Privacy Policy

Effective Date: May 25, 2018

Crowe Horwath First Trust LLP is a member of Crowe Global, a Swiss verein. Each member firm of Crowe Global is a separate and independent legal entity. Crowe Horwath First Trust LLP and its affiliates are not responsible or liable for any acts or omissions of Crowe Global or any other member of Crowe Global.

This privacy notice is in two parts.

Part 1:
This part sets out the personal data protection policy, referenced in our engagement letters with clients, in accordance with the Personal Data Protection Act of Singapore.

Part 2:
This part sets out, in relation to information we collect from this website (the "Site"), the practices we follow to respect the privacy of all visitors. Specifically, it outlines the types of information that we gather about you while you are using the Site, and the ways in which we use this information.

Part 1

Personal Data Protection Policy for Crowe Horwath First Trust Group

Crowe Horwath First Trust LLP and its network firms (“Crowe”, “the Firm” or “us”) respect and are committed to the protection of your personal information and your privacy. This Personal Data Protection Policy explains how we collect and handle your personal information in accordance with the Singapore’s Personal Data Protection Act 2012 (“PDPA”).

It is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

In the absence of such written notification from you, we will deem it that you consent to the processing, usage and dissemination of your personal information in the manner, to the extent and within the scope of this policy. If you do not consent to the processing of your personal information as above, we may not be able to provide you the services you requested.

1. PERSONAL INFORMATION

1.1 Type of personal information
Personal information means any information which relates to you and which was collected or provided to Crowe for the purposes stated in Section 2 below. Your personal information may include but is not limited, to the following:
• Personal details such as name, identity card or passport number, gender, race, nationality, date of birth or age, marital status, occupation, photo, credit card number, assets, financial and banking account details;
• Contact details such as address, telephone number, fax number, mobile number and email address;
• Information in connection with services provided by us or you have registered your interest with us for information, updates, inquiries and engagement;
• Other information that are, have been or may be collected by Crowe, or which you provide to us, from time to time, in connection with any service, transaction, survey, questionnaire or communication with Crowe
• Your image, by way of video or photo shooting during our seminar and corporate events;
• There is automatic collection of some information about your computer such as IP address, web browser software and other information when you visit our website.

1.2 Source of personal information

1.2.1 Client or Prospect
Crowe Horwath collects your personal information directly from you or indirectly from:
• your legal representatives;
• your service providers (e.g. outsourcing IT, human resources and accounting services, merchant bankers, etc);
• your employer or employee when you, your legal representatives, service providers and/or employer / employee send us enquiries for services via various means, including online and physical hardcopies at public venues or in our premise;
• your personal information may also be collected from cookies through the use of our website;
• third party sources such as credit reference agencies, fraud prevention agencies, credit bureau reported, and publicly available source of information;
• inquiry or communication made with or to us or any companies within Crowe Global
Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If you contact us, we may keep a record of that contact.

1.2.2 Prospective candidates in recruitment

As part of our recruitment process, we collect your personal information directly or from your authorised intermediaries to consider you for employment with our firm. During the course of the recruitment and selection process, we may request further personal information that is necessary to assess your suitability for positions with our firm. We may also obtain, with your consent, references from your current or former employer(s) or other sources, in situations where pre-employment checking may be necessary.

2. PURPOSE IN COLLECTION OF PERSONAL INFORMATION
We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If you are acting as an intermediary or otherwise on behalf of a third party or supply us with information regarding a third party (such as a friend, a colleague, an employee etc), you undertake that you are an authorised representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.

2.1 Client or Prospect
Your personal information is collected and further processed by Crowe as required or permitted by law and to give effect to your requested commercial transaction, including the following:
• to provide our services
• to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
• to maintain contact with clients and other contacts
• to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we are holding, that may be of interest to them
• for general management and reporting purposes, such as invoicing and account management
• all other purposes related to our business.
Where you have indicated your consent to receiving marketing or promotional updates from Crowe, you may opt-out from receiving such marketing or promotional material at any time. You may select the “opt-out” option provided in Crowe’s email blasts or you may contact Crowe at the details provided in Section (6) below.

2.2 Prospective candidates in recruitment
Your personal information is collected and further processed by Crowe for the primary purpose of considering your suitability for positions with us and will be used only by partners and staff directly involved in the recruitment process. We will not collect or use personal information in ways other than for the purpose of recruitment.

3. DISCLOSURE OF PERSONAL INFORMATION

3.1 Client or Prospect
We respect the confidentiality of the personal data you have provided to us. Your personal information provided to us is processed by entities (in or outside of Singapore) within Crowe (including related business units, companies, subsidiaries, holding companies, associated companies and outsourcing partners) in order to meet the purposes for which you have submitted the information and activities directly related to it.

We may disclose personal data to other member firms in the Crowe Global network of firms, where it is necessary (i) to meet the purpose for which you have submitted the information; or (ii) to enable you to be provided with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary request. We may also transfer all data in our possession to a successor-in-interest to our business or assets.

By submitting personal data to us, you are providing explicit consent to trans-border transmission of such data as described in this policy. However, we will ensure that any transfer of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

We do not disclose personal data to third parties except when required by law, when we have your consent or deemed consent or in cases where we have engaged the third party such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.

However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations. For more information on these exceptions, please refer to The Second, Third and Fourth Schedule of the PDPA, at the website http://statutes.agc.gov.sg.

3.2 Prospective candidates in recruitment
Information will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with our firm's activities. All such contractors will be bound contractually to keep all information confidential.

4. ACCESS AND UPDATE TO PERSONAL INFORMATION
You have the right to access and correct your personal information held by us (subject always to certain exemptions).

For a request to access personal data, we will provide you with the relevant personal data within thirty (30) days from such a request being made. Where a request cannot be complied with within the above time frame, we will inform you of the reasonably soonest time in which we will respond.

We will make every endeavour to ensure your personal information is accurate and up to date therefore we ask that if there are changes to your information you should notify us directly. Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge for a request to access in accordance with the requirements of the PDPA.

5. REQUEST TO WITHDRAW CONSENT
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to our Data Protection Officer.

We will process your request within thirty (30) days from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.

However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.

The collection of your Personal Data by us may be mandatory or voluntary in nature depending on the Purposes for which your Personal Data is collected. Where it is obligatory for you to provide us with your Personal Data, and you fail or choose not to provide us with such data, or do not consent to the above or this Policy, we will not be able to provide products and/or services or otherwise deal with you.

6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.

We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

7. CONTACT AND ACCESS TO THE DATA PROTECTION OFFICER
If you wish to access or delete your personal data provided to us or if you believe that information we hold about you is incorrect or out of date, or if you have concerns or further queries about how we are handling your personal data, or any problem or complaint about such matters, you may contact us at the following address, attention it to “The Data Protection Officer”:

Crowe Horwath First Trust
9 Raffles Place, #19-20 Republic Plaza Tower 2
Singapore 048619
+65 6221 0338
Email Address: [email protected]

8. UPDATES ON DATA PROTECTION POLICY
As part of our efforts to ensure that we properly manage, process and protect your personal data, we will undertake a continuous review of our policies, procedures and processes. We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website. You are encourage to visit us at www.crowe.sg from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Part 2

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy.

Cookie List

How We Collect and Use Information

We may collect, store and process personal or other information that you supply to us through your use of the Site. For example, individuals who applied for registration as a Member Firm may be contacted by Crowe Global and individuals who contacted us with their information may be contacted to answer their inquiries.

Crowe Global and Crowe Horwath First Trust LLP collect personally identifying information from our users through the Site’s pages, and from time to time there may be other pages where information may be sought which will seek similar information. Generally, this information includes names, phone numbers, e-mail addresses, passwords and employment information for registration or opt-in purposes.

We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect information about your computer's connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site. The Site may also automatically recognize and store information about the type of browser you are using; your Internet Protocol (“IP”) address; the time, date, and length of your visit; and the referring site. We also use a standard browser software feature called a “cookie,” in order to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help identify how many unique users visit us, track user trends and patterns, and may help deliver advertisements or other notices. They also may prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before. Cookies may not expire unless you manually delete them or set your browser to reject them. If you do not accept cookies, you may have difficulty navigating the Website, or the performance may not be the same. The Site also may use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open HTML-formatted email messages.

We may use the information we collect from you while you are using the Site in a variety of ways, including using the information to customize features and advertising that may appear on the Site. Crowe Horwath First Trust LLP may also share information you provide us with Crowe Global and its Member Firms (“Members”) who may use your information to contact you as a prospective Member, client or for similar business purposes. Similarly, in cases where Crowe Global or its other Members may collect information from you directly, they may share such information with us. In cases where your information is collected by Crowe Global or its other Members, their respective privacy policies would also apply to their use of your information, and those policies may differ from ours. If you have any questions regarding the privacy policy of Crowe Global or one of its other Members, you should contact Crowe Global or the other Member directly for more information.

We may also provide your information to third parties such as data processors or other service providers or advertisers in order to improve your experience with us, the Site, or Crowe Global and its other Members, or to provide you with information about related products and services.

If you do not wish your information to be used for any of the above described purposes, email: [email protected] and specify the purposes for which you do not want your information to be used. Please allow us a reasonable time to remove your information from these purposes and cessation of these purposes may therefore not be immediate.

Additionally, Crowe Horwath First Trust LLP may disclose your information to the extent that such disclosure is required by law or to such an extent as we reasonably believe such disclosure is necessary to protect our legal interests. We reserve the right to cooperate with legal authorities and to release such information to comply with legal process. Your information may also be transferred to a third party in the event of a sale, acquisition, merger or bankruptcy involving Crowe Horwath First Trust LLP, or the change in Member Firm for a specific jurisdiction.

The Site may also include links to other websites or provide access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third party products or services, use of any information you provide is governed by the privacy policy of the site you are visiting who is providing such products or services or collecting your information.

Use of Google Analytics

We may also use Google Analytics Advertiser Features (or other similar services) to optimize our business.

Advertiser features include:

Remarketing with Google Analytics;

Google Display Network Impression Reporting;

DoubleClick Platform Integrations; and

Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Site. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Site, and match the right audience with the right advertising message.

You can opt out of Google’s use of cookies by visiting Google’s ad settings and/or you may opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

Location of Your Information

Your personal data may be processed by us in the United States in accordance with applicable law. To the extent your data is transferred by us, to Crowe Global, or between its Members internationally, such transfers will be effected through use of appropriate safeguards under applicable law. BY AGREEING TO THE CROWE HORWATH FIRST TRUST LLP PRIVACY POLICY, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING INTERNATIONALLY OF ANY PERSONAL AND NON-PERSONAL INFORMATION COLLECTED OR OBTAINED BY CROWE HORWATH FIRST TRUST LLP.

Storage Of Your Information

Your information is stored on Crowe Horwath First Trust LLP’s servers that deliver our content and messaging, and is kept as long as such information remains potentially useful for the purposes it was collected, and not any longer. Your information can only be accessed by us, Crowe Global, its Members that subscribe to its Global Directory, and those who help manage its Member portal. Such Members may also store such information.

Email Marketing And Opt-Out

To the extent required by the United States’ Controlling the Assault of Non-Solicited Pornography and Marketing Act of 2003 (CAN-SPAM Act), or other similar domestic and international regulation, all of the commercial emails sent to you by us will include an unsubscribe link in them. You can remove yourself at any time from our mailing list by clicking on the unsubscribe link that can be found in every communication that we send you.

Please note that changes to your email marketing preferences may not be effective immediately, and Crowe Horwath First Trust LLP may be unable to prevent all commercial email contact from Crowe Global or its other Members, which may require you to separately take advantage of opt-out features provided by Crowe Global or its other Members.

Your Privacy Rights

You have the right to access, transport, update, rectify, or erase your personal data, as well as the right to object to or restrict its processing, transform it into anonymous form, or withdraw from any consent-based uses. These rights may be exercised by emailing [email protected].You also have a right to complain to your local data protection authorities if you believe your privacy rights related to your personal information have not been properly observed.

Additionally, California’s “Shine the Light” Law (CA Civil Code § 1798.83) allows California residents to request certain information regarding our disclosures, if any, of your personally identifiable information to third parties for their own direct marketing purposes in the prior calendar year. To make such a request, please email: [email protected] with “Request for California Privacy” in the letter subject line.

When contacting us regarding your rights, you must include sufficient detail for us to locate your file; at a minimum, your name, email and postal address.

We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that the California Shine the Light law does not cover all information sharing, and our disclosure may only include information covered by the law.

Updates to Privacy Policy

Crowe Horwath First Trust LLP reserves the right to update and revise this Privacy Policy at its discretion. You can determine if this Privacy Policy has been revised since your last visit by referring to the “Effective Date of Current Policy” date at the top of this page. Your use of our Website constitutes your acceptance of the terms of the Privacy Policy as amended or revised by us, and you should therefore review this Privacy Policy regularly to ensure that you are aware of its terms.

If you have questions concerning this privacy policy, please email [email protected].