Privacy Notice

Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how Lazard Asset Management (Singapore) Pte. Ltd manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us or submitting information to us you agree and consent to Lazard Asset Management (Singapore) Pte. Ltd, its related corporations and affiliates, (collectively referred to herein as "Lazard", "us", "we" or "our"), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Lazard’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to Lazard nor does it affect any rights which Lazard may have at law in connection with the collection, use or disclosure of your Personal Data. Lazard may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Site. Please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the Site T&Cs. In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Site T&Cs, the Privacy Policy shall prevail.

All defined terms contained in the Site T&Cs shall apply to this Privacy Policy unless otherwise specifically stated.

Your Personal Data

In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):

 

i. your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

ii. information about your use of Lazard’s Site and services, including cookies, IP address, subscription account details and membership details, but only to the extent that Lazard may identify you from such information;

iii. information about your usage of and interaction with our Site and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Site.

Collection of Personal Data

Generally, Lazard collects your Personal Data in the following ways:

 

i. when you submit forms relating to any of our products or services;

 

ii. when you register for or use any of our services on the Site or when you register as a member of Site owned and/or operated by us, or use services on the Site;

 

iii. when you request that we contact you;

 

iv. when you are contacted by, and respond to, our representatives;

 

v. when you respond to our request for additional Personal Data;

 

vi. when you ask to be included in an email or other mailing list; and

 

vii. when you submit your Personal Data to us for any other reason.

 

When you browse our Site, you generally do so anonymously but please see the section below on cookies.

 

If you provide us with any Personal Data relating to a third party (e.g. information of dependents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

 

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

 

Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, Lazard collects, uses and discloses your Personal Data for the following purposes:

i. responding to your queries, resolving complaints and handling requests and enquiries;

ii. to verify and process your personal particulars in relation to your account with us;

iii. conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you;

iv. carrying out the necessary due diligence and background checks;

v. providing information about investment products and services in accordance with the Lazard’s internal rules and regulations;

vi. communicating with you to inform you of changes and development to Lazard policies, terms and conditions and other

vii. administrative information, including for the purposes of servicing you in relation to products and services offered to you;

viii. provision of products and other services as may be agreed to between the client and Lazard;

ix. preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;

x. conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;

xi. compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

xii. facilitating business asset transactions (which may extend to any merger, acquisition or asset sale); and/or

xiii. purposes reasonably related to the aforesaid.

In addition, Lazard may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

i. If you are a subscriber to one of our collective investment schemes:(collectively, the “Purposes”)

a. carrying out investment management activities and mandates (including but not limited to (a) allotting and transferring interests in

collective investment schemes or accounts; (b) record keeping);

b. providing the client information about their account (including by the issue of statements) and updating the client from time to time in relation to the products or services which they may have applied for; and/or

c. purposes reasonably related to the aforesaid.

In addition, where permitted under the Act, Lazard may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):

i. sending you details of products, services which may be of interest to you; and

ii. conducting market research for us to review, develop and improve our products and services.

In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

 

Disclosure of Personal Data

Lazard will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

i. our agents;

ii. authorized service providers who provide operational services such as telecommunications, mailing houses, information technology, payment, data processing, archival or other services;

iii. professional advisors such as our auditors and lawyers;

iv. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

v. anyone to whom we transfer or may transfer our rights and duties;

vi. relevant government regulators or authorities or law enforcement agencies to comply with any applicable laws, rules, regulations or guidelines;

vii. any other person in connection with the Purposes; and

viii. any other person to whom you may authorise disclosures.

Cookies

 

We collect information using "cookies" on the Site for the purposes of operating an efficient online service and tracking the patterns of behaviour of visitors to the Site. Although you can usually modify your browser to prevent cookie use, if you do this, the Site may not work properly for you.

 

Third-Party Sites

Our Site may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Site. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our Site, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

 

Governing Law

This Privacy Policy shall be governed in all respects by the laws of Singapore.

 

How to contact us

If you wish to withdraw your consent to any use of your Personal Data as set out in this Policy, or if you have any questions or complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records, please contact Lazard’s designated Data Protection Officer at:

 

Data Protection Officer
Lazard Asset Management (Singapore) Pte. Ltd.
1 Raffles Place
#15-02 One Raffles Pace Tower 1
Singapore 048616
email: DataProtectionOfficer.SG@Lazard.com

 

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