Shareholder Data Protection Policy

 

This Shareholder Data Protection Policy (“Data Protection Policy”) outlines how the Personal Data collected will be managed by IFS Capital Limited (“IFS”, “we” or “us”) in accordance with the Personal Data Protection Act 2012 (“PDPA”) including the purposes for which such Personal Data may be collected, used or disclosed by us.

By becoming our shareholder, or interacting with us or submitting information to us in your capacity as a shareholder or potential shareholder of IFS, you agree and consent to IFS as well as its board of directors, company secretaries, share registrar, representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to its authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents which may have been previously provided to us and your consents herein are additional to any rights that we may have at law in connection with the collection, use and/or disclosure of the Personal Data. Nothing herein is to be construed as limiting any of these other rights.

We may amend and vary this Data Protection Policy from time to time and subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time on our website at http: www.ifscapital.com.sg

  1. Personal Data
    In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data or (b) from that data and other information to which IFS has or is likely to have access.

  2. Collection of Personal Data

    1. Generally, IFS collects Personal Data in the following ways:

      1. when you become a shareholder of IFS or in the course of you being a shareholder of IFS;

      2. when IFS seeks information from The Central Depository (Pte) Limited (“CDP”) in connection with your shareholding in IFS;

      3. when you make relevant statutory disclosures to IFS and/or the regulatory authorities in compliance with applicable laws and regulations;

      4. when you provide your Personal Data to IFS for any other reason, including communication (for example, via telephone calls, letters and emails) with IFS company secretariat, investor relations officers and share registrar; and e. information from cookies, or other technologies deployed for analysis of visits to websites or the use of any information technology application of IFS.

    2. If you provide IFS with any Personal Data relating to a third party (e.g. information of your spouse, children, parents or proxy), by submitting such information to IFS, you represent and warrant to IFS that you have obtained the consent of the third party to provide IFS with their Personal Data for the respective purposes.

  3. Purposes for the Collection and Use of Personal Data
    IFS may collect, use and/or process your Personal Data for, one or more of the following purposes:

  1. complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies, which are binding on IFS and/or you (including but not limited to responding to, disclosing to regulatory bodies, share registrar and conducting audit checks, due diligence and investigations);

  2. administering our relationship with you, including without limitation, the maintenance of shareholder register;

  3. managing publication of shareholder statistics and data on annual reports and circulars;

  4. handling of dividend or any other payments;

  5. facilitating communications with you, including responding to your queries and requests, and sending notices of general meetings, annual reports and shareholder circulars to you;

  6. facilitating corporate actions (including without limitation, capital reduction, rights or bonus issue and repurchase and cancellation of shares);

  7. facilitating shareholder analysis;

  8. registering shareholders at general meetings and shareholders’ events organised by IFS (including without limitation, verification of your identity and/or your proxy and grant of system access for e‐polling system (if any));

  9. taking photographs and/or video recordings of you at general meetings or events organised by IFS, for publication in IFS’s annual reports, or posting on IFS website, or any other medium IFS deems appropriate;

  10. legal and investor relations purposes (including without limitation, rendering or procuring legal and regulatory advisory); and

  11. any other purposes reasonably related to any of the above. (collectively, the “Purposes”)

  • Disclosure of Personal Data
    In carrying out one or more of the above Purposes, the Personal Data may be disclosed to the following parties (whether located within or outside Singapore) for the above Purposes or for processing in accordance to the above Purposes on a need to know basis:

  1. director, company secretary, officer, staff and relevant personnel of IFS or its related corporations;

  2. IFS’s share registrar;

  3. any agent, contractor or third party service provider who provides operational services such as courier services, processing, administrative, nformation technology, printing, mailing, telecommunication or other services to IFS;

  4. third party service providers (including without limitation, scrutineers and service providers to facilitate polling);

  5. IFS’s auditors and professional advisors including its solicitors;

  6. any person or entity to whom IFS is under an obligation or otherwise required to make disclosure pursuant to legal process or pursuant to any domestic or foreign legal and/or regulatory obligation or rules issued by stock exchange;

  7. regulators, law enforcement and government agencies;

  8. any business partner, investor, actual or proposed assignee or transferee in relation to business asset transactions (which may include merger or acquisition) involving IFS and its related corporations; and

  9. any person in connection with any of the Purposes.

  • Withdrawal of Consent
    The consent to use or disclose the Personal Data for any of the above Purposes can be withdrawn by you at any time by reasonable notice in writing to IFS pursuant to PDPA. However, depending on the circumstances and the nature or extent of the withdrawal of consent, such withdrawal of consent may result in IFS’s inability to continue to attend to your queries and needs as a shareholder or to administer your shareholding. IFS’s legal rights and remedies are expressly reserved in such event.

  • Access and Correction of Personal Data
    To the extent that the applicable law allows, you may request access to, and correction of, the Personal Data in relation to yourself. However, some Personal Data may be exempt from such access and correction rights in accordance with the PDPA. All requests for access to, and/or correction of, the Personal Data can be submitted to IFS’s Data Protection Officer via email address at dpo@ifscapital.com.sg. Please note that IFS has the right to charge a reasonable fee for the handling and processing of such requests. However, please note that if your Personal Data has been provided to us by The Central Depository (Pte) Limited (“CDP”), you should contact CDP to make such requests to IFS on your behalf.

  • Governing Law
    This Data Protection Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the courts of Singapore.

  • Contacting Us
    For any queries relating to the collection, use or disclosure of the Personal Data or for more information about this Data Protection Policy, please contact IFS’s Data Protection Officer at dpo@ifscapital.com.sg.
    For the avoidance of doubt, where the Singapore personal data protection law permits an organization such as IFS to collect, use, disclose or process Personal Data without consent, such permission granted by the law shall continue to apply and nothing herein is to be construed as limiting any of these rights.