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KCM Data Protection Policy
The Personal Data Protection Act 2012 of Singapore (“PDPA”) came into force on 2 July 2014. KCM takes its obligations under the PDPA seriously and is committed to safeguard any personal information that has been, and will in future be, provided to it in its role as Investment Manager to its managed portfolios. This Policy sets out the purposes for which KCM will collect, use, disclose and process personal data.

Collection of Personal Data
“Personal data” is data that can be used to identify a natural person. Examples of personal data that KCM may collect are:

(a) personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
(b) specimen signatures;
(c) financial details;
(d) employment details;
(e) tax information;
(f) information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets; and
(g) banking information.

Generally, KCM obtains personal data by virtue of its role as Investment Manager to its managed portfolios, where the relevant Fund Administrators share subscription and other account information with KCM to facilitate the management of the various portfolios, and compliance with KCM’s obligations under applicable anti-money laundering and countering the financing of terrorism laws, regulations or directives.

Use of Personal Data
KCM may use personal data reasonably in relation to its core business, which use includes for:

(a) the provision of investment management services to its managed portfolios;
(b) assessing and processing subscriptions, and other instructions or requests from investors in its managed portfolios;
(c) communicating with investors in its managed portfolios, including the provision of monthly fact sheets and other investor notifications;
(d) managing its business operations, and complying with internal policies and procedures;
(e) responding to queries or feedback from investors in its managed portfolios, and addressing or investigating any complaints, claims or disputes;
(f) verification of identity for the purposes of meeting compliance obligations under applicable anti-money laundering and countering the financing of terrorism laws, regulations or directives;
(g) complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities, or other agencies of competent authority;
(h) enforcing any obligations that may be owed to KCM;
(i) financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes; and
(j) seeking any professional advice, including legal advice.

KCM may also use personal data for the purposes set out in the various terms and conditions of the respective subscription forms of any fund in its managed portfolios.

Use of Personal Data for Marketing Purposes
KCM may use personal data to inform on the launch of new funds that may be of interest to the existing investors in its managed portfolios, for which such existing investors may be eligible. In doing so, KCM will comply with the PDPA and any other applicable data protection laws and regulations. Upon request by any person, KCM will cease to use that person’s personal data for marketing purposes.

Disclosure of Personal Data
KCM may from time to time, and in compliance with all applicable laws, disclose personal data to any of the managed portfolios, the relevant Fund Administrators, or to other third parties, whether located in Singapore or elsewhere, in order to carry out the purposes set out above. Where personal data is disclosed to such parties, KCM shall take reasonable steps ensure that any such data is kept confidential and secure. KCM may on occasion transfer, store, process and/or deal with personal data outside Singapore, and in doing so, will comply with the PDPA and other applicable data protection and privacy laws, including taking reasonable steps to prevent the unauthorised access, collection, use and disclosure of personal data.

Websites
KCM’s website may contain links to other websites which are not maintained by KCM. For the avoidance of doubt, this Policy shall only apply to KCM’s website, and shall not extend to the use of any third party website.

Access and correction
Where permitted under applicable law, KCM will allow access and/or corrections to personal data in its possession or under its control. Upon request by any person, and subject always to any applicable laws that KCM may be required to comply with, KCM will take reasonable steps to erase and/or cease to use that person’s personal data.

Retention of Personal Data
KCM will retain personal data as long as the purpose for which such data was collected remains, and until it is no longer necessary for any other legal or business purpose.

Data Protection Officer
KCM has appointed a Data Protection Officer to address all queries and feedback on the Company’s data protection obligations. The Data Protection Officer may be contacted at (+65) +65 6291 0297 during office hours in Singapore, or at admin@kredenscapital.com, using “Privacy Policy” in the email subject line.

Amendments and Updates
KCM may amend this Policy from time to time to ensure that consistency with any developments in the way KCM uses personal data, or to comply with any changes to the laws and regulations applicable to KCM. Updates to this Policy will be made available upon request. All communications and dealings with KCM shall be subject to the latest version of this Policy in force at the relevant time.