Privacy Policy
Terms and Conditions
The following terms and conditions (“Terms”) govern the use of our website www.steelblue-stork-980747.hostingersite.com (“Website”) operated by Farro Capital Pte. Ltd. (“we”, “us”, or “our”). By accessing or using our website, you agree to abide by these Terms. If you do not agree with any part of these Terms, you are advised not to use our website.
Who we are and how to contact us?
Farro Capital Pte Ltd. is a Capital Markets Service License (CMS) Holder from Monetary Authority of Singapore (MAS). We are a regulated organization, incorporated and headquartered in Singapore. We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website and use our services.
Our full details are:
Legal Name: Farro Capital Pte Ltd.
Address: 3 Phillip St, #08-01 Royal Group Building, Singapore 048693
Email: info@steelblue-stork-980747.hostingersite.com
Phone: +65 65399975
If you have any questions about this Privacy Policy or our privacy practices, please contact our Data Protection Officer at info@steelblue-stork-980747.hostingersite.com or at the address above.
By using our site, you accept these terms
By accessing or using the website of Farro Capital (“our site”), you acknowledge that you have read, understood, and agree to be bound by these terms of use (“Terms”). These Terms govern
your use of our site and form a binding contractual agreement between you and Farro Capital. If you do not agree to these Terms, you are advised not to use our site.
We recommend that you either print a copy of these Terms or save them to your computer for future reference. We may amend these Terms from time to time. Every time you wish to use our site, please check these Terms to ensure you understand the terms that apply at that time.
There are other terms that may apply to you:
Privacy Notice: Our Privacy Notice outlines the manner in which we process any personal data collected from you, or that you provide to us. By using our site, you consent to such processing, and you warrant that all data provided by you is accurate.
Cookie Policy: Our Cookie Policy provides information about the cookies on our site, including how we use them and how you can manage or delete them.
Please take the time to read and understand these additional terms, as they form part of our contractual agreement with you when using our site.
We may make changes to these terms.
We reserve the right to amend these terms of use at our discretion and at any time. Whenever we make changes to these terms, we will post the updated terms on our site and, where appropriate, notify you by email or through a notice on our site.
It’s advisable that you review these terms periodically to stay informed of any changes. By continuing to use our site following the posting of changes, you accept and agree to the revised terms.
We may make changes to our site.
We may update and change our site from time to time to reflect changes to our products, services, our users’ needs, or our business priorities. Whenever we make changes to these terms, we will revise the updated date at the bottom of this page.
It’s important that you review these terms of use periodically to stay informed of any changes. By continuing to use our site after changes to these terms are made, you acknowledge and agree to be bound by the revised terms.
We may also provide notifications of changes to these terms or other matters by displaying notices or links to notices generally on the site, or by sending you an email.
We may suspend or withdraw our site.
Our site is made available free of charge. We do not guarantee that our site, or any content on it, will always be available or be uninterrupted. We may suspend, withdraw, discontinue, or change all or any part of our site without notice. We will not be liable to you if for any reason our site is unavailable at any time or for any period.
You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms of use and other applicable terms and conditions, and that they comply with them.
Privacy Notice
This Privacy Notice is applicable to customers and prospective customers of FARRO CAPITAL Pte. Ltd. (“FARRO CAPITAL”). It elucidates how we will collect, process, and manage the personal data we hold about you, along with delineating your rights under the Personal Data Protection Act (PDPA) of Singapore concerning the data held.
FARRO CAPITAL will act as the Data Controller as defined under the Personal Data Protection Act of Singapore legislation and regulations.
Lawful Basis and Purpose for Processing Your Data
We will process your personal data only when there is a legal basis for doing so, as detailed below:
Consent: Where you have provided explicit consent for us to process your data for a specific purpose.
Contractual Necessity: Where processing is essential for the performance of a contract to which you are a party, or to take steps at your request before entering such a contract.
Legal or Regulatory Obligation: Where processing is necessary for compliance with a legal or regulatory obligation to which FARRO CAPITAL is subject.
Legitimate Interests: Where processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data.
Any decision to process data based on legitimate interests will be made on a case-by-case basis and in alignment with the guidance set forth in the Personal Data Protection Act of Singapore.
The information that we collect.
We collect personal data from you at various stages of your relationship with us, including at the outset, during your application process, and throughout the course of our ongoing relationship. This data may be collected directly from you, from third parties you authorize to act on your behalf, or from other third parties such as your financial adviser or providers transferring money or assets to us at your instruction.
The categories of personal data we may collect include, but are not limited to:
Contact Information: Including name, address, telephone numbers, and email addresses.
Communication Records: Including voice recordings from telephone calls, letters, and emails exchanged with us.
Socio-demographic Information: Such as age, employment status, profession, earnings, gender, and other sources of wealth.
Family Circumstances: Including marital status and beneficiary information.
Transactional Information: Such as account transactions and access to our online client portals.
Identification and Legal Documentation: Including national identifiers, copies of documents relating to your identity, nationality, and citizenship such as birth certificates, passports, proof of address documents, and marriage certificates.
Special Category Data (if necessary): Such as information relating to your health, including medical conditions and disabilities.
We handle your personal data with the utmost care and in compliance with the Personal Data Protection Act of Singapore. The processing of your personal data is necessary for the provision of services to you, compliance with legal obligations, and for other legitimate interests pursued by FARRO CAPITAL.
Sharing your personal data
We may share your personal data within FARRO CAPITAL and with third parties who provide services related to the administration of your account. The circumstances under which we may disclose your personal data are as follows:
Service Providers: We may share your personal data with third-party service providers involved in the administration of your account.
Legitimate Business Purposes: We may disclose your personal data for legitimate business reasons, or as necessitated by law and regulations, to your Financial Adviser, third parties appointed by your Financial Adviser, third-party investment managers, and product providers with whom you or your Financial Adviser instructs us to invest.
Credit Reference Checks: We may disclose your personal data to credit reference agencies to verify your details during the application process and for the ongoing administration of your account. This helps prevent fraud, money laundering, and verifies your identity. Please note that these checks may be recorded on your credit history.
Legal, Regulatory, or Governmental Bodies: We may disclose your personal data to legal, regulatory, or governmental bodies if required by applicable law and regulations.
Sensitive Personal Data: With your consent or instruction, or that of your Financial Adviser, we may need to disclose sensitive personal data, such as health information, to third parties to effectuate instructions regarding your account.
International Transfers: We may transfer your personal data to another country, ensuring that your personal data is afforded the same level of protection as required under the Personal Data Protection Act of Singapore legislation and regulations prior to the transfer. We are committed to maintaining the confidentiality of your personal data and will not use it for any other purpose, nor share it with third parties without your explicit consent, except as outlined in this section or required by law.
Retention of your personal data
We are committed to retaining your personal data only for the duration necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
The retention period for personal data may vary based on the nature of the services provided, the terms and conditions applicable to your account, and our legal or regulatory obligations. Typically, we will retain your personal data for a period of seven years from the end of our relationship, in accordance with regulatory requirements.
Under certain circumstances, we may retain personal data for longer periods if necessary for legal proceedings, investigations, or other significant obligations.
We may also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
At the end of the retention period, we will securely delete or destroy your personal data in accordance with applicable laws and regulations.
Your Data Protection Rights
Under the Data Protection laws, you possess several rights concerning your personal data. These rights include:
Access: You have the right to request a copy of the personal data we hold about you. This is known as making a Subject Access Request (SAR). In most instances, this will be provided free of charge, however, for repeated requests or further copies, an administrative fee may be applied.
Data Portability: You have the right to have your personal data transferred securely to another service provider in electronic form.
Rectification: You have the right to have any inaccurate personal data we hold about you corrected.
Erasure: You have the right to have any out-of-date personal data deleted, provided there’s no business necessity or legal requirement for us to retain it.
Processing Restrictions: You have the right to object or restrict processing in certain circumstances, particularly when we do not have legitimate grounds for processing your personal data.
Marketing Opt-out: You have the right to object to your personal data being used to send you marketing material. We will only send you marketing material where you’ve provided consent, and you may withdraw this consent at any time.
We are committed to honoring these rights in accordance with the applicable legal and regulatory requirements. If you wish to exercise any of these rights, please contact us using the information provided in the ‘Who We Are and How to Contact Us’ section of this Privacy Policy.
Important Information
If you have any inquiries or concerns regarding our data handling practices, please feel free to contact us at info@hotpink-hippopotamus-721257.hostingersite.com. We are committed to addressing any issues you may have concerning your personal data.
Should you not be satisfied with our response or handling of your data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Further information regarding your rights under the Personal Data Protection Act of Singapore can be accessed on the ICO’s website at https://www.pdpc.gov.sg/overview-of-pdpa/the-legislation/personal-data-protection-act.
By signing our product application form, you provide consent for us to use your personal information for the purposes and under the terms stipulated above. Please note that you have the right to withdraw your consent at any time.
Cookies
Our website utilizes cookies to distinguish you from other users, which aids in providing a personalized browsing experience and allows us to improve the functionality and user-
friendliness of our site.
Here are the categories of cookies we may use:
Strictly Necessary Cookies: These are essential for the operation of our site, enabling you to navigate and use the features of our site.
Performance Cookies: These cookies collect information about how visitors use our website, for instance, which pages visitors go to most often, and if they receive error messages from web pages. The information collected by these cookies is aggregated and therefore anonymous.
Functionality Cookies: These are used to recognize you when you return to our site, enabling us to personalize our content for you and remember your preferences.
Targeting/Advertising Cookies: These cookies record your visits to our site, the pages you have visited, and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests.
You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled.
For more information on managing and deleting cookies, visit the help pages of your browser or see www.allaboutcookies.org. For more detailed information about the cookies we use, please contact us at info@hotpink-hippopotamus-721257.hostingersite.com.
Changes to this Privacy Notice
We may update our Privacy Notice from time to time to reflect changes in our data processing practices, changes in legal or regulatory requirements, or for other purposes. Any changes we make to our Privacy Notice in the future will be posted on this page.
We encourage you to review this Privacy Notice periodically to stay informed about how we are protecting and using your personal data. If we make any significant changes to this Privacy Notice that materially alter our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our website.
Your continued use of our website and services after any changes to this Privacy Notice constitutes your acceptance of the updated policy.
Contact
Should you have any questions, comments, or requests pertaining to this Privacy Notice, we warmly invite you to reach out to us at the following contact details:
Email: info@farrocapital.com
Postal Address: 3 Phillip St, #08-01 Royal Group Building, Singapore 048693
Phone: +65 65399975
We are committed to addressing your inquiries and providing you with the necessary information concerning our privacy practices.
Web Policy
Protecting the confidentiality and security of personal information is integral to the way in which Farro Capital Ltd. conducts its business worldwide. We at Farro Capital Ltd. are committed to safeguarding the privacy of our clients and use it in accordance with our privacy principles set out below while providing our services to them. The following are major points from our updated Privacy Policy statement that will help to explain the data processing practices of our businesses.
Introduction
In accordance with the GDPR, applicable EU data protection legislation and the DIFC Data Protection Law. Farro Capital Ltd. , being the data controller for the purposes of this application for its services, must provide you with information on how your personal data will be processed.
Purposes of processing and lawful basis of processing
The personal data collected from you, provided by you, or obtained from other sources on your behalf will be held, disclosed and processed by Farro Capital Ltd. for the purposes of offering you our services and maintaining the relationship with you. We process personal data only when we have a lawful purpose. Presently, we use your personal
data for the following lawful purposes:
- Performance of Contract
- On receiving your application with the subscription money and signed Investment Management/Subscription Agreement (IMA) along with you providing the required documentation as specified in the IMA, Farro Capital Ltd. shall carry out the account opening process.
- Managing and administering your portfolio and any related account on an ongoing basis which involves your personal data for redemption, distribution of payments and for future subscriptions.
- Disclosures to third parties identified in the IMA/Offering Memorandum such as auditors, regulatory, tax authorities and technology providers;
- Recording, maintaining, storing and using recordings of telephone calls that you make to and receive from Farro Capital Ltd. , the Administrator, or the Manager and their delegates or duly appointed agents and any of their respective related, associated or affiliated companies for processing and verification of instructions, management and administration of your account(s) and any other matters related to your investment with Farro Capital Ltd. , dispute resolution, record keeping, security and/or training purposes.
- Circulating periodic reports.
- Responding to queries or providing you support.
- For any other purpose as provided for in the Agreement between us.
- Compliance with legal obligations
- Complying with any applicable legal, Tax or regulatory obligations imposed on the Portfolio Manager including legal obligations under the Companies Act, Tax Laws and the AML regulations including but not limited to:
- AML: in line with anti-money laundering requirements under the PMLA, the DFSA AML regulations and other related regulations set by globally recognized AML agencies, all investors are required to be identified. For this purpose, certain documentation will be required at the time of application as set in the IMA.
- CRS/FATCA: Farro Capital Ltd. is obliged to collect certain information about each investor’s tax arrangements. For CRS/FATCA reporting purposes, please note that in certain circumstances Farro Capital Ltd. may legally be obliged to share this information and other financial information with respect to investor’s interest with the relevant tax authorities under relevant jurisdictions.
- Screening – Farro Capital Ltd. shall engage in screening for the purpose of AML regulations and counter terrorist facing legislations including PEP screening and with UN, EU and other applicable sanctions regimes.
- Complying with any applicable legal, Tax or regulatory obligations imposed on the Portfolio Manager including legal obligations under the Companies Act, Tax Laws and the AML regulations including but not limited to:
- Legitimate interest
- Carrying out statistical analysis and market research;Recording, maintaining, storing and using recordings of telephone calls that you make to and receive from Farro Capital Ltd. , the Administrator
- Consent
From time to time, Farro Capital Ltd. may send you information about financial markets etc., by telephone, by email or by other reasonable means of communication. You have the right not to receive such information. Your consent is not required to process your personal data for the purposes referenced above. However, in order to process your personal data for the purposes of direct marketing, Farro Capital Ltd. seeks your consent.
You have a right to withdraw this consent at any time. However, your withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. You can withdraw your consent by contacting Farro Capital Ltd. at the address above. - Disclosures to data processors and / or third parties
Personal data relating to you which is collected from you or provided by you or on your behalf may be handled by Farro Capital Ltd. or their duly appointed agents and any of their respective related, associated or affiliated companies for the purposes specified above.
These data processors will handle your information in accordance with applicable Data Protection Legislation.
Farro Capital Ltd. may disclose your personal data to other third parties where required by law or for legitimate business interests. This may include disclosure to third parties such as auditors and the regulatory bodies, taxation authorities and technology providers. - Transfers Abroad
Since we are an international company, your data will be processed outside of the EU region or the DIFC. Personal data collected from you or provided by you or on your behalf may be transferred outside of transactions originating jurisdiction including to companies situated in countries which may not have the same data protection laws. Such data transfers will only involve companies which are part of the same corporate group or acting as service providers to the Farro Capital Ltd. - Retention period
Farro Capital Ltd. will retain your personal information for as long as is needed to fulfil the purposes outlined in our Privacy Policy, unless a longer retention period is required or permitted by law. - Security Measures to Protect your Data
We maintain reasonable and appropriate security measures to protect Customer Data from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Our information security controls ensure that personal and financial data is well protected and accessible only to authorised personnel. - Your data protection rights
Your data protection rights are as under:- You have a right of access to and the right to amend and rectify your personal data.You have the right to have any incomplete personal data completed.You have a right to be forgotten (right of erasure of personal data)You have a right to restrict processing.You have a right to data portability.You also have the right to object to processing where Farro Capital Ltd. is processing personal data for legitimate interests.You have the right to withdraw your consent used for Direct Marketing
Additionally, you have a right to lodge a complaint with a supervisory authority, in particular, in the State of your habitual residence; place of work or place of the alleged infringement if you consider that the processing of personal data relating to you carried out by Farro Capital Ltd. is not as per the regulation in force.
You may request for your rights as outlined above by submitting your written request to us via:
Data Privacy Officer:
Rajiv Garg
Farro Capital Ltd.
Address: Unit C1406-A, Level 14, Burj Daman,
Dubai Financial Centre, Dubai, UAE
Email : dpo@farrocapital.com
Other Points:
We do not track your online activities across the Internet. We do not use your personal information for automated decision making, including profiling. We do not sell or rent your personal information to third parties.
Refusal to provide personal data:
The provision by you of personal data, as outlined in the section titled “Purposes of processing and lawful basis for processing” is required for us to accept your application and manage and administer your portfolio and so that we can
comply with the contractual, tax, legal and regulatory requirements referenced above. Where you fail or refuse to provide such personal data, we may not be able to perform the contract we have entered into with you, or we may be prevented
from complying with our legal obligations.