Legal Information

Legal Notice
Any reference in this website to “we”, “our”, us” or “SMDAM-SG”, means Sumitomo Mitsui DS Asset Management (Singapore) Pte. Ltd., Company Registration Number 201318710W. 

1. Agreement to Terms of Use
Please read the following before proceeding.
By accessing this website, you represent that you are either resident in Singapore or that the applicable laws of your jurisdiction allow you to access this website, and that  you agree with the following conditions. If you do not agree to the conditions below, you should exit this website immediately. Your use of this site constitutes your agreement to the following terms of use and legal information which shall be governed by the laws of Singapore. The use of this website is unauthorized in any jurisdiction that does not give effect to all provisions of these conditions of use.

2. Intended Users
This website and its contents are intended only for use by institutional investors and accredited Investors, as defined in Singapore's Securities and Futures Act, or equivalent classes of investors under the laws of the country or jurisdictions of such persons. 

3. Intended Purpose
The contents of this website are provided on an “as is” and “as available” basis. Such contents are provided for information purposes only and should not be considered an offer or solicitation to deal in and/or dispose of any investments, or an offer to provide services in any jurisdiction in which such offer, solicitation or distribution would be unlawful or in which the person making such offer or solicitation is not qualified to do so or to anyone to whom it is unlawful to make such offer or solicitation.
Information in this website should not to be relied on as investment, legal, tax or other advice, as it does not have regard to the specific objectives, financial situation and particular needs of any specific person. 

4. General Disclaimers and Terms
The information and materials herein, including any opinions or forecasts have been obtained from or are based on sources believed by SMDAM-SG to be reliable, for our own use. 
Any person acting in reliance upon these information and materials does so entirely at his or her own risk. Neither SMDAM-SG nor its affiliates, members and partners nor any of our/their directors or employees warrant, expressly or impliedly, the accuracy, adequacy or completeness of any information in this website. Liability for any error or omission is disclaimed.
Past performance is not necessarily indicative of future performance. Any projections or other forward-looking statements regarding future events or performance of countries, markets or companies, may differ from actual events or results. Exchange rate changes may cause value of overseas investments to fluctuate.  Investors may not get back the amount invested.
For information on any funds, products or services, please read the relevant offering documents and product disclosure statements.
The information in this website is not to be taken as SMDAM-SG's endorsement or recommendation of any services, company, security or participation in any funds. Where news stories are quoted in this website, such stories reflect only the author's opinion and not necessarily that of SMDAM-SG or its affiliates.
If third party sites can be accessed by hypertext link from this website, you access them at your own risk. We do not accept any responsibility for information contained therein, nor do we endorse their contents.  You should also review each such website’s privacy policy before disclosing any personally identifiable information.

5. Copyright and  Trademark
This website is owned and operated by SMDAM-SG. 
Copyright in the pages of this site, the screens displaying them, and the information and material contained therein, and their arrangement is owned or licensed by SMDAM-SG and/or its affiliates, unless otherwise indicated You may not reproduce or copy (except for private, non-commercial viewing purposes) this website or any part thereof without SMDAM-SG's prior written permission. All trademarks, service marks, trade names, and logos displayed on this website, including “Sumitomo Mitsui DS Asset Management” and its logo, are proprietary to SMDAM-SG and/or its affiliates.
All rights reserved.

6. Unauthorized Access
This website is not fully protected against unauthorized access by third parties. We are not responsible for ensuring that no such unauthorized access occurs , nor for notifying you that such access has taken place or that any data has been compromised during transmission or reliability.

7. No Unlawful or Prohibited Use
You represent and warrant to us that you will not use this website for any purpose that is unlawful or prohibited by these Terms of Use.

8. Electronic Communication
There is no guarantee that any electronic communication will be received by us, or that the contents therein will remain private or unaltered during transmission. If this is a concern, you may choose to telephone or write to us instead.
We accept no liability for any alteration or loss of confidentiality of information contained in your electronic communication sent to us.
We may filter and/or retain electronic communications to protect our systems, and to comply with laws, regulations and good practice.

9. Downloads
Any software is downloaded at your own risk. We neither warrant their suitability nor accept any liability in respect thereof.

10. Privacy. 
We take the privacy of all visitors to our website seriously. Please refer to the "Privacy  Policy" section of this website, on how your personal data will be managed in accordance with our Privacy Policy and the Personal Data Protection Act 2012. By accessing and using this website, you agree and consent to how your personal data will be managed in accordance with the aforesaid. We encourage you to review our Privacy Policy before disclosing any personally identifiable information.

11. Cookies
We use cookies on our website, and when you visit our website, we may store information on how you use the website, to improve your experience on our website. Your use of our website constitutes consent by you to our storing and accessing cookies on your device. You can change your cookie settings at any time. Where you access third party websites through links in our website, you should be aware that these websites may also send their own cookies to users, or otherwise collect data and/or solicit personal information.

12. Geographic Exclusion
The information provided on this website is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject SMDAM-SG and/or its affiliates to any registration requirement within such jurisdiction or country.

Singapore Stewardship Principles
Sumitomo Mitsui DS Asset Management (Singapore) Pte. Ltd. embraces and supports the Singapore Stewardship Principles ("SSP"). The SSP encourages responsible investment and promotes good stewardship practices among the investor community. The SSP aims to enable investors to be active and responsible shareholders, by articulating the core actions associated with investor stewardship. The SPP also encourages companies to pursue the spirit of good governance and stewardship, with the ultimate objective of helping companies secure their performance over the long term, thus creating sustainable long term value for all stakeholders. 

Privacy Policy
Your privacy is important to us. This Privacy Policy outlines how any personal data which you may provide to us, will be managed and protected in accordance with Singapore’s Personal Data Protection Act 2012 (the “Act”).  
This Privacy Policy forms part of the terms and conditions governing your relationship with us. This Privacy Policy does not supersede or affect any other consents which you may have previously provided to us. Nor does it affect any rights we may have at law in relation to the collection, use and/disclosure of your personal data. 

If you have any questions on this policy or other queries on how we collect, use, disclose, manage, protect and/or process your personal data, or you have any complaint about how we handle your personal data, please contact either of the following at Sumitomo Mitsui DS Asset Management (Singapore) Pte. Ltd.:- 
Data Protection Officer: the Chief Executive Officer, via email at akihiro_sato@smd-am.co.jp
Alternate Data Protection Officer: the Chief Compliance Officer, via email at eric_ng@smd-am.co.jp

Personal data
“Personal data” refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access to, including data in our records as may be updated from time to time. Personal data that you may provide to us includes, but is not limited to, your name, your identification details such as your identity card, passport or other identification number, your contact details such as your telephone numbers, mailing address, email address, your employment, education, and income details, and your bank account details and other financial information. Personal data may also include the IP address of your personal computer, the country from which the enquiry is made, the pages visited, the time the visit was made, and the browser type.

This information may come from sources such as forms submitted by you, from other written, electronic or verbal correspondence, from your transactions, from your brokerage or financial advisory firm, financial adviser or consultant, your interaction with us on this website and/or from information captured on our  website.

Consent
You agree and consent to Sumitomo Mitsui DS Asset Management (Singapore) Pte. Ltd. and affiliates, as well as our authorized service providers and relevant third parties collecting, using, disclosing and/or sharing your personal data in the manner outlined in this Privacy Policy.

In the event that you provide personal data relating to a third party (such as information of your next-of-kin, spouse, dependent, children and/or parents) to us, you represent and warrant by submitting such data to us that the third party's consent has been obtained for the collection, use and disclosure of the personal data for the Purposes described below.

Purposes for collection, use and disclosure
We may collect, use, disclose and/or process your personal data for various purposes, including but not limited to: 
a. facilitating any proposed or actual business with you;
b. storing, hosting and/or backing up (whether for disaster recovery or otherwise) of your personal data, whether in or outside Singapore;
c. communicating with you about any administrative changes, updates and/or amendments to our policies, terms and conditions;
d. taking instructions from you or handling feedback, queries or complaints;
e. legal claims, actions or proceedings including, but not limited to, defending or enforcing of our legal rights and obligations;
f. complying with our internal policies and procedures, any applicable laws, rules and regulations, regulatory policies, guidelines and industry codes, orders, directions, and/or any directions or requests issued by any court, governmental bodies (whether in Singapore or otherwise), and in response to audit checks, surveillance and investigation;
g. credit checks and complying with our “Know Your Customer” requirements;
h. investigating crime, misconduct, offence or unlawful activity including, but not limited to, fraud, money-laundering, terrorist financing and bribery, and analyzing and managing commercial risks;
i. generating financial, regulatory, management or other related reports, correspondence, statements, invoices, confirmations, advices or notices in connection with our services and/or investment products;
k. other purposes, directly or indirectly relating to any of the above and our activities; and
l. where you have specifically provided us with consents to do so, we may also collect, use and/or disclose your personal data for the purposes of sending you marketing and promotional materials, subject to applicable laws,
(hereafter referred to as the “Purposes”).

Disclosure or personal data
We may disclose your personal data to our holding company, subsidiaries, related and/or associated companies, affiliates, delegates, trustee(s), business partners, and/or service providers, or any third party and/or agents (including outsourcing agent, data processors, brokers, dealers, financial advisors, consultants, our marketing agents, accountants and lawyers), any and all governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, and court and/or officer of the court for any of the Purposes.
Your personal data may be transferred to locations outside Singapore. Where your personal data is to be transferred out of Singapore, we will comply with the Act in doing so.
We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that all of the purposes for which that personal pata was collected is no longer being served by the retention of such personal data, and retention is no longer necessary for any Purpose or any other legal or business purposes or legal / regulatory compliance.

Cookies
We use cookies on our website. Cookies are small text files that are placed and stored on your computer when you visit any website. Cookies enable the website to recognize you, log when you visit a particular page, although they also improve your browsing comfort. Your use of our website constitutes consent by you to our use of cookies.

Request for Access and/or Correction of Personal Data
You may request to access and/correct personal data which is in our possession, by sending us a written request. We will require sufficient information from you in order to ascertain your identity and the nature of your request. If your request is denied, we will inform you that is it denied, and provide you with the reasons for so doing.

Request to Withdraw Consent
You may withdraw your consent given for any or all Purposes set out herein by notifying the Data Protection Officer or the Alternate Data Protection Officer by email at the respective address provided above. In the event that your consent is withdrawn for any Purpose, we may not be able to process your personal data for all of the Purposes. In  the event that as a result thereof, the performance of contractual obligations are affected, all our legal rights and remedies will be expressly reserved.

Update of Privacy Policy
This Privacy Policy may be updated from time to time to ensure that it is consistent with our business purpose and/or any changes in law or regulations.