service providers and other third parties (our “Partners”);

2.4.2. to enable us and our Partners to perform their client onboarding and screening procedures in relation to the Investment-related Services that you intend to participate in;

2.4.3. to enable us to fulfil our contractual obligations to you and to our Partners, including our transfer of Personal Data to our Partners for your intended participation in the Investment-related Services;

2.4.4. to respond to your request for information or assistance, either through an online form or through email;

2.4.5. to respond to your interest in any career opportunities, that you may submit to us through an online form, our social media accounts, or through email;

2.4.6. to manage your employment relationship with us (if applicable);

2.4.7. to respond to your enquiries about our range of products and services;

2.4.8. to comply with our legal or regulatory obligations, including (but not limited to):

• the prevention, detection, investigation and prosecution of crime in any jurisdiction (including, without limitation, money laundering, terrorism, fraud and other financial crime);
• identity verification, government sanctions screening and due diligence checks; and
• to comply with local or foreign law, regulations, directives, judgments or court orders, government sanctions or embargoes, reporting requirements under financial transactions legislation, and demands of any authority, regulator, tribunal, enforcement agency, or exchange body;

2.4.9. to effect agreements between any member of the Standard Chartered PLC’s group of companies (the “Standard Chartered Group”) and any authority, regulator, or enforcement agency;

2.4.10. to comply with policies (including the Standard Chartered Group’s policies) and good practice standards where it is in our legitimate interest to do so; or

2.4.11. where it is in our legitimate interests to seek professional advice, including without limitation, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights; and/or

2.4.12. for statistical analysis to improve our products and services.

2.5. We will not utilise your Personal Data for any marketing purposes if you have opted out of receiving marketing material. You may withdraw your consent at any time by contacting us at the details specified in section 4 (How we store and manage Personal Data) below.

3.     To whom we may disclose Personal Data

3.1. We may disclose your Personal Data to any of the following parties, in any jurisdiction, for any of the purposes specified in section 2 (How We Use Personal Data) above:

• any member of the Standard Chartered Group anywhere in the world, including any officer, employee, agent or director;
• professional advisers (including auditors), third party service providers, agents or independent contractors providing services to support our and the Standard Chartered Group’s business;
• our Partners who may provide, or support the provision of, Investment-related Services to you;
• any person to whom disclosure is allowed or required by local or foreign law, regulation or any other applicable instrument;
• any court, tribunal, regulator, enforcement agency, exchange body, tax authority, or any other authority (including any authority investigating an offence) or their agents;
• any debt collection agency, credit bureau or credit reference agency, rating agency correspondents, insurer or insurance broker, direct or indirect provider of credit protection and fraud prevention agencies;
• any financial institution to conduct credit checks;
• any due diligence service provider to conduct anti-money laundering and due diligence related checks, for fraud prevention and detection of crime purposes, and (where applicable) to manage your employment relationship with us;
• anyone we consider necessary to facilitate requests for services or applications for the Investment-related Services or to provide services in connection with the Investment-related Services; and
• any actual or potential participant or sub-participant in relation to any of our obligations in respect of any agreement, assignee, novatee or transferee (or any officer, employee, agent or adviser of any of them).

3.2. As your Personal Data may be transferred to our Partners as referenced to in Section 2.4.1 above, our Partners, our Partners may have specific terms that govern the collection, use and disclosure of your personal data. Such other terms and conditions must be read in conjunction with this Privacy Notice, and the collection, use and disclosure of any Personal Data you provide to them is governed by their privacy policies and not ours. The list of some of the third-party service providers and Partners within whom we work is as follows:

• Issuers/ Fund Managers (e.g., FundBridge Capital Pte. Ltd.);
• Chekk Limited –  https://www.chekk.me/privpol/prvpol-en/index.html;
• London Stock Exchange Group – https://www.lseg.com/en/policies/privacy-statement;
• ACME Technology Pte. Ltd. – https://www.tryacme.com/legal.

4.     How We Store And Manage Personal Data

4.1. We may transfer your Personal Data to countries outside of Singapore. If we do so, we will ensure that the recipient is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is comparable to the protection under Singapore law.

4.2. We will retain your Personal Data (i) for as long as we are required to do so for compliance with our legal and regulatory obligations, or where required for business and operational purposes, or (ii) for at least seven (7) years after you have terminated your relationship with us, whichever is the greater time period.

4.3. Subject to applicable law and regulations, you may have certain rights in relation to your Personal Data, including:

i.   Access: You may have the right to request a copy of your Personal Data in our possession or under our control, and information about its use or disclosure, subject to applicable laws. We may charge an administrative fee for processing your request.

ii.   Correction: You may request at any time that we correct your Personal Data.

iii.   Erasure:

• If you access and use our Platform, you may at any time request that we cease to collect, use, or disclose your Personal Data. However, in such a situation, as the processing of Personal Data may be necessary for us to provide our products and services to you and to allow you to access our Platform, which means that we may have to cease the provision of services to you and terminate your relationship with us.
• If you are an applicant to any career opportunities with us, we will require your Personal Data to manage our relationship with you and comply with our regulatory obligations. In such a situation, depending on the nature and extent of your request, if you are an applicant, we may not be able to consider you for the employment opportunity if you request us to cease to collect, use, or disclose your Personal Data.
• If you are an employee with us, we will require your Personal Data to manage our employment relationship with you and comply with our regulatory obligations, even in situations where your relationship with us has been terminated or altered in any way.

We may retain a copy of your Personal Data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws, or in order to comply with our compliance obligations, policies, and processes. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

iv.   Portability: In some circumstances you may have the right to request the Personal Data you have given to us in a machine-readable format.

5.     Contact Us

5.1. If you have any questions or feedback relating to how we collect, use, process, or otherwise handle your Personal Data, or wish to exercise your rights in relation to your Personal Data, please contact us at:

Email: dpo@libeara.com

Attention: Data Protection Officer

6.     Updates and Amendments

We reserve the right to revise this Privacy Notice from time to time without any prior notice. Any such amendments shall take effect from the date they are published on our Platform. By (i) continuing to access or use the Platform and our products and services after any revisions become effective, and/or (ii) (where applicable) you continue to be in our employment and continue your participation in our recruitment process, you agree to be bound by the updated Privacy Notice.