Privacy Policy
Stonebroom Compliance Department
Last Updated: 2024
Disclaimer: This document is a standard template provided for informational purposes regarding data processing on this website and does not constitute formal legal advice.
01. Introduction
Stonebroom ("we", "us", or "our") operates the website dedicated to investing for beginners in Singapore, focusing on ETF and SGX stock market fundamentals. We are committed to protecting your personal data and your privacy in accordance with the laws of Singapore.
This Privacy Policy outlines how we collect, use, disclose, and process your personal data when you visit our website, subscribe to our newsletters, or use our educational resources. Our practices are governed by the Personal Data Protection Act 2012 (PDPA) of Singapore.
02. Data Controller
The data controller responsible for your personal data is Stonebroom, located in the Queenstown district of Singapore. As the operator of this platform, we ensure that all personal data is handled with the highest standards of security and confidentiality.
Contact Details:
Address: 167 Jalan Bukit Merah, Singapore 150167, Queenstown
Email:
Phone: +65 9283 7991
03. Personal Data We Collect
We collect information that identifies you or can be used to identify you. This includes:
- Identity Data: Full name, username, or similar identifier provided via contact forms.
- Contact Data: Email address and telephone number.
- Technical Data: Internet Protocol (IP) address, browser type and version, time zone setting, browser plug-in types, operating system, and platform.
- Usage Data: Information about how you use our website, products, and services, including search queries regarding SGX stocks and ETFs.
- Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
04. Purpose and Legal Basis
Under the PDPA, we process your data based on one of the following legal grounds:
Consent
Where you have given us clear consent to process your personal data for a specific purpose, such as subscribing to our SGX market insights.
Contractual Necessity
To perform a contract we are about to enter into or have entered into with you regarding our investment guides.
Legitimate Interests
Necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legal Obligation
Where we need to comply with a legal or regulatory obligation in Singapore.
05. Retention of Data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use, and the applicable legal requirements in Singapore.
06. Disclosure to Third Parties
We may share your personal data with the parties set out below:
- Service providers acting as processors who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, and insurers.
- Regulators and other authorities in Singapore who require reporting of processing activities in certain circumstances.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
07. International Transfers
Whenever we transfer your personal data out of Singapore, we ensure a similar degree of protection is afforded to it by ensuring at least one of the protection requirements under the PDPA is implemented. This includes transferring only to countries that provide a standard of protection to personal data that is comparable to the protection under the PDPA.
08. Your Legal Rights
Under certain circumstances, you have rights under the PDPA in relation to your personal data:
Right to Access
You have the right to request a copy of the personal data we hold about you and to check that we are lawfully processing it.
Right to Correction
You have the right to request the correction of any incomplete or inaccurate data we hold about you.
Right to Withdraw Consent
Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time.
To exercise any of these rights, please contact our Data Protection Officer at .
09. Cookies and Tracking
Our website uses cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our investment guides and allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them, please see our Cookie Policy.