This privacy policy (“Privacy Policy”) sets out how Tower Capital Asia Pte Ltd and its related corporations (“TCA”) manage your Personal Data (as defined below). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with TCA, as well as its representatives and/or agents (“us”, “we” or “our”), submitting information to us, in your engagement with us and/or in the course of our fund and investment management, you agree and consent to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace 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. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

This Privacy Policy may be updated from time to time to ensure that this Privacy Policy is consistent with our future developments and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our website at Please check the website at regularly for updated information on the handling of your Personal Data.

  1. Your Personal Data
    1.1 In this Privacy Policy, “Personal Data” means all data that falls within the definition of personal information, personal data, personally identifiable information or similar language under any applicable law relating to the protection, privacy and security, collection, use or disclosure of sensitive or other personally identification information, including the Singapore Personal Data Protection Act 2012 (collectively, “Data Protection Laws”).

    1.2 Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you (or any other individuals) which you have provided us in any form you may have submitted to us, or in other forms of interaction with you

  2. Collection of Personal Data
    2.1 Generally, we collect your Personal Data in the following ways: (1.a) when you deal with us in the ordinary course of business e.g. in entering into any agreements with us, providing us with information for compliance with Know-Your-Client or anti-money laundering verifications policies and procedures;

    (1.b) in respect of any banking or financial dealings with or involving TCA, such as wiring for the settlement of trades, writing cheques, transfer of funds, arrangement of banking/ credit facilities on behalf of institutional customers. Personal data in such circumstances may include signatures, answers to questions intended for security verification, etc;

    (1.c) when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, emails, faxes, face-to-face meetings, social media platforms, or via our website;

    (1.d) when you request that we contact you or request that you be included in an email or other mailing or contact list;

    (1.e) when you respond to our promotions, initiatives or to any request for additional Personal Data;

    (1.f) when you participate in our events, functions, seminars etc.;

    (1.g) when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;

    (1.h) when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events; <

    (1.i) when you are contacted by, and respond to, our marketing representatives and customer service officers;

    (1.j) when we receive references from business partners and third parties, for example, where you have been referred by them;

    (1.k) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for the purposes of the management of the fund or employee applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities;

    (1.l) from the deployment of cookies or other technologies deployed for the analysis of visits to our websites; and/or

    (1.m) when you submit your Personal Data to us for any other reasons.

    2.2 If you provide us with any Personal Data relating to a third party, by submitting such information to us, you represent and warrant that the disclosure of that Personal Data to us, as well as the further collection, use, disclosure and/or processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

  3. Purposes for the Collection, Use and Disclosure of Personal Data

    3.1 In general, we collect, use and disclose your Personal Data for the following purposes, where we have obtained your consent or as otherwise where permitted under applicable Data Protection Laws:

    (1.n) performing obligations in the course of or in connection with our provision of the services requested and in the course of the management and operation of the fund;

    (1.o) to provide, process and administer the institutional customer’s accounts and services or to process applications of the institutional customer, including but not limited to the making of decisions relating to the account opening or continuation of accounts or otherwise maintaining up-to-date “know your customer” information;

    (1.p) in connection with the verification of identity and in relation to the conducting of any required due diligence including but not limited to those relating to Know-Your-Client, anti-money laundering or combating of the financing of terrorism, or otherwise;

    (1.q) to respond to, process and handle your queries, feedback, complaints and requests;

    (1.r) to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

    (1.s) to manage our administrative and business operations and to comply with internal policies and procedures;

    (1.t) to monitor or recording phone calls and customer-facing interactions for quality;

    (1.u) to commence, respond to, or act in connection with any claims, disputes, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution) and to facilitate any investigations thereto;

    (1.v) to protect, comply with and enforce our contractual and legal rights and obligations;

    (1.w) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;

    (1.x) to facilitate corporate transactions (which may extend to any sales, transfer or disposal of shares, assets or other interest, corporate mergers and/or acquisitions) us or any of our affiliates in the same corporate group;

    (1.y) to match any Personal Data held which relates to you for any of the purposes listed herein;

    (1.z) to communicate with you changes and development to our policies, terms and conditions and other administrative information; and/or

    (1.aa) to comply with any applicable rules, laws and regulations, compliance requirements codes of practice or guidelines, including FATCA and CRS requirements or to assist in law enforcement and investigations by relevant authorities, including but not limited to complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within TCA for compliance with sanctions.

    3.2 Furthermore, where permitted under the Data Protection Laws, or with your specific consent, we may also collect, use and disclose your Personal Data:

    (2.a) providing or marketing services, products and benefits to you and/or your organisation;

    (2.b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services;

    (2.c) sending you and/or your organisation details of upcoming events, updates or information about our products, services, either to our customers generally, or which we have identified may be of interest to you;

    (2.d) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer services as well as programmes which may be relevant to your and/or your organisation’s preferences.

    3.3 In relation to your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

    3.4 You may withdraw your consent for by contacting us using the contact details set out at Paragraph 6 below.

  4. Disclosure of Personal Data

    4.1 Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

    (1.a) amongst our affiliated companies in our corporate group (including their respective staff);

    (1.b) any agent, contractor, service provider by the fund administrator or third-party service provider who provides administrative, corporate secretarial, IT maintenance, mailing, telecommunications, travel, visa, knowledge management, credit reference checks, know-your-client (KYC) checks, probity checks, securities screening or other services to TCA in connection with or ancillary to the operations of its fund management business;

    (1.c) any financial institution, securities brokerage firms and investment services providers with whom the institutional customer has or proposes to have dealings with, and any credit reference agencies, credit information bureaus;

    (1.d) external banks, credit card companies, other financial institutions and their respective service providers;

    (1.e) our professional advisers such as consultants, auditors and lawyers;

    (1.f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving us or any of our affiliated companies within our corporate group;

    (1.g) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or

    (1.h) any other party to whom you authorise us to disclose your Personal Data to.

  5. Keeping Your Personal Data Accurate and Up-To-Date
    We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability or delays in processing any requests and applications you may have made to us.

  6. Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data

    6.1 If you:

    (1.a) have any questions or feedback relating to your Personal Data or about this Privacy Policy;

    (1.b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or

    (1.c) would like to obtain access or make correction to your Personal Data records, or many other request in respect of your Personal Data records,

    please contact us as follows:

    By mail:
    138 Market Street

    #36-01 CapitaGreen
    Singapore 048946

    By email:

    6.2 Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.

    6.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you, or administer any contractual relationship in place. Our legal rights and remedies in such event are expressly reserved.

  7. Protection of Personal Data
    We strive to protect the security of your Personal Data in accordance with Data Protection Laws from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

  8. Retention of Personal Data
    We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable Data Protection Laws.

  9. Governing Law
    This Privacy Policy shall be governed in all respects by the laws of Singapore.