Privacy Policy

Types of personal information collected

This privacy statement explains our practices with regard to “Personal Information” collected by UPMAX for its business purposes. Personal information include any information that can be used (directly or indirectly) to identify, locate or contact you from that information alone or in combination with other information we process or can reasonably access. We may collect the following types of personal information:

Your personal identification information (which may include your name and passport information, your IP address, politically exposed person (PEP) status, personal data available in the public domain, details of your financial information, sources of wealth and your assets and such other information as may be necessary for UPMAX to provide its services and to complete its client due diligence process and discharge its KYC/AML/CFT obligations).
"Contact Information" that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages.
"Relationship Information" that helps us do business with you, such as the types of products and services that we provide to you or that may interest you, information on your company’s size, geographic locations, creditworthiness and demographics.
"Transaction Information" about how you interact with UPMAX, including purchases, inquiries, client account information, and information about how you use the UPMAX websites and applications.
If you apply for a position with us we may collect information relating to your past employment, professional qualifications and education, your nationality and immigration/residential status, opinions from third parties about you (such as references) and other details about you which may be gathered during the recruitment process. We may also review publically available information about you on your social media accounts.

We will not collect and process your sensitive personal information (which includes data relating to race or ethnic origin, religious beliefs, physical or mental health, or sexual orientation) unless we have obtained your explicit consent as may be required under applicable law.

This Privacy Policy (“Policy”) outlines the accountability and obligations of UPMAX Group and applies to all its subsidiaries and affiliates (collectively “UPMAX”, “us”, “our” or “we”) in relation to the collection, use and disclosure of your personal data.

Our Group Personal Data Policy applies to all UPMAX companies within the UPMAX Group worldwide. In this Privacy Statement, ‘UPMAX’ refers to UPMAX Group, and any other UPMAX company whose websites link to this Privacy Statement. Every UPMAX company must respect privacy and protect personal information that is entrusted to it. This Privacy Statement explains how UPMAX collects, uses, maintains, protects, and discloses personal information from our websites or as part of our services.

We may update this Policy from time to time to ensure that it is consistent with the way we process your personal data and/or any changes in laws and regulations applicable to UPMAX Group. Other UPMAX companies may have their own privacy statements, although their practices are always governed by the Group Personal Data Policy.

By continuing to use our services, you signify that you have read and understood this Policy.

Methods of collecting personal information

In the majority of cases, we collect personal information directly from you or from third parties. For example, we may collection your personal information from your authorised representatives and advisor(s), your employer, our corporate clients where we are providing services to them, our service providers of referees, in the case of prospective employees. We may ask you for personal information (including contact information and relationship information) when you interact with us, such as registering on our websites, signing up to receive a newsletter, or making a purchase. We may collect additional relationship information from third party search information suppliers who can help us better understand our clients.

We collect transaction information when you purchase services or products from UPMAX. We also collect transaction information when you visit our website, use our applications or contact us, such as for client service purposes.

If you interact with us online, we use cookies and other technological tools to collect information about your computer and your use of our website and applications. We treat this information as personal information when it is associated with your contact information. For more information about cookies and other technologies, please see the section cookies and other data collection technologies below.

Use of personal information

UPMAX may use your personal information to:

Fulfill your requests for services or products and for related activities, such as service and product delivery, client service, account management, support and training and to provide other services related to your relationship with UPMAX;
Provide our corporate clients with services or products and for related activities, such service and product delivery, client service, account management, support and training and to provide other services related to their relationship with UPMAX;
Provide you with direct marketing communications and offers for services and products from UPMAX and in some cases, our partners, including offers targeted based on your interests, business characteristics and location, in each case, subject to your consent (which includes an indication of no objection) where required under applicable law;
Comply with laws, regulations, and guidelines applicable to us and/or other members of the UPMAX Group;
Administer surveys, market research, and promotional events;`
Determine if you are eligible for certain products, services, or offers;
Provide you with additional information that may be of interest, such as UPMAX news and announcements and technical service bulletins;
Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance, business continuity and complaint, claim or litigation management; and
Consider job applicants for employment.

We may not always rely on consent as a legal basis for processing your personal information although we will seek your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

GDPR (General Data Protection Regulation) statement

To ensure that your personal data is protected at all times, we have adopted the principles of the General Data Protection Regulation of the European Union (GDPR) as the minimum level of protection afforded to your personal data. Wherever a law requires a higher level of protection to be afforded your personal data, then such higher level shall apply.

We only send you the most relevant information in the private and corporate services, taxation and auditing industries, hand-picked by our dedicated team of professionals, who are individuals that value the privacy of personal information just like you.

Fail to provide personal information

Where we need to collect personal information by applicable law or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with goods or services). In those circumstances, we may have to cancel a product or services you have with us. We will seek to notify you if this is the case at the relevant time.

Direct marketing

In connection with direct marketing, UPMAX intends to use your personal information, which include but not limited to your name, contact information (such as phone number, email address and mailing address), business characteristics and geographical location in order to send to you marketing communications on the services and products that are offered by UPMAX from time to time through telephone, text (SMS), email, post, push notification and any other electronic means. Such services and products may include but not limited to private and corporate.

If at any time you do not wish for us to continue to use your personal information for direct marketing purposes and do not wish to receive any direct marketing materials, you may opt out from direct marketing by notifying us at the contact information set out below.

Information sharing

We will share your personal information with third parties only in the ways that are described in this privacy policy. We share personal information within UPMAX's international network. UPMAX may include disclosures or transfers to third party agents, suppliers or contractors, in connection with the processing of your personal information for the purposes described in this privacy statement. For example, we may disclose or transfer your personal information to third party agents who provide administrative, storage, information technology, security, communication, compliance, payment and other data processing services. Where necessary, UPMAX will endeavor to take reasonable steps to ensure that data processing agreements are entered into with such third party agents, suppliers or contractors to ensure that they process your personal information, on our behalf, with the same level of security and confidentiality as applied by UPMAX. We do not sell your personal information to third parties.

We may also provide your Personal Information to other parties to the extent required or provided by law, regulation or court order, for example if we are under a duty to disclose your personal information in order to comply with any legal or regulatory obligation such as our KYC/AML/CFT obligations or if we have agreed to assist with any tax or other regulatory filing requirements.

as required by law, such as to comply with a subpoena, or similar legal process;
when we believe, in good faith, that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
if we are involved in a merger, acquisition, or sale of all or a portion of our assets (in which case you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information); and
to any other third party, with your prior consent to do so.

We may provide your personal information to companies that provide services to help us with our business activities (such as processing your order/payment, registering your business or offering client service). These companies are authorised to use your personal information only as necessary to provide these services.

We may disclose your personal information for the purposes of seeking references and confirmation of the details which you have provided should you apply for a position with us.

Cookies, data collection & tracking technologies, analytics

When you visit our website or use our mobile applications, we collect certain transaction information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

For example, when you visit our website, we place cookies on your computer. Cookies are small text files that websites send to your computer or other internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the “help” section of your browser to learn about cookie preferences and other privacy settings that may be available. If you reject cookies, you may still use this site, but your ability to use some areas of this site will be limited.

We collect many different types of information from cookies and other technologies. For example, we may collect information from the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address assigned to the device you use to connect to the internet. An IP address is a unique number that devices use to identify and communicate with each other on the internet. We may also collect information about the website you were visiting before you came to UPMAX and the website you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in a non-identifiable way, without any reference to personal information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

In some cases, we do associate the information we collect using cookies and other technology with your personal information. This privacy statement applies to the information when we associate it with your personal information.

We partner with a third-party ad network to either display advertising on this site or to manage our advertising on other sites. Our ad-network partner uses cookies and web beacons to collect non-personally identifiable information about your activities on this website, and other websites, to provide you with targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you with targeted ads, you may opt out by clicking here.

Please note this does not opt you out of being served with advertising. You will continue to receive generic ads.

One of the third party vendor used by UPMAX is Google Analytics. For information on how Google Analytics uses data please visit “How Google uses data when you use our partners’ sites or apps”, located at https://policies.google.com/technologies/partner-sites.

Your rights

You have the following rights in respect of the personal information about you that we process:

Access to your information. You have the right to access the personal information that we hold about you at any time.
Data portability. You may ask us to provide you with a copy of the personal information that we hold about you.
Correction of your personal information. You have the right to ask us to update and correct any out-of-date or incorrect personal information that we would hold about you.
You have the right to object to automatic decision making.
Deletion of your personal information (the right to be forgotten). You have the right to ask us to delete your personal information, to the extent that we have no legal and/or regulatory obligations to keep such personal information.
Restriction of processing of your personal information. You have the right to ask us to restrict the processing of your personal information where:

∙ You have contested the accuracy of the personal information held by us;
∙ The processing is unlawful, but you have objected to the deletion of the personal data and request the restriction of the use instead;
∙ We no longer need the personal data for the purposes of the processing, but you require it for legal reasons;
∙ You have objected to processing and we are investigating whether there are legitimate grounds to override your objection.

Object. You have the right to object at any time to the processing of your personal data for any direct marketing (and related profiling) by us. In addition, you have the right to make a complaint with the local supervisory authority with respect to the way we are processing your personal data or the way we are handling your rights. However, the rights you have to object are not absolute and are subject to various limitations; we reserve the right not to comply with a request, if we believe such limitation is applicable.

Please note that even if you opt-out of promotional emails, we may still need to contact you with important Transaction Information about the services or products we are providing or will provide to you or the organisation you work for. For example, even if you opt-out of emails, we may still send you activity confirmations and account statements.

If you have any questions about your rights, choices or if you need any assistance with opting-out, please contact us via email to info@upmaxgroup.com. You can also write us at the address in the how to contact us section below. If you send us a letter, please provide your name, address, email address, and information about the communications that you do not want to receive.

Automatic decision making

We never base our decisions on purely automatic means.

Security

The security of your personal information is important to us. We are committed to providing the highest level of security and privacy. All online actions, including processing debit/credit-card payments, are carried out securely using technology, supported by your browser, which encrypts all information that is sent to us. We use the best commercially available encryption on the internet. When you enter sensitive information (such as debit/credit-card, bank-account or proprietary-business information) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We take every precaution to protect your personal information from loss, misuse, unauthorized access, release, alteration or destruction, and keep personal information only for the purpose you have provided it for.

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

Please note that you should also take steps to protect yourself and your personal information, especially online. When you register at UPMAX websites, choose a strong password, and do not use the same password that you use on other sites. Do not share your password with anyone else. UPMAX will never ask you for your information and/or password in an unsolicited phone call or in an unsolicited e-mail. Also remember to sign out of the website and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if others have access to your computer.

Third party privacy

This privacy statement only addresses the use and disclosure of information by UPMAX. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. Our affiliates, suppliers and business partners have their own privacy policies too. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

News, articles, insights, jurisdiction update & other areas

Our websites may provide news, articles, insights(include market), jurisdiction update and other areas where you can communicate with others and publicly post information. Prior to posting in these areas, please read our terms of use carefully. You have no privacy rights in public postings. All the information you post will be accessible to anyone with internet access, and any personal information you include in your posting may be read, collected, and used by others. For example, if you post your email address, you may receive unsolicited messages. Please use caution when posting any personal information.

Partnership & intermediaries

If you have applied for partnership and intermediaries with UPMAX, the personal information submitted with your application may be added to our support team and used for partnership program and other customary human resources purposes. You have the right to withdraw consent to personal information by contact us at info@upmaxgroup.com.

Job applicants

If you have applied for employment with UPMAX, the personal information submitted with your job application may be added to our support team and used for recruitment and other customary human resources purposes. You have the right to withdraw consent to personal information by contact us at info@upmaxgroup.com.

Protection of personal data

We are committed to ensuring the security of your personal data. We take appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data. We will ensure a level of security suitable to the identified risks and pursuant to applicable data protection laws and, where the processing concerns personal data of EU residents, shall take measures required pursuant to article 32 of the GDPR.

Our employees are trained to handle personal data securely and with utmost respect and they will treat your personal data strictly confidential. Staff members shall be authorized to access personal data only to the extent necessary to serve the applicable legitimate purposes for which the data is processed by us and to perform their job. In addition, all our employees have committed themselves to the confidentiality of the personal data of our clients, as a condition of their employment.

International transfers and data storage

We process and store personal data on cloud-based databases which are held on servers located in a third country assessed by the European Commission to have adequate level of protection by means of an adequacy decision. We may disclose and transfer personal data to other companies of the UPMAX located outside the European economic area, while, if applicable, taking additional measure to ensure the same level of protection.

Where we disclose or transfer personal data to third parties, outside the European economic area, we ensure that special safeguards are adopted to ensure that the protection travels with the personal data and where required we ensure the transfer is subject to a contract incorporating model contractual clauses in the form adopted by the European Commission (as amended from time to time)

If disclosure or transfer of personal data is being done in a country that does not ensure an adequate level of protection of your personal data, we will make sure additional safeguards will be put in place.

Data retention

We will process and store the relevant personal data for the duration of our services or for the duration of the business relationship. We may also store the data for as long as it is necessary or required in order to fulfill legal, contractual or statutory obligations and, or for the establishment, exercise or defense of legal claims, and in general where it has a legitimate interest for doing so.

To determine the appropriate retention period for personal information, we will consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of personal information, the purposes for which we process personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Change of purpose

We will only use personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use any personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process personal information without your knowledge or consent, in compliance with the above, where this is required or permitted by law.

Changes to this policy

We may update this privacy policy to reflect new or different privacy practices. If we make any material changes, we will notify you by means of a notice on this site prior to the change becoming effective.
We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting us

You have the right to request access to, correction or erasure of personal information that we hold about you. All requests will be reviewed and processed in accordance with applicable law.

If you would like to access, correct, or erase your personal information or if you have any questions, comments or complaints (e.g. if you believe that UPMAX has not handled your personal information properly or that it has breached its privacy obligations) or opt out from direct marketing at any time, please contact UPMAX’s office of privacy & data governance in the following ways:

Email address: info@upmaxgroup.com

Postal address: 10 Collyer Quay #40, Ocean Financial Centre, Singapore 049315

The privacy officer will investigate any complaint and notify the individual within reasonable time-frame of the outcome of the investigation.

Please note this updated version of our privacy statement does not substantively change the way we treat personal information in comparison to the previous version of the privacy statement available historically on our websites.