For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified –


(a)  from that data; or


(b)  from that data and other information which an organisation has or is likely to have access.


Such Personal Data shall also refer to that which is already in the possession of AMG Alliance Wealth or that which shall be collected by AMG Alliance Wealth in the future.


This Policy provides information on the obligations and policies of AMG Alliance Wealth in respect of an individual customer’s Personal Data. AMG Alliance Wealth undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out in this Policy to its operations.




AMG Alliance Wealth and its representatives (including its management, staff, financial consultants, etc.) shall use reasonable endeavours to respect the confidentiality of and keep safe all Personal Data collected, stored, disclosed and used for, or on behalf of, the Organisation. AMG Alliance Wealth shall use reasonable endeavours to ensure all collection, storage, disclosure and usage of Personal Data by the Organisation shall be done in an appropriate manner and in accordance with the Act and this Policy.




This Policy supplements but neither supersedes nor replaces any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

Types of Personal Data Collected


As part of its day-to-day activities, AMG Alliance Wealth may collect from data subjects, through various means, including via referrals, introducers, road shows, seminars, personal networks and social media, and any forms (survey forms, feedback forms) used by the Organisation from time to time, the following Personal Data:

 - Full name

 - NRIC/Passport number

 - Date of birth

 - Gender

 - Marital status

 - Nationality

 - Residential address

 - Phone number (including mobile)

 - Email address

 - Employment status

 - Occupation

 - Income details

 - Education level

 - Dependants’ details

 - Bank account/credit card details

 - Photographs and images

 - Other information, as may be required in the respective forms

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Purpose of Collection of Personal Data


In order to carry out the functions described below, AMG Alliance Wealth requires consent to collect and use your Personal Data. Failure to receive consent may affect our ability to provide financial solutions to you. The Personal Data mentioned in Paragraph 3.1 is collected for the following purposes:




 - Prospecting for potential clients through various channels stated in Paragraph 3.1;

 - Fact-finding of potential clients’ financial needs;

 - Financial planning for clients;

 - Developing financial plans for clients and recommending investment and/or insurance products;

 - Assisting clients to apply for recommended investment and/or insurance products through the relevant financial companies or institutions;

 - After-sales service to clients – responding to their queries and feedback, notifying them of any changes to their investment or insurance terms and conditions;

 - Keeping clients informed of new investment and insurance products that may be relevant to them;

 - Market research and analysis (using anonymised data).






Disclosure of Personal Data


In order to carry out the functions described above, AMG Alliance Wealth may, from time to time, disclose your Personal Data between its Organisational entities.




Without derogating from any of the above, AMG Alliance Wealth may also disclose your Personal Data to the following third parties:




 - Regulators and law enforcement officials

 - Financial institutions providing investment and insurance products

 - Lawyers

 - Auditors

 - Third party service providers and consultants

 - Credit, debit and charge card companies, banks and other entities processing payment

 - Any agent or subcontractor acting on AMG Alliance Wealth’ behalf for the provision of the Organisation’s services.




AMG Alliance Wealth may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:

 - To the extent that the Organisation is required to do so by the law;

 - In connection with any legal proceedings or prospective legal proceedings;

 - To establish, exercise or defend the Organisation’s legal rights;

 - To any person and/or entity for the purpose of processing such information on the Organisation’s behalf;

 - To third parties who provide services to the Organisation or on its behalf;

 - With your consent; or

 - For the purposes of disaster recovery.


Optional Provision of Personal Data


In some instances, you may also be requested to provide certain Personal Data that may be used to further improve AMG Alliance Wealth’ financial planning services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a service is dependent on your providing all requested data, failure to provide the requested data may prevent the Organisation from providing the service to you. This type of data includes, but is not limited to:




 - Health and medical information

 - Lifestyle, hobbies and leisure activities

 - Family and household demographics




Under certain circumstances, telephone calls made to any of AMG Alliance Wealth’ service hotlines or inquiry telephone numbers will be recorded for the purposes of training, quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance with this Policy.


Your Personal Data may be processed by AMG Alliance Wealth’ affiliates, agents, introducers and third parties providing services to organisations in jurisdictions outside of Singapore. The Organisation will comply with the terms of the Personal Data Protection Act in such events, which include, but are not limited to:

 - Overseas reference checks

Where possible, AMG Alliance Wealth will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, AMG Alliance Wealth is able to validate the data provided against pre-existing data held by the Organisation. In some cases, AMG Alliance Wealth is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of the Organisation, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email or postal address provided at Paragraph 2.2.


AMG Alliance Wealth uses commercially reasonable physical, managerial and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside the Organisation, other than to you or as described in this Policy. However, AMG Alliance Wealth cannot ensure or warrant the security of any information you transmit to us should there be any breach of the safeguards or any situation which is beyond AMG Alliance Wealth’ control at the information transmission stage. In particular, AMG Alliance Wealth cannot warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of the Organisation’s physical, technical or managerial safeguards.


AMG Alliance Wealth will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of the Organisation and where the Personal Data is deleted from the Organisation’s electronic, manual, and other filing systems in accordance with the Organisation’s internal procedures and/or other agreements.


To the extent that any of the communication means which you have provided AMG Alliance Wealth with (which may include your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your signing of the Your Financial Blueprint, or by any other means of indication, you hereby grant AMG Alliance Wealth your clear and unambiguous consent to contact you using all of your communication means you have provided to the Organisation, including via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated in Paragraph 3.2.


AMG Alliance Wealth reserves the right to alter any of the clauses contained in this Policy in compliance with local legislation, and for any other purpose deemed reasonably necessary by the Organisation. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.


This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.




This Policy only applies to the collection and use of Personal Data by AMG Alliance Wealth. It does not cover third-party sites to which we provide links. AMG Alliance Wealth does not share your Personal Data with third-party websites. AMG Alliance Wealth is not responsible for the privacy and conduct practices of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.