Data Protection Policy

This Data Protection Policy applies to all personal data collected by China Merchants Bank Co.,Ltd (Singapore Branch), its related entities, affiliates and subsidiaries (individually and collectively, "CMBSG") under Clause 1 below.

For the purpose of this Policy, “we”, “our” and "us" shall refer to CMBSG.

Personal data is defined under the Personal Data Protection Act (“PDPA”) as data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access. It may include the individuals' name, address, identification number, telephone number, financial records, credit card information, photographs and video images, etc.

1. When we will collect personal data from you

We may collect personal data from you:1.1. When you register for or use any services owned and/or operated by us;
1.2. When you take part in any survey or promotion conducted by us and/or our business partners; and
1.3. When you enquire on services owned and/or operated by us, or hosted by us on behalf of our business partners.

We will collect your personal data in accordance with the PDPA. In general, unless otherwise required or permitted by law, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes.

If you provide data to us about another person (such as a joint account holder, trustee, beneficiary or guarantor) you must ensure that you have obtained consent from such person and that you have proof of these consents. You must provide us with such proof if we request for it.

2. Purposes for which we will collect, use and disclose your personal data

Personal data which we collect from you may be used and disclosed by us to our affiliates and business partners (who may be based outside Singapore) and other third parties for the following purposes:

2.1. to respond to your requests and queries, and understand your financial needs;
2.2. to provide goods and services to you;
2.3. to facilitate and/or process your transactions with us;
2.4. to verify and process your personal particulars and payments;
2.5. to facilitate processing, dealing with, administering, managing and/or maintaining your relationship with us;
2.6. to carry out your instructions;
2.7. to communicate with you;
2.8. to enforce contractual and legal rights and obligations;
2.9. to update and enhance CMBSG’s records;
2.10. to conduct (or assist other financial institutions to conduct) credit checks or review credit worthiness;
2.11. for marketing research, user profile and statistical analysis;
2.12. to send you information, promotions, updates, and marketing or advertising materials in relation to our goods and services;
2.13. for complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which we are expected to comply;
2.14. for any other purposes for which we have obtained your consent, including during the registration process under our KnowYourCustomer ("KYC") Terms and Conditions;
2.15. to conduct customer due diligence and personal identification in accordance with laws, regulations and policies including our internal policies;

2.16. to achieve any other incidental business purposes related to or in connection with the above.

3. Transfer of Personal Data

In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to third parties, including law enforcement and financial sector regulatory authorities, our third-party service providers, agents and/or our affiliates or related corporations, which may be sited outside of Singapore, for one or more of the above-stated purposes. This is because such third-parties would be using or processing your personal data on our behalf for one or more of the above-stated purposes.

4. Withdrawal of Consent

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control anytime by submitting your request to the contact details listed below:

(a) Singapore telephone number: +65 6786 7888.
(b) E-mail: pdpasg@cmbchina.com
(Attention to the Data Protection Officer)
(c) Office address: 1 Raffles Place #32-61, One Raffles Place Tower 2 Singapore 048616
(Attention to the Data Protection Officer)

We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request.

Please note that by withdrawing your consent for the collection, use and/or disclosure of your personal data by us, our ability to provide services to you may be affected, and we may become unable to provide part or all of our services to you depending on the extent of your withdrawal.

5. Access and Correction

You may request for access to or correction of your personal data currently in our possession at any time by submitting your request through the following methods.

CMBSG will have to verify your identity first before providing you with access to the personal data or correcting such personal data. We may charge you a reasonable fee for processing your request for access. We may be unable to provide you access to some data in certain situations. If so, we would explain why not unless it is not lawful to inform you so.

6. Complaints

If you have any complaint or grievance regarding how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

Please contact us through one of the following methods with your complaint or grievance:

Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in CMBSG to handle. For example, you could insert the subject header as “PDPA Complaint”.

We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

7. Retention

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the personal data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

8. Transfer of your personal data

Where personal data is transferred by us to any third parties outside of Singapore, we will ensure that such transfers are compliant with the requirements under the PDPA. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the PDPA.

9. Amendments and Update

We reserve the right to amend this Data Protection Policy at any time and will place any such amendments on this Web Site. You are encouraged to visit our Web Site from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

November 2022