Dymon Asia Capital Ltd, its affiliates and the collective investment vehicles and client accounts which are managed or advised by Dymon Asia Capital Ltd and/or its affiliates (together, “Dymon”, “we”, “us” or “our”) may obtain personal data about you in connection with your use of this Website. For the purposes of data protection law, we are a user or controller in respect of your personal data. We are responsible for ensuring that we use your personal data in compliance with applicable data protection law.
Dymon respects your concerns about privacy and is committed to protecting the privacy of all personal data obtained.
This Privacy Statement explains: (i) the personal data we process; (ii) how that information is processed; (iii) with whom we may share it; and (iv) the rights available to you. This Privacy Statement covers information collected through your use of this Website, when you contact or request information from us, when you engage us for services or as a result of your relationship with one or more of our staff and clients, and applies to all organizations within the Dymon Group.
As referenced in this Privacy Statement, “personal data” generally means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, Dymon (or its representatives or its service providers). In addition to factual information, it may also include any expression of opinion about an individual and any indication of the intentions of Dymon or any other person in respect of such individual.
For the purposes of this Privacy Statement, the term “process” includes any operation that is carried out in respect of personal data, including but not limited to, collecting, using, storing, disclosing or otherwise processing personal data.
I. Personal data that we collect about you
Dymon may collect and process the following personal data about you through your use of this Website:
a. Information that you provide to us or one of our affiliates. This includes information about you that you give to us by filling in online forms or by communicating with us, whether by e-mail or otherwise. This information may include (but is not limited to) your contact information (including your name, occupation, address, telephone number(s), e-mail address etc.), username and password to access Dymon products and services online, information that you provide in the course of applying for a job with us (including your education, work, religion, military history, legal work eligibility status etc.).
b. Information we collect or generate about you. This may include (but is not limited to) personal data that we collect through your use of our e-mail system (including but not limited to your full name, e-mail address and the content, date and time of your e-mail correspondence).
Dymon may process your personal data for the following purposes (to the extent applicable):
a. to provide, manage or administer the products or services provided to you, including processing transactions;
b. to manage your account, maintain your personal profile and personalize your experience on our Website;
c. to communicate with you when necessary or appropriate in relation to the services being provided to you;
d. to manage career opportunities at Dymon;
e. to perform analytics (including market research, trend analysis, financial analysis and anonymization of personal data);
f. to keep you updated whilst you are a client in relation to the products or services provided to you and to provide you with information or opportunities that we believe may be relevant to you;
g. to conduct our everyday business purposes, which may include compliance with industry standards and policies and/or obligations under applicable law;
h. to ensure that we meet our obligations under any applicable laws, rules, regulations, guidelines, notices or directions, including (without limitation):
i. verifying compliance with the relevant laws, rules, regulations, guidelines, notices or directions that apply to Dymon;
ii. any obligations related to tax matters (such as identification, tax reporting and tax audit);
iii. any obligations related to anti-money laundering and countering the financing of terrorism legislation or regulations; and
iv. responding to any mandatory request for information made by a governmental or other regulatory body, any exchange or self-regulatory organization; and
i. in order to establish, exercise or defend our legal rights.
We are entitled to use your personal data in these ways because:
a. we need to in order to perform our obligations and exercise our rights in connection with managing your account and providing products and services to you;
b. we have legal and regulatory obligations that we have to discharge;
c. we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
d. the use of your personal data as described may be necessary for our legitimate business interests:
i. allowing us to effectively and efficiently administer and manage the operation of our business;
ii. ensuring compliance with all legal and regulatory obligations and industry standards, and preventing fraud;
iii. maintaining compliance with internal policies and procedures; or
iv. ensuring the security of our information systems.
No personal data will be disclosed to third parties except in the following circumstances (to the extent applicable):
a. to our affiliates or employees, who have a bona fide need for this information in order to perform their job responsibilities or necessary to perform services on our behalf;
b. to third party service providers, outside counsel, auditors and other independent professionals in connection with the purposes as described in this Privacy Statement;
c. any organization at your request or any person acting on your behalf (including your adviser, broker, solicitor or accountant);
d. assessing compliance with applicable laws, rules and regulations, as required by law of relevant government or administrative authority and then, to the extent reasonably possible, only subject to customary undertakings of confidentiality;
e. to the extent required by law (for example, if we are under a duty to disclose your personal data in order to comply with any legal obligation), establish, exercise or defend our legal rights or for the purpose of legal proceedings;
f. if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes; and
g. if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer.
No personal data is shared with unaffiliated third parties for their marketing purposes.
IV. International Transfers
Personal data may be transferred internationally for the purposes described in this notice. The protections which apply to international transfers of personal data are further described in this paragraph IV, and will apply regardless of the international transfer or processing of such information.
Transfers outside the European Economic Area (the “EEA”)
Where we are subject to the EU General Data Protection Regulation (or any equivalent data protection legislation) in respect of our processing of your personal data and if we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance where:
a. the recipient destination has been subject to a finding from the European Commission that it ensures an adequate level of protection for the rights and freedoms that you possess in respect of your personal data;
b. if the recipient is in the United States of America, it is a certified member of the EU-US Privacy Shield scheme; or
c. the recipient has signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data.
To the extent that the EU General Data Protection Regulation (or any equivalent data protection legislation) applies to you, you are entitled to request further details of the protection given to your personal data when it is transferred outside its country or jurisdiction of origin.
Transfers outside Singapore
Where we are subject to the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “PDPA”) in respect of our processing of your personal data and if we transfer your personal data outside Singapore, we will take all reasonable steps to ensure that:
a. the recipient agrees to protect personal data at a standard that is at least comparable to the PDPA in accordance with the PDPA; or
b. any other transfer will otherwise be in accordance with the PDPA.
Transfers outside Hong Kong
Where we are subject to the Hong Kong Personal Data (Privacy) Ordinance (the “PDPO”) in respect of our processing of your personal data and if we transfer your personal data outside Hong Kong, we will ensure that:
a. we have reasonable grounds for believing that there is in force in that recipient destination any law which is substantially similar to, or which serves the same purpose as the PDPO;
b. you have consented in writing to the transfer;
c. we have reasonable grounds for believing that, in the circumstances in question:
i. the transfer is for the avoidance or mitigation of adverse action against you;
ii. it is not practicable to obtain your consent in writing to that transfer; and
iii. if it was practicable to obtain such consent, you would give it; or
d. we have taken all reasonable precautions and exercised all due diligence to ensure that the data will not, in that recipient destination, be collected, held, processed or used in any manner which, if that recipient destination were Hong Kong, would be a contravention of a requirement under the PDPO.
We will retain the personal data that we obtain about you until it is no longer required in order to perform our obligations or exercise our rights under our employment agreement with you, except to the extent that we are permitted by law to retain it for a longer period of time (in which case, we will retain it for the period permitted by law) or to the extent that we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings.
VI. Your rights
To the extent you are entitled to do so under applicable law:
a. you have a right to obtain information on, and access to, the personal data that we process about you and to request the correction of any error or inaccuracy in relation to such personal data; and
b. you also have the following rights in respect of your personal data:
i. the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we can rely on another legal ground for doing so;
ii. in some circumstances, the right to receive any personal data which we process about you on the basis of your consent (as opposed to any other legal ground) in a structured, commonly used and machine-readable format and/or request that we transmit such data where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
iii. the right to request that we rectify your personal data if it is inaccurate or incomplete;
iv. the right to request that we erase your personal data in certain circumstances. Notwithstanding this, please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
v. in some circumstances, the right to request that we restrict our processing of your personal data. Notwithstanding this, please note that there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and/or reuse that request;
vi. the right not to be subject to a decision based solely on the automated processing of your personal data, where this produces legal effects concerning you or which significantly affects you; and
vii. the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by us.
You may exercise any of the above rights or obtain further information about the use of your personal data by contacting firstname.lastname@example.org.
In order to process your request, we reserve the right to use personal data previously obtained to verify your identity or take other actions that we believe are appropriate, subject to the requirements under applicable law.
To protect your personal data from unauthorized access and use, Dymon uses security measures that comply with applicable law. These measures include appropriate physical, electronic and procedural controls which are reasonably designed to:
a. ensure the security and confidentiality of your records and information;
b. protect against any anticipated threats or hazards to the security or integrity of your records and information; and
c. protect against unauthorized access to or use of your records or information that could result in substantial harm or inconvenience to you.
You may also wish to note that you may be able to access other organizations’ websites through links on this website and in this regard, please note that Dymon is not responsible for the privacy standards and processes of those organizations and external websites.
This Privacy Statement may be updated periodically to reflect changes in our firm’s policies and applicable law. We suggest that you periodically review this Privacy Statement for any update.
If you have any questions about this Privacy Statement, please contact email@example.com.