Singapore Privacy Notice
Banking Circle Singapore Pte. Ltd. | Personal Data Protection Act 2012 (PDPA) | Version 1.0 |
Last Updated: June 2026
Contents
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- General Information
- Your situation
- Make an enquiry about our services
- Make a complaint
- You are the ultimate beneficial owner and/or legal representative of one of our clients or prospects
- You are the payer or beneficiary of a payment executed via Banking Circle’s infrastructure or their ultimate beneficial owner
- You are the borrower under a loan agreement entered into with Banking Circle or an ultimate beneficial owner of the borrower
- Apply for a job
- You are or represent a third-party contractor of Banking Circle
- You are the person of contact of an employee of Banking Circle
- Respond to our consultation requests and surveys
- Attend an event, seminar or workshop
- Subscribe to our newsletters
- Request our white papers or other publications
- You are a visitor to our offices
- You are an investor in Banking Circle
- How do you get in touch with us?
- How do you make a complaint?
1. General Information
Banking Circle S.A. and its affiliated companies and subsidiaries (“Banking Circle”, “we”, “us”, “our”) are committed to protecting your privacy. As a global company, Banking Circle has offices, branches and subsidiaries in different jurisdictions that may independently collect personal data, or process personal data on behalf of other Banking Circle entities.
In Singapore, Banking Circle operates through Banking Circle Singapore Pte. Ltd. (“Banking Circle Singapore”, “BCSG”, “we”, “us”, “our”). For matters relating to the handling of your personal data in Singapore, the relevant regulator is the Personal Data Protection Commission (“PDPC”). Please see the “How do you make a complaint?” section of this notice for further information.
This privacy notice explains how Banking Circle Singapore Pte. Ltd. collects, uses, discloses and protects personal data in connection with our Singapore business activities. It also explains your rights and how to contact us.
Please read this notice together with any other privacy or collection notice we may provide when we collect personal data from you.
We will update this notice from time to time. The latest version date appears at the top of this page.
What is our role when handling your personal data?
Under the PDPA, we are responsible for personal data in our possession or under our control, including personal data processed for us by service providers where required by Singapore law.
Under the PDPA, this generally means we are responsible for:
- notifying individuals of the purposes for which we collect, use or disclose their personal data, and handling personal data only for purposes that a reasonable person would consider appropriate in the circumstances;
- obtaining consent where required under the PDPA, or relying on an applicable exception, and allowing individuals to withdraw consent on reasonable notice where the law requires;
- taking reasonable steps to ensure personal data is accurate and complete where it is likely to be used to make a decision affecting an individual or disclosed to another organisation; and
- protecting personal data with reasonable security arrangements, retaining it only as long as necessary, and ensuring comparable protection where personal data is transferred outside Singapore.
When we use service providers, we require them to protect personal data and process it only for authorised purposes and in line with our instructions, where applicable.
What rights do you have over your personal data?
You have certain rights we need to make you aware of.
To exercise any of the rights described below, please contact us at:
Email: privacy@bankingcircle.com
We may need to verify your identity before processing your request.
Your right of access
You may ask for a copy of the personal data we hold about you and information about how we have used or disclosed it in the year before your request, subject to legal exceptions.
How to request access
The quickest and most efficient way to express this right:
Email us at privacy@bankingcircle.com with your full name, what information you are looking for, and any relevant dates or reference numbers.
We will verify your identity first. We will respond within one month from the date your identity has been verified. A reasonable fee may apply to access requests where permitted by law.
If you are dissatisfied with our response, you may contact us again for further review or make a complaint to the PDPC. See the “How do you make a complaint?” section below.
Your right to correction
If you believe your personal data is inaccurate or incomplete, you may ask us to correct it. Where required, we will make the correction as soon as practicable.
Your right to withdraw consent
Where we rely on your consent, you may withdraw it by giving us reasonable notice. This may affect our ability to provide certain products, services or information to you.
Your right to lodge a complaint
If you have a concern about how we handle your personal data, please contact us first. You may also make a complaint to the PDPC in Singapore.
Key PDPA information about personal data we hold
Here is a quick summary of the personal data we may hold and how we use it.
Categories of personal data: contact details, identity information, business relationship details, transaction data, compliance and due diligence records, correspondence, marketing preferences, and security logs.
How we use personal data: to provide and improve services, manage enquiries and complaints, meet legal and regulatory obligations, maintain security, and send communications where permitted.
How to make a request: email privacy@bankingcircle.com with your name, contact details and enough information for us to identify your request.
Fees: We do not usually charge a fee for requests. A reasonable fee may apply where permitted by the PDPA, and if so, we will let you know before processing the request.
Who do we share your personal data with?
We do not share personal data with third parties for their own direct marketing.
We use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
Some personal data may be transferred outside Singapore, including within the Banking Circle Group and to service providers. Where this happens, we take steps required by the PDPA to ensure comparable protection.
We may also share personal data within the Banking Circle Group for operations, compliance, risk management and administration.
We may disclose personal data where required or permitted by law, regulation, court order or a request from a competent authority.
For more information about key service providers, please see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use.
How do we protect your personal data?
We use organisational, technical and physical security measures to protect personal data from unauthorised access, loss, misuse and disclosure. These measures include access controls, policies, procedures, staff training and incident response processes.
Where third parties process personal data for us, we require them to apply appropriate confidentiality and security measures.
Do we use any automated processing of your personal data?
We use automated tools, including profiling, to support anti-money laundering, counter-terrorist financing and sanctions screening.
Where appropriate, alerts or risk indicators generated by these tools are reviewed by relevant personnel before follow-up action is taken.
2. Your situation
Choose the section below that best matches your relationship with Banking Circle.
Make an enquiry about our services
Purpose of collection, use and disclosure
When you contact us to make an enquiry, we collect information, including your personal data, so that we can respond to it.
We process your personal data based on your consent.
What we need
We need enough information from you to answer your enquiry. If you contact us via email, we’ll need a return address for response. We also merge this information with engagement touchpoints you have had with us, to help us measure and optimise the marketing information that you consent to receive.
What we do with it
We’ll set up a file on our system to record your enquiry and so we can get it to the correct area of the business to be dealt with. We’ll also keep a record of our response. We use the information supplied to us to deal with the enquiry.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. In most cases, this means that personal data is deleted or anonymised no later than 12 months after the relevant purpose has been fulfilled, unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA.
Make a complaint
Purpose of collection, use and disclosure
When you contact us to make a complaint, we collect information, including your personal data, so that we can respond to it and fulfil our regulatory responsibilities.
As a regulated bank, we are required by financial regulation to record and respond to complaints. Where we use complaint data to improve our services internally, we rely on our legitimate interests in maintaining service quality.
What we need and why we need it
We need information from you to investigate your complaint properly such as name, address, issue you have experienced with our services.
When we receive a complaint from you, we’ll set up a case file. This normally includes your contact details and any other information you have given us about the other parties in your complaint such as the beneficiaries of your payments.
We need to know the details of your complaint so we can investigate it and fulfil our regulatory obligations.
What we do with it
We will use your personal information to investigate your complaint. We compile and share statistics showing information like the number of complaints we receive with our regulatory supervisory authorities, but not in a form that identifies anyone.
No third parties have access to your personal information unless the law allows them to do so.
However, if you have made a complaint related to the provisions of services by one of our clients or their customers, we usually have to disclose your identity to them. This is so we can clearly explain to them what you think has gone wrong and they can handle your complaint directly. This also means we may receive information about you from them.
If you are acting on behalf of someone making a complaint, we’ll ask for information to satisfy us of your identity and if relevant, ask for information to show you have authority to act on someone else’s behalf.
How long we keep it
We retain personal information only for as long as necessary for the purposes which it is processed. In most cases, this means that personal information is deleted or anonymised no later than 10 years following termination of the relationship with our clients, unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA. You may request further details by contacting privacy@bankingcircle.com.
You are the ultimate beneficial owner and/or legal representative of one of our clients or prospects
Purpose of collection, use and disclosure
When we enter into a business relationship with our clients, we collect information, including your personal data, so that we can comply with our AML/CFT due diligence obligations on them.
We also ensure that the person deciding to enter into business relationship with us on behalf of our clients and signing the contractual arrangement we have with our clients are duly authorised as legal representative to make such decision on behalf of our clients.
We collect your personal data when this is necessary to comply with any applicable anti-money laundering and counter terrorism financing (AML/CTF) laws we are subject to as a regulated credit institution.
What we need
- Full name
- Address
- Salutation (if applicable)
- Maiden name (if applicable)
- Date of birth
- Place of birth
- Nationality
- Proof of residency
- Proof of identity
- Proof of ID number i.e. (passport number)
- Job position
- TIN
- Tax residency
- Criminal convictions and offences
Why we need it
For the purpose of identifying the true beneficial owners and legal representatives of our clients and comply with our Know your Clients obligations under any applicable anti money-laundering and counter terrorism financing (AML/CTF) laws we are subject to as regulated credit institution.
To satisfy our reporting obligation to the tax authorities under tax cooperation treaty with the United States or other countries of the OECD.
To monitor any adverse media information associated with our clients.
What we do with it
We collect and retain your personal information in our client relationship management system to document the compliance with our legal obligations under any applicable anti money-laundering and counter terrorism financing laws we are subject to as regulated credit institution.
We process your data through our adverse media screening tool.
We may be obliged to share your personal information as part of a report regarding any suspicious activity or transactions on clients’ activity to our regulatory supervisory authorities in countries where we operate our activities. We may also share your personal information with our correspondent institutions involved in the payment chain upon request.
No other third parties may however have access to your personal information unless the law allows them to do so.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. In most cases, this means that personal data is deleted or anonymised no later than 10 years following termination of the relationship with our clients, unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA. You may request further details by contacting privacy@bankingcircle.com.
You are the payer or beneficiary of a payment executed via Banking Circle’s infrastructure or their ultimate beneficial owner
Purpose of collection, use and disclosure
When we receive or make a payment from or to you for our clients and their customers, we collect information, including your personal data, so that we can fulfil our regulatory obligations.
When you contact us to make an enquiry regarding a payment you have sent to or receive from us, we collect information, including your personal data, so that we can respond to it.
We collect your personal data when this is necessary to comply with a legal obligation under any applicable anti-money laundering and counter terrorism financing (AML/CTF) laws we are subject to as regulated credit institution, and your consent.
What we need and why we need it
Your name and address, bank account as well as transaction details.
- For the purpose of detecting financial crimes patterns or criminal behaviour in payment transactions;
- For the purpose of screening the same transactions against sanction lists published by governmental organisations in the countries where we operate our activities as regulated credit institution.
- For the purpose of passing on information to our correspondent institutions involved in the payment chain.
- For reporting to local supervisory authorities where applicable the true identity of the ultimate beneficial owner of a payment.
If you have made a query related to a payment sent by our clients or their customers, we’ll keep a record of your enquiry and so we can get it to the correct area of the business to be dealt with. We’ll also keep a record of our response. We use the information supplied to us to deal with the enquiry.
We usually have to disclose your identity to our clients. This is so we can clearly explain to them what you think has gone wrong and they can handle your query directly. This also means we may receive information about you from them.
What we do with it
We collect and retain your personal data in our transaction platforms to document the transactions performed for our clients and their customers. We compile and share statistics showing information like the number of payments we receive with our regulatory supervisory authorities, but not in a form that identifies anyone.
We use your personal data as well as any other information identifying you as payer or as beneficiary of a payment and any information related to the transactions underlying the payment we receive to feed, evaluate and further develop our transaction monitoring and sanction screening tool or applications to provide assurance that we have effective processes to identify, manage, monitor and report money laundering and terrorism financing risks we are or might be exposed to.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. In most cases, this means that personal data is deleted or anonymised no later than 10 years following its collection, unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA. You may request further details by contacting privacy@bankingcircle.com.
You are the borrower under a loan agreement entered into with Banking Circle or an ultimate beneficial owner of the borrower
Purpose of collection, use and disclosure
When we enter into a business relationship with our clients, we collect information, including your personal data, so that we can comply with our AML/CFT due diligence obligations.
In order to pay out the loan to you, we collect information, including your personal data, so that we can fulfil our contractual obligations.
We collect your personal data when this is necessary to comply with a legal obligation under any applicable anti money-laundering and counter terrorism financing (AML/CTF) laws we are subject to as regulated credit institution.
What we need and why we need it
- Full name
- Address
- Salutation (if applicable)
- Maiden name (if applicable)
- Date of birth
- Place of birth
- Nationality
- Proof of residency
- Proof of identity
- Proof of ID number i.e. (passport number)
- Job position
- TIN
- Tax residency
- Criminal convictions and offences
For the purpose of detecting financial crimes patterns or criminal behaviour in payment.
For the purpose of identifying the true beneficial owners and legal representatives of our clients and comply with our Know your Clients obligations under any applicable anti money-laundering and counter terrorism financing (AML/CFT) laws we are subject to as regulated credit institution.
To monitor any adverse media information associated with our clients.
To disburse the loan amount to your bank account.
What we do with it
We collect and retain your personal data in our client relationship management system to document the compliance with our legal obligations under any applicable anti money-laundering and counter terrorism financing laws we are subject to as regulated credit institution.
We process your data through our adverse media screening tool.
We may be obliged to share your personal data as part of a report regarding any suspicious activity or transactions on clients’ activity to our regulatory supervisory authorities in countries where we operate our activities. We may also share your personal data with our correspondent institutions involved in the payment chain upon request.
No other third parties may however have access to your personal data unless the law allows them to do so.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. In most cases, this means that personal data is deleted or anonymised no later than 10 years following termination of the relationship with our clients, unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA.
Applying for a job
Purpose of collection, use and disclosure
We collect, use and disclose your personal data to assess suitability for a role you have applied for and to help us develop and improve our recruitment process thereby enhancing your experience and journey as well as to protect the interests of Banking Circle and its clients.
Where we process information about applicants’ criminal convictions and offences as part of the pre-employment screening, we do so to comply with our legal obligation as a regulated institution, under the specific authority provided by the PDPA.
What we need at the application stage
- Email address
- Full name
- Country
- Address
- Postal code/city
- Gender
- CV
- Mobile (incl. area code)
What we do with it
If you use our online application system, your details will be collected by our data processor Talentech (which runs the platform, Talent Recruiter) on our behalf. We ask you for your personal details including name and contact details. We’ll also ask you about previous experience, education, referees and for answers to questions relevant to the role. Our recruitment team and hiring team designated to each role will have access to all this information.
Why we need it
The information we ask for is used to assess your suitability for employment. You don’t have to provide what we ask for but it may affect your application if you don’t. We will keep your data on file for 12 months to evaluate your candidacy for our other open roles. You can at any time exercise your rights to see what information we hold and request its erasure by sending an email to privacy@bankingcircle.com.
We will use any feedback you provide about our recruitment process to develop and improve our future recruitment campaigns.
Recruitment process
Our hiring managers and recruitment partners review and shortlist applications for interview.
We may ask you to attend an interview and/or participate in assessments or case studies. Information will be generated by you and by us. For example, you might complete a written test or we might take interview notes. This information is held by us.
If you are unsuccessful after assessment for the role, we would like to keep you on file in our talent pool for up to 12 months, in case other suitable roles arise. If you do not wish to stay in the talent pool you can at any time exercise your rights to see what information we hold and request its erasure by sending an email to privacy@bankingcircle.com.
Conditional offer
If we make a conditional offer of employment, we’ll ask you for information so that we can carry out pre-employment checks. You must successfully complete pre-employment checks to progress to a final offer. We must confirm the identity of our staff and their right to work, and seek assurance as to their trustworthiness, integrity and reliability.
You must therefore provide:
- proof of your identity – you will be asked to send us copies of identification documentation
- proof of your qualifications – you will be asked to send us copies of diplomas or other relevant documentation
- proof of right to work (if applicable) – you will be asked to send us copies of work permit(s) and visa documentation
- a criminal records declaration to declare any unspent convictions and/or to provide a copy of an up-to-date criminal record, as applicable
- a declaration on no outside business interest (we will provide you with a template)
- proof of residence – in certain jurisdictions we may ask you to send us evidence of your current address.
Further to the above, we may carry out certain background checks to further assess your character and fitness for the job offered. We will not carry out any background checks without your prior consent. The background checks we carry out depend on the job position offered, but may involve credit checks, litigation checks including past or pending civil or criminal proceedings against candidates, sanctions screenings and adverse media checks.
We will ask you to provide us with references as part of the background check. Once you have sent us their contact information we will reach out to directly and obtain the reference. Depending on the location of the job position we’ll also ask you to complete a questionnaire about your health to establish your fitness to work.
Any documents that you share with us electronically will be shared on a secure connection via a link that we provide to you.
Do we use any data processors and transfer your data internationally?
Yes we use Talentech to assist in the recruitment process and AlvaLabs for recruitment tests. We also use PeopleHR (People Apps Limited) for our HR Management process. For more information, please see People HR’s privacy notice.
We also use Experian Ltd to run background checks. For more information, please see Experian’s privacy notice.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed.
If you are employed by us, for the duration of your employment and then for a further period of up to 5 years, after which the information will normally be deleted.
If you are an unsuccessful applicant, for up to 12 months after your application, after which we will delete it unless we have agreed otherwise with you or we have a legal obligation to store such data longer.
How we make decisions about recruitment
Final recruitment decisions are made by hiring managers and members of our recruitment team. We take account of all the information gathered during the application process.
You can ask about decisions on your application by speaking to your contact in our recruitment team.
You are or represent a third-party contractor of Banking Circle
Purpose of collection, use and disclosure
We collect information to assess your suitability for the services you or your company will provide as well as to protect Banking Circle and its clients against any fraud.
We collect your personal data when it is necessary to perform a contract or to take steps at your request, before entering a contract.
We process information about you as representative of a third-party contractor or you as third party contractor’s criminal convictions and offences and other background checks. We process this data pertains to complying with a legal obligation we are subject to as regulated institution and of the legitimate interests of Banking Circle and its clients.
What we need
- Full name
- Title
- Address
- CV
- VAT number
- Contact information
- Bank account holding statement
Further to the above, we may carry out certain background checks to further assess your character and fitness for the service to be provided. The background checks we carry out depend on the required service, but may involve the following:
- Fitness and Propriety declaration (including credit issues, directorships and convictions)
- Credit/financial information
- Information pertaining to a sanctions screening
- Publicly available adverse news articles and information
- Current and previous director appointments and information on disqualifications
- Information on civil litigation and bankruptcy
What we do with it
We’ll use all the information you provide during the supplier selection process to progress yours and/or your company engagement with a view to enter into an engagement letter/consultancy agreement with you or your company, or to fulfil legal or regulatory requirements if necessary.
We will not share any of the information you provide with any third parties for marketing purposes.
We’ll use the contact details you give us to contact you to progress yours and/or your company’s engagement. We may also contact you to request your feedback about our supplier selection process. We’ll use the other information you provide to assess your suitability for the provisions of the services.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. In most cases, this means that personal data is deleted or anonymised no later than 5 years after end of contract, unless a longer retention period is required by law or regulatory obligations.
Why we need it
The information we ask for is used to assess your suitability for the provision of the services. You don’t have to provide what we ask for but it may affect yours and your company’s engagement if you don’t.
We will use any feedback you provide about our supplier selection process to develop and improve our process.
Do we use any data processors and transfer your data internationally?
We use Experian Ltd to run background checks. For more information, please see Experian’s privacy notice.
For a list of our main data processors that may process your personal information as part of the services they provide to us see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some of these processors are located, or host the data, outside Singapore, which means that your personal information may be transferred internationally as part of the services they provide to us. In such cases, Banking Circle takes steps required by the PDPA to ensure that the transferred personal data is protected to a standard comparable to the protection under the PDPA.
You are the person of contact of an employee of Banking Circle
Purpose of collection, use and disclosure
We request every employee to provide us with the contact details of a person of contact that we can reach should anything happen to the employee during his or her time at work.
What we need and why we need it
- Full name
- Phone number
- Relationship with the employee
- Address
To contact the employee’s family, should anything happen to the employee during his or her time at work.
We do not collect this information directly from you. It is provided to us by the employee as part of their employment onboarding or HR records.
What we do with it
We use this information solely to contact you in an emergency or urgent welfare situation involving the employee. We will not use your details for any other purpose — including marketing, business development, or any other HR process unrelated to the employee’s welfare.
Your details are accessible only to authorised members of our HR team and, where necessary in an emergency, to relevant managers or medical personnel. No third parties may however have access to your personal data unless the law allows them to do so.
How long we keep it
We retain this personal data for as long as it is reasonably necessary for emergency contact purposes, typically for the duration of the employee’s employment or until the employee updates or removes the emergency contact details, after which it will be deleted or anonymised unless a longer retention period is required by law.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA.
Respond to our consultation requests and surveys
Purpose of collection, use and disclosure
With your consent, we might contact you from time to time to obtain user experience and client satisfaction about Banking Circle user interface or other applications and we process your contact details to get in touch with you.
As a participant in user tests and research about Banking Circle’s user interface, applications and platforms we will ask you to provide certain personal data to be able to contact you, and to verify your profile in the user tests.
What we need and why we need it
- Full name
- Job title
- Work email
- Work phone number
- Behaviour on and thoughts about the user experience
We will process all data provided as part of your participation with the purpose of developing our offerings. As a rule, we will not share any personal data unless agreed upon. We will only publish results or direct quotes including your job role, company and/or name on our website, social media accounts and other externally accessible sources, if agreement with you has been made and consent has been granted.
What we do with it
We process the information internally for the above stated purpose. We don’t intend to share your personal data with any third party. Any specific requests from a third party for us to share your personal data with them will be dealt with in accordance with the provisions of the data protection laws.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. We will retain consultation and survey response information until our work on the subject matter of the consultation is complete and then normally for a period of 2 years after which we will delete it (or anonymise it if it is required for further research after that point), unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers we entrust with handling personal information, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure that the recipient provides a standard of protection comparable to the PDPA.
On our behalf — it will be clear if we are using Surveymonkey. For more information please consult Surveymonkey privacy policy.
Any data collected by Surveymonkey for Banking Circle is stored on servers in the United States.
Attend an event, seminar or workshop
Purpose of collection, use and disclosure
Our purpose for collecting this information is so we can facilitate the event.
We collect your data for the purpose of organising and administering events and following up with attendees. If we contact you about future events or marketing after the event, we will rely on your separate consent. When we collect any information about dietary or access requirements, we also need your consent.
What we need and why we need it
If you wish to attend one of our events, you will be asked to provide your contact information including your name, your organisation’s name and, if offered a place, information about any dietary requirements or access provisions you may need. We may also ask for payment details if there is a charge to attend.
We use this information to facilitate the event. We also need this information so we can contact you.
What we do with it
If you are not successful in securing a place, we’ll let you know and hold your details on a reserve list in case a place becomes available.
If you are allocated places at an event, we’ll ask for information about any dietary/access requirements. We don’t share this information in any identifiable way with the venue, and we delete it after the event.
We don’t publish delegate lists for events.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. As long as reasonably necessary for the purposes of organising the event and then for up to 10 years afterwards, after the relevant purpose has been fulfilled, unless a longer retention period is required by law or regulatory obligations.
What are your rights?
We rely on your consent to process the personal data you give us to facilitate the event. This means you have the right to withdraw your consent at any time. If at any point you want to withdraw your consent please email us at marketing@bankingcircle.com. If you do that, we’ll update our records immediately to reflect your wishes.
For more information on your rights, please see the “What rights do you have over your personal data?” section.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main data processors that may process your personal information as part of the services they provide to us see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some of these processors are located, or host the data, outside Singapore, which means that your personal information may be transferred internationally as part of the services they provide to us. In such cases, Banking Circle takes steps required by the PDPA to ensure that the transferred personal data is protected to a standard comparable to the protection under the PDPA.
We also use data processors to help facilitate the events.
We may sometimes charge a fee to attend an event. If this happens, our communications about the event will provide details of the data processor we use to collect payments.
Subscribe to our newsletters
Purpose of collection, use and disclosure
Our purpose for collecting the information is so we can provide you with a service and let you know about upcoming events.
Where required, we rely on your consent to send you marketing communications. Where relevant communications are sent to Singapore telephone numbers, we also comply with applicable Do Not Call rules.
What we need and why we need it
Your name and email address.
We use your email address to send you our E-newsletter.
What we do with it
We only use your details to provide the service.
We gather statistics around email opening and clicks using industry standard technologies including clear gifs to help us monitor and improve our e-newsletter.
You will receive a confirmation email once you have submitted your details and then the newsletters monthly.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed, consistent with sending you marketing communications, after which we will either confirm that you are happy for us to continue to do so, or delete it (except to the extent we need to retain it for the sole purpose of suppressing further marketing communications to you), unless a longer retention period is required by law or regulatory obligations.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA.
We also use MailChimp to deliver the e-newsletter. For more information, please see MailChimp privacy notice.
Any data collected by MailChimp for Banking Circle is stored on servers in the United States.
Request our white papers or other publications
Purpose of collection, use and disclosure
Our purpose for collecting this information is to carry marketing activities and business development.
We process your personal data based on your consent.
What we need and why we need it
Your name, job position and address details.
So that we can send you the publications you have requested. We also merge this information with engagement touchpoints you have had with us, to help us measure and optimise the marketing information that you consent to receive.
What we do with it
We only use the contact details to provide this service. We run statistical reports on the types and quantities of publications requested for monitoring purposes, but this does not contain any personally identifiable information.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed, consistent with sending you marketing communications, after which we will either confirm that you are happy for us to continue to do so, or delete it (except to the extent we need to retain it for the sole purpose of suppressing further marketing communications to you), unless a longer retention period is required by law or regulatory obligations.
What are your rights?
Where we rely on your consent to send you requested publications or related marketing communications, you may withdraw that consent at any time by emailing us at marketing@bankingcircle.com. If you do that, we’ll update our records immediately to reflect your wishes.
For more information on your rights, please see the “What rights do you have over your personal data?” section.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers we entrust with handling personal information, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure that the recipient provides a standard of protection comparable to the PDPA.
We use WordPress as content management system to deal with some publication requests, but WordPress is only allowed to use the information to send out the publications. For more information please see WordPress privacy notice.
We also use MailChimp to deliver the publication but MailChimp is only allowed to use the information to send out the publications. For more information, please see MailChimp privacy notice.
You are a visitor to our offices
We meet visitors at our head office, including:
- Consultants, advisors and external auditors;
- External training providers;
- Job applicants;
- Suppliers and tradespeople;
- Board members and representatives of our shareholders; and
- Representatives of our regulatory supervisory authorities.
If your visit is planned, we’ll send your name, position and purpose of visit to reception before your visit.
We ask all visitors to sign in and out at reception and show a form of ID. The ID is for verification purposes only, we don’t record this information.
We collect your personal data to maintain the security of our premises and the safety of our staff and visitors. CCTV may operate in or around our premises or shared building areas for security purposes. Where CCTV in common areas is operated by a building owner or manager rather than by us, that operator will be responsible for its own processing.
We have Wi-Fi on site for the use of visitors. We’ll provide you with the address and password.
We record the device address and will automatically allocate you an IP address whilst on site. We also log traffic information in the form of sites visited, duration and date sent/received.
We don’t ask you to agree to terms, just to the fact that we have no responsibility or control over your use of the internet while you are on site, and we don’t ask you to provide any of your information to get this service.
The purpose for processing this information is to provide you with access to the internet whilst visiting our site.
We keep the personal information relating to you for as long as is necessary in order to enable us to provide the relevant services to our client, after which we will delete it. Normally, we will not keep this information for more than 12 months following its collection.
For more information on your rights, please see the “What rights do you have over your personal data?” section.
You are an investor in Banking Circle
Purpose and lawful basis for processing
We will only collect and process personal data about you, which is considered necessary for Banking Circle to comply with its regulatory compliance and corporate governance obligations.
We collect your personal data when this is necessary to comply with a legal obligation. We may also process your personal data on the basis of legitimate interests of Banking Circle as regulated institution.
What we need and why we need it
- Full name
- Address
- Salutation (if applicable)
- Maiden name (if applicable)
- Date of birth
- Place of birth
- Phone number
- E-mail address
- Nationality
- Proof of residency
- Proof of identity
- Proof of ID number i.e. (passport number)
- Social security
- Job position and title
- CV
- Job location
- Work e-mail address
- Work phone number
- TIN
- Tax residency and taxes
- Criminal convictions and offences
- Salary and other compensation
- Bonus
- Bank account number
To satisfy its regulatory compliance and corporate governance obligations.
What we do with it
We may make available your personal data to supervisory entities, correspondent institutions, or other financial institutions but also legal advisors, corporate service providers or external auditors.
Certain personal data will also be reported to government authorities where required by law and for tax or other purposes.
How long we keep it
We retain personal data only for as long as necessary for the purposes which it is processed. In most cases, this means that personal data is deleted or anonymised no later than 5 years following termination of your investor relationship with Banking Circle, after the relevant purpose has been fulfilled, unless a longer retention period is required by law or regulatory obligations.
Copies of criminal records and background checks will be deleted when the request for which it was collected has been answered.
Do we use any data processors and transfer your data internationally?
Yes. For a list of our main service providers that handle personal data on our behalf, see our data and outsourcing addendum available at https://www.bankingcircle.com/terms-of-use. Some service providers may be located outside Singapore or may host data outside Singapore. Where we transfer personal data outside Singapore, we take steps required by the PDPA to ensure the recipient provides a standard of protection comparable to the PDPA.
3. How do you get in touch with us?
To contact our Data Protection Officer or ask about this notice, please email us or write to us using the details below.
| Contact | Address |
|---|---|
| privacy@bankingcircle.com | |
| Banking Circle S.A. (Group privacy contact) | Attn: Data Protection Officer Banking Circle S.A. 2 Boulevard de la Foire L-1528 Luxembourg |
| Banking Circle Singapore Pte. Ltd. | Attn: Data Protection Officer Banking Circle Singapore Pte. Ltd. 138 Market Street CapitaGreen, #24-01 Singapore 048946 |
For general contact please use this page of our website: https://www.bankingcircle.com/contact-us
4. How do you make a complaint?
If you have a question or complaint about how we handle personal data, please email privacy@bankingcircle.com.
If you remain dissatisfied, you may make a complaint to the Personal Data Protection Commission (PDPC) in Singapore:
| If you are in… | You can contact… |
|---|---|
| Singapore | Personal Data Protection Commission (PDPC) 10 Pasir Panjang Road, #03-01 Mapletree Business City Singapore 117438 Tel: +65 6377 3131 https://www.pdpc.gov.sg/ |