Notice Relating to Personal Data Privacy (“Notice”)

Protecting your personal data

CMG (Asia Pacific) Limited, CMG Wealth Management Pte. Ltd., and CMG Fiduciary Services Limited (collectively, the “Company”) is committed to protecting your personal data in accordance with applicable privacy laws and regulations in the jurisdictions where we operate, including the following (where applicable):

  1. Hong Kong: The Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO“); and
  2. Singapore: The Personal Data Protection Act 2012 (“PDPA“)

If your personal data is collected, processed, or stored in either Hong Kong or Singapore, it will be handled in full compliance with the relevant jurisdiction’s privacy laws and principles.

The Company collects your personal information to provide you with our professional services, which may include one or more of the following services (“Services”), where applicable:

  • Investment advisory services;
  • Discretionary investment management;
  • Fund management;
  • Transaction advice;
  • Investment research and analysis;
  • Trust advisory services;
  • Fiduciary and corporate secretarial services;
  • Any other services requested by you in writing from time to time, subject to applicable regulatory permissions.

You hereby authorise and consent to us and our officers, employees, representatives, agents, service providers and any other persons who by reason of their scope of work, capacity or office have access to Client Information (as defined below), collecting, using, disclosing, transferring and processing all and any information and data relating to you and/or any of your authorised person(s)  (including but not limited to, personal data, information and particulars relating to you and/or any of your authorised person(s), details of your account(s) (whether held alone or jointly, or via any corporate entit(ies)) (collectively, the “Accounts”), your credit standing and financial position, your transactions, your use of our Services, and your relationship with us) (collectively “Client Information”) for the purposes listed below (the “Purposes”)

  1. to manage your relationship with us;
  2. assessing and processing any application to open any account with us, any requests for any Services and/or any instructions we receive from you;
  3. verifying your identity, conducting background and credit checks and verifying your ongoing credit worthiness from time to time;
  4. to set up, close, maintain (including updating transactions of) or operation of your Account(s);
  5. providing the Services or any transactions requested or authorised by you;
  6. to collect any amounts due from you;
  7. communicating with you, including providing you updates on changes to the Account(s) and/or Services including the changes to the terms and conditions relating thereto;
  8. supporting any statements made in any documents in connection with the Services of the Company;
  9. assisting other relevant parties, including professionals, institutions, or relevant regulatory authorities, to verify information in connection with the Account(s) and/or Services where required;
  10. complying with any laws and regulations, and any rules, orders, rulings, notices, directives, guidelines, circulars, practice directions and/or codes issued by any governmental or regulatory authority (including without limitation, any relevant stock exchange, clearing house or securities council) or any court or tribunal with competent jurisdiction, whether in Hong Kong, Singapore or elsewhere, including without limitation to make disclosures of Client Information to regulators, governmental bodies, tax authorities, or industry-recognized bodies such as exchanges, clearing houses, securities and banking associations and credit reference agencies, all of which may be within or outside Hong Kong and/or Singapore;
  11. without limitation to sub-paragraph (j) above, complying with any obligations, requirements, or arrangements that the Company has or may have in the future with local or foreign regulatory or tax authorities, whether imposed by law or assumed by them for the protection of their financial, commercial, or other legitimate interests in or related to such jurisdictions, including but not limited to compliance with obligations binding on the Company;
  12. without limitation to sub-paragraph (i) or (j) above, taking any action, we deem required or appropriate in relation to any Financial Crime or Sanctions Compliance;
  13. managing the Company’s infrastructure and business operations and complying with the Company’s internal policies and procedures;
  14. establishing whether you are a citizen of the United States, resident of the United States for its federal income tax purposes, or otherwise subject to tax in the United States and/or to substantiate whether your account has US status for the Foreign Account Tax Compliance Act of the United States of America (“FATCA”);
  15. establishing your reporting status for the Automatic Exchange of Financial Account Information (“AEOI”). The Company is required to identify financial accounts held by tax residents of reportable jurisdictions or held by passive non-financial entities whose controlling persons are tax residents of reportable jurisdictions in accordance with due diligence procedures.
  16. enforcing or defending our legal rights, drafting and reviewing documents, obtaining legal or other professional advice, facilitating dispute resolution and any other legal or similar purposes;
  17. handling client feedback or complaints;
  18. for our operational requirements (including, without limitation, financial reporting, regulatory reporting, management reporting, risk management, system or product development and planning, insurance, audit, record keeping and administrative purposes);
  19. facilitating any proposed or actual business assignment, transfer, participation or sub-participation in any of our rights or obligations in respect of our relationship with you;
  20. conducting market research, surveys and data analysis relating to any Account or Service provided by us which may be relevant to you; and 
  21. any other purposes reasonably related or incidental to any of the above.   

Further, you authorise and consent to us and our officers, employees, representatives, agents and service providers undertaking the following:

  1. where required under certain circumstances and for the Purposes, to disclose and transfer the Client Information to the service providers, agents, affiliates, associates and/or business partners of the Company, whether in or outside of Hong Kong and/or Singapore, for any of the Purposes; and
  2. without prejudice to the generality of the foregoing, to disclose to any exchange, market, clearing house, depository or depository agent or any other relevant person any and all information on you, your account(s) and your transactions including (i) such information as may be necessary to monitor any foreign ownership or other limits imposed by or on an issuer of capital markets products on the holding of any capital markets products and (ii) such information as may be required to fulfil any statutory obligation imposed on the exchange, market, or clearing house or under any applicable laws and regulations.

Failure to supply Client Information may result in the Company being unable to open or continue accounts or establish, continue, or provide Services to you.

Investment Information Provision

You hereby authorise and consent to us and our officers, employees and representatives undertaking the following:

  1. to provide you with marketing, advertising and promotional information, materials and/or documents relating to the investment products and/or services that we or our affiliates, associates or business partners may be offering or managing, whether such products or services exist now or are created in the future; and
  2. to send you such marketing, advertising and promotional information, materials and/or documents through the following modes of communication: (i) postal mail and/or email to your email address; and (ii) to your telephone number(s) by way of voice, text (SMS/MMS), fax, smart phone applications such as but not limited to Whatsapp. Viber, Line, WeChat and Telegram.

If you provide us with any Client Information (including Personal Data) of any individual (other than your own, if you yourself are an individual), you hereby consent on behalf of that individual, to our collection, use, disclosure and processing of Client Information (including Personal Data) relating to him/her in accordance with this Notice and for the Purposes. You warrant that you have obtained that individual’s prior consent to such collection, use, disclosure and processing of Client Information (including Personal Data) relating to him/her by us and that the Client Information (including Personal Data) relating to him/her that you provide to us is true, accurate and complete.

Client Rights

You have the right to:

  1. Check whether the Company holds data about you;
  2. Request corrections to any inaccurate data; and
  3. Ascertain the Company’s policies and practices regarding Client Information.

You understand that you are entitled to withdraw your consent for the collection, use and disclosure of all or any part of your Client Information (including Personal Data) for one or more Purposes at any point in time by notifying us in writing.

Updates to this Notice

The Company may update this Notice from time to time and provide written notice to you regarding any changes.

We strongly encourage you to review this Notice and contact us with any questions that you may have about the subject. You can reach out to us as follows: