Hamilton & Sherwind Pte. Ltd. Data Policy

Updated: April 9, 2019

This Hamilton & Sherwind Personal Data Policy (“PD Policy”) sets out how Hamilton & Sherwind Private Limited (Co. Reg. No. 201406560E) and its associated individuals/organizations collect, use, disclose and retain your personal data.

Among the most important assets of Hamilton & Sherwind is the trust and confidence placed in us to properly handle personal data. You can expect us to maintain your personal data accurately, protect your personal data against manipulation and errors and keep your personal data secure from theft and free from unwarranted disclosure.

This PD Policy provides you with notice as to what and how personal data is collected, how it is intended to be used, to whom your personal data may be transferred to, how to access, review and amend your personal data and our policy on the use of cookies.

Hamilton & Sherwind recognises its responsibilities in relation to the collection, holding, processing or use of personal data. The provision of your personal data is voluntary. You may choose not to provide us with the requested data, but failure to do so may inhibit our ability to do business with or provide services to you.


How we collect personal data

Hamilton & Sherwind collects personal data in the following ways:

  1. When you use our products or services, access our website and use our online and mobile services;
  2. When you submit documents and application forms to us during the application process for the purchase, or in consideration of the purchase, of our products or services.
  3. When you respond to our queries or request for us to contact you;
  4. When you interact with our personnel, customer service officers or sales representatives via phone, email, face to face meetings, interviews, SMS, fax, mail or electronic mail.
  5. When we receive referrals and collect personal data from within Hamilton & Sherwind, its associated persons/organisations, agents, business partners and service providers, and third party service providers and representatives of Hamilton & Sherwind Pte. Ltd.
  6. When you submit personal data to us to participate in a lucky draw, contest, or event organised by Hamilton & Sherwind, its partners, representatives or service providers.


By providing us with any personal data relating to a third party (e.g. family members and beneficiaries), you represent and warrant that you shall ensure accuracy of such personal data provided and have obtained such third party’s prior consent for our collection, use and disclosure of such third party’s personal data for the relevant purposes, except to the extent that such consent is not required under relevant law. You further agree to keep us fully indemnified from and against any and all damages, losses, costs, legal fees (solicitor- client basis), penalties and proceedings, including any penalties or other amounts levied, imposed or charges by any regulator or regulatory authority, arising out of or in connection with your (or those of your officers, employees, advisors, agents and representatives) acts or omission, fault or negligence in performing these obligations or which results in us breaching relevant laws.


Type of personal data collected, used or disclosed

Hamilton & Sherwind may collect, use and disclose personal data including but not limited to the following:


  1. Your personal particulars such as NRIC numbers, passport numbers, contact details, addresses, date of birth, occupation, photographs;
  2. Your financial information such as bank account numbers, credit card, GIRO and other payment details;
  3. Your employment information and employment history
  4. Personal data of a third party that you provide to us in connection with the purchase of our products and services or for referrals.


Purposes for which personal data is collected, used or disclosed

Hamilton & Sherwind collects, uses and discloses personal data for the following purposes:


  1. To assess, process, administer, implement and effect the requests or transactions;
  2. Assessing your eligibility to purchase our products and services;
  3. Servicing your account and relationship with us;
  4. Responding to your requests and queries including requests and queries from your authorised representatives and individuals purporting to be you;
  5. Verifying your identity and any information you provide to us;
  6. Marketing and promoting the business activities, products and services to you via face to face meetings, telephone calls, SMS, fax, mail and electronic mail;
  7. Participating and administering contests, lucky draws, and events
  8. Providing, managing, operating, processing and administering our products and services to you;
  9. Archiving, backing-up or destroying personal data;
  10. Compliance, monitoring and audit reviews;
  11. Meeting requirements of prevailing internal policies of Hamilton & Sherwind;
  12. To design new or enhance existing products and services provided by us;
  13. To communicate with you including to send you administrative communications about any account you may have with us or about future changes to this PD Policy;
  14. For market, statistical or actuarial research and trend analysis of our products and services for company, regulatory or industry exercises and studies and reviewing the standard of our products and services;
  15. For data matching, internal business and administrative purposes;
  16. Meeting requirements imposed by any law, rules, regulations, agreements or schemes imposed by any government regulators, law enforcement agencies, government authorities, dispute resolution or industry bodies or in connection with any investigations;
  17. To personalise the appearance of our websites, provide recommendations of relevant products and provide targeted advertising on our website or through other channels;
  18. For quality and training when our communications with you are recorded;
  19. Conducting general administration in connection with the foregoing;
  20. Other purposes as notified at the time of collection; and other purposes directly relating to any of the above.


By providing your personal data to us, you accept that Hamilton & Sherwind may retain your information for as long as necessary, to fulfill the purpose(s) for which it is collected in compliance with applicable laws and regulations and Hamilton & Sherwind’s prevailing internal policies. Hamilton & Sherwind applies reasonable security measures to prevent unauthorised or accidental access, processing, erasure, loss or use including limiting physical access to data within Hamilton & Sherwind’s systems and encryption of sensitive data when transferring such data. Reasonable steps will be taken to delete, destroy or anonymise your personal data when it is no longer necessary for any of the purposes above.


Consent for marketing purposes

If you have given us consent to receive marketing and promotional information through electronic mail or postal mail or on your Singapore telephone number (s) via phone calls, text or fax, we may from time to time contact you on such Singapore telephone numbers (s) via your designated mode of communication or through electronic mail or postal mail (as the case may be) to provide you with marketing, promotional information and updates about our products and services.

We may also seek your consent and notify you separately of the purposes of the collection, use and disclosure of your personal data from time to time with respect to particular products and services.

Any consent that you have given for marketing purposes is not affected by termination of particular services.


Consequences of consent withdrawal

You may withdraw your consent for us to collect, use or disclose your personal data by giving us reasonable notice.

If you withdraw your consent for us to collect, use or disclose your personal data for non-marketing reasons, we will be unable to process, administer and/or manage your service requests, relationship and/or account with us.

You may withdraw your consent for your personal data to be used for marketing purposes and you will stop receiving marketing information from us via the mode(s) of communication for which you have withdrawn such consent after a period permitted under law or in accordance with our internal policies. Please note that such withdrawal of your consent will not affect our ability to provide you with the products and services for which you have requested or to which you have applied, subscribed or are participating with us.


Data accuracy

As Hamilton & Sherwind relies on your personal data to provide products and services to you, you shall ensure that the information provided by you to us is at all times correct, accurate and complete. You shall update us in a timely manner of all changes to the information provided to us.


Use of cookies

Cookies are unique identifiers placed on your computer or other device by a web server, which contains information that can later be read by the server that issued the cookie to you. Hamilton & Sherwind may use cookies on various websites we maintain. The information collected (including but not limited to: your IP addresses (and domain names), browser software, types and configurations of your browser, language settings, geo-locations, operating systems, referring website, pages and content viewed, and durations of visit) will be used for compiling aggregate statistics on how our visitors reach and browse our websites to help us understand how we can improve your experience on it. Such information is collected anonymously and you cannot be identified unless you have logged on as a member. We use such data only for website enhancement and optimisation purposes. The cookies also enable our website to remember you and your preferences, and tailor the website for your needs. Advertising cookies will allow us to provide advertisements on our websites that are as relevant to you as possible, e.g. by selecting interest-based advertisements for you, or preventing the same advertisement from constantly reappearing to you.

Most web browsers are initially set up to accept cookies. If you do not want to receive cookies, you can disable this function in your browser settings. However, by doing so you may not be able to fully enjoy the benefits of our websites and certain features may not work properly.


Amendments to this PD Policy

Hamilton & Sherwind reserves the right, at any time and without notice, to add to, change, update or modify this PD Policy, simply by notifying you of such change, update or modification. If we decide to change our personal data policy, those changes will be notified on our website so that you are always aware of how and what information we collect, how we use the information and under what circumstances the information is disclosed. Any such change, update or modification will be effective as stated in the PD Policy.


Contact us

You have the right to access and request for the correction of your personal data and withdraw your consent given to us to collect, use or disclose your personal data. In all other cases, requests for withdrawal of consent, access and correction may be made via e-mail or should be addressed in writing to:


65A Temple Street

Singapore 058610