This Privacy Notice is issued by ISR Capital Limited ("ISR"). As part of ISR's day to day business, we collect your Personal Information when you apply to open an account with us, subscribe to any of our products or services or communicate with us. In return, we may use this information to provide you with our products or services, maintain our records or send you relevant information.

Under the Personal Data Protection Act 2012 ("PDPA"), we are required to inform you:

  • of the type of Personal Information we collect and how we collect it;
  • how we use your Personal Information;
  • the parties that we disclose the Personal Information to.

Your privacy is therefore important to us and we are committed to protecting your Personal Information by collecting and using your Personal Information in accordance with the PDPA.

For the purposes of this Privacy Notice, please note that:

  • "ISR" refers to ISR Capital Limited and all its direct and indirect subsidiaries, including, but not limited to: ISR China Limited, ISR Shanghai Investment Advisory Co Ltd, ISR Global Pte Ltd, Dynamic Return (Singapore) Pte Ltd, Infiniti Advantage Pte Ltd and Raintree Strategic Consultancy Limited.
  • "Personal Information" refers to any information which relates directly or indirectly to you and/or your transactions with us. This information may include your name, NRIC number, address, occupation, contact details, details of your account(s), the type of products and/or services subscribed to and such other necessary information regarding yourself and your transaction(s).
  1. The Kind Of Personal Information We Collect And How We Collect It

    In order to enable us deal with your inquiries or to provide you with our products and services, we may be required to collect, use, disclose and store (i.e. "process") your personal and/or financial information. Such personal and/or financial information is required amongst others to:

    • establish your personal identification and background;
    • establish your financial standing and creditworthiness where required;
    • supply you with any of our products and/or services applied for.

    We may also obtain the above information about you from the following sources:

    • Your relationship with us, for example information provided by you in application forms you completed through the agreements you entered into with us, or in the course of establishing and maintaining a client relationship with us regarding an investment product;
    • Your verbal, written and/or electronic communications with us, our subsidiaries or authorised agents;
    • Third parties connected with you, such as your employer, joint account holder, security providers and guarantor(s) subject to your prior consent;
    • Due diligence conducted to establish your financial standing and creditworthiness before successful subscription to our investment products;
    • Your access and use of our services, transactions you make and payments effected through your account(s); and/or
    • Any other sources which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

    The Personal Information we collect can be either mandatory or optional. Mandatory Personal Information is your information that we require so that we can provide you with the requested products and services. If you do not provide us with the mandatory Personal Information, we will not be able to provide you with those products and services. Optional Personal Information are your information that are not obligatory to be provided to us. If you do not wish to provide your optional Personal Information, you may still apply for our products and services. Mandatory and voluntary Personal Information may differ for our various products and services and these will be indicated in the application forms of our products and services.

  2. How We Use Your Personal Information

    Other than as stated above, we may use your Personal Information for one or more of the following purposes:

    • To complete your transaction of the requested investment product, as well as to provide confirmation of the transaction to you;
    • Access and manage your application(s) for our products and services so that we can provide you with more and up to-date information such as company and fund performance updates to the existing investment products, development of new products and service which may be of interest to you;
    • Manage and maintain your account through regular updates, consolidation and improving the accuracy of our records. In this manner we can respond to your enquiries, complaints and to generally resolve disputes quickly so that we can improve our business and your relationship with us;
    • Produce data, reports and statistics from time to time, however such information will be aggregated so that your identity will remain confidential. Sometimes it may be necessary if required, to verify your financial standing through credit reference/reporting checks;
    • Comply with the requirements of any law binding on us such as conducting anti-money laundering checks, crime detection/prevention, prosecution, protection or enforcement of our rights to recover any debt owing to us including transferring or assigning our rights, interests and obligations under any of your agreement with us;
    • Perform shared services within ISR such as audit, compliance, legal, human resource, risk management including assessing financial and insurance risks;
    • Outsourcing of business and back-room operations within ISR; and
    • Any other purpose(s) that is required or permitted by any law, regulations, guidelines and/or relevant regulatory authorities.

    We will seek your consent before using your Personal Information for a purpose other than those that are set out in this Privacy Notice and/or in the terms of any of your agreement(s) with the ISR.

  3. Disclosure Of Your Personal Information

    As part of providing you with our products and services we may be required to disclose certain information about you and/or your accounts with us to the following third parties:

    • our agents, service providers, vendors and/or professional advisers who assist us in processing, administering, fulfilling transactions or providing value added services that you have requested;
    • any person authorised or appointed by you to give instructions to us on your behalf such as your agents, accountants, auditors, lawyers, financial advisers, brokers and intermediaries;
    • any person(s) connected to the enforcement or preservation of any of our rights or transferring the rights and obligations under your agreement(s) with us;
    • other financial institution(s) for the purpose of fulfilling the transactions required by you;
    • any competent authority(ies) and/or regulator(s), including foreign regulator(s) for the performance of their functions, subject at all times to any laws, including foreign laws applicable to the ISR.

    Otherwise, we will not disclose your information to others, except where:

    • you have opted-in for purposes of marketing of third party products;
    • we are required or permitted to do so by law;
    • required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental with jurisdiction over ISR
    • we may transfer rights and obligations under our agreement(s) with you; and/or
    • we are required to meet our obligations to any relevant regulatory authority.

    But rest assured, that at all times, we will respect and protect the privacy and confidentiality of your personal information. ISR Capital Limited will not release or sell your personal information to external or third-party vendors.

  4. Revisions To The Privacy Notice

    Our Privacy Notice may be revised from time to time and if there is/are any revision(s), it will be posted on our website and/or other means of communication deemed suitable by us. However any revision(s) will be in compliance with PDPA.

  5. Enquiries/Complaints

    If you have any enquiries or complaints concerning this Privacy Notice, you may contact:

    Mail To : Attn: Data Protection Officer
    ISR Capital Limited
    20 Martin Road,
    #10-01 Seng Kee Building,
    Singapore 239070.
    Tel No. : +65 6319 4999
    Fax No. : +65 6319 4980
    E-mail Address :