Privacy policy

Introduction

We are committed to protecting the privacy of our clients and visitors to our website. This policy is intended to set out the basis upon which any personal data or information that we compile, or that you provide to us, may be collected and processed by (or on behalf of) us.

Who we are:

Personal information held about you

We collect personal information from you during our business, including when you contact or request information from us, you engage our services, or as a result of your relationship with one or more of our clients.

The types (categories) of personal information we will hold about you include:

• Information establishing your identity (for example, name, residential and work addresses, phone number, email address, date of birth, copies of identification documents) and publicly available information (which may include information relating to your family and associates)

• where you are a corporate client or where relevant to your organisational structure, details about persons with an interest in or connection to you, including shareholders, partners, trustees, settlors, protectors, enforcers, beneficiaries, staff and corporate contacts

• any other information relating to you which you may provide to us

• sensitive personal information is only collected where it is necessary to provide you with a specific service or you have consented to that collection, for example, where we enquire about dietary requirements when inviting you to hospitality events.

• The information is required to be provided under our contractual terms and to fulfil our statutory and regulatory obligations.

Where you determine not to provide the data or request us to cease processing your data, we may need to discontinue provision of our services to you.

How we will use information about you

We use your information to provide the service for which you have engaged use which includes:

• providing third parties with your information where we identify a need to engage or liaise with the third party in order to deliver the services requested (for example, external legal counsel);

• our own business purposes (for example, issuing invoices, recovering a debt, managing and archiving client matters, conflict checks, assessing and managing our operations and risks, and bringing or defending any dispute or litigation concerning the services provided to you); and

• fulfilling our legal and/or regulatory and/or financial and/or other reporting obligations, including in relation to anti-money laundering and countering the financing of terrorism.

• We may confirm some of the information you provide to us with external sources, through open-source information (via the internet) or consulting public registers or a client that is a company and to which you are connected.

We may also acquire information about you from other organisations to ensure the information is accurate, up to date and to prevent or detect crime. This may include a client to which you are connected, for example, as a director, beneficial owner or officer.

People who contact us by telephone

When you call us and elect to leave a voicemail, we will retain this voicemail on our systems in accordance with our data retention procedures.

People who email us

Any email sent to us, including any attachments, is checked for reasons of security and monitoring purposes. Email monitoring or blocking software is also used.

People who make a complaint to us

If you make a complaint to us, your contact details, the nature of your complaint and sufficient information to enable us to confirm your identity will be retained on our systems in line with our data retention procedures.

Sharing your information

The information we collect about you will not be transferred to or stored outside Singapore (or a jurisdiction with equivalent data protection requirements) unless it is to support provision of the service you have requested.

We share personal data with other legal or professional advisers used by us to provide you with services.

We may disclose or transfer your information for the purposes set out in this privacy policy to:

• our employees, agents and service providers, who are required to maintain the confidentiality of this information;

• companies and organisations that assist us to provide the services for which you have engaged us;

• regulatory, police or law enforcement authorities and fraud prevention agencies, where we are compelled or permitted or required to do so by order of a court or governmental or administrative tribunal, or by law, regulation or any other legal requirement; or

• any other person where disclosure is made at your request or with your consent.

Protecting and storing your information

The information we collect about you is stored under our control and with our selected archive and data backup service providers.

We have put in place security procedures, plus technical and organisational measures that we consider appropriate to safeguard your personal information and which are intended to defend against unauthorised or unlawful access to, or alteration, disclosure or destruction of, personal data and against accidental loss or destruction of or damage to personal data. Access to internal data servers is limited to specialist personnel and is controlled using defined policies.

We will only retain the information gathered for as long as is necessary, having regard to relevant laws and regulations and our data retention procedures. Such information may be retained after a matter has been closed, and for client identification purposes in accordance with our data retention procedures.

Access to your information and correction

If you would like access to some or all of the personal information, we hold about you please e-mail or write directly to contact@ultero.com

You may ask us to correct, remove or cease processing information if you think it is inaccurate or where you wish us to discontinue provision of services.

If you agree, we will try to deal with your request informally, for example, by providing you with the specific information you need over the telephone.

We may ask for certain personal information when you contact us in order to confirm your identity.

Complaints

Should a situation arise where you feel the need to complain about how we process and/or retain your data, we request that you contact us so we may address your concerns.