TP ICAP Group (“we”, “us”, “our”) is committed to safeguarding personal data, personal information or sensitive information (collectively, “Personal Information”), as defined under applicable data protection laws. 

This notice (“Privacy Notice”) applies to all TP ICAP Group entities operating in the Asia Pacific region and sets out how and why Personal Information may be collected, used, disclosed and processed by us and provides other information as required by applicable data protection laws including how we respect individual rights. 

By interacting with us, submitting information to us, or requesting that we provide you with broking services offered by us (“Services”), you agree and consent to us and our representatives and/or agents collecting, using, disclosing and processing your Personal Information within the TP ICAP Group and to our authorised service providers and relevant third parties.

Personal Information we may collect about you 

Personal Information we may collect about you includes:

(a) Identification data, i.e. full name, title, gender, marital status, date of birth, identification number, signature, address, beneficial ownership information etc.
(b) Information received in respect of clients or other individuals known to clients, invoicing details and payment history.
(c) Information about individual participation in conferences and in-person seminars, credentials, associations, product interests, and preferences, newsletter requests, event registrations, dietary, subscriptions, downloads, and username/passwords.
(d) Information provided by job applicants in connection with employment opportunities.

Collection, use, disclosure and processing of your Personal Information

We collect, use, disclose and process your Personal Information:-

(a) to provide you with Services and ongoing account administration or client onboarding purposes, including monitoring and analysing the conduct of your account, assessing any credit limit or other credit decision and enabling us to carry out statistical and other analysis and otherwise market services to you, including disclosure to our affiliates, third parties such as professional advisors, service providers, regulatory bodies, auditors, technology providers, and any duly authorised agents of the foregoing for the same purpose;
(b) to comply with legal and regulatory obligations, including in relation to financial promotion, applicable anti-money laundering and counter terrorist financial legislation as well as tax reporting, know-your-client and fraud protection and prevention obligations;
(c) for our internal business processes, including providing support to our staff and maintenance and carrying out of an internal investigation;
(d) enforce our standard terms and conditions of business and any other agreements;
(e) protect our and our clients’ rights, property, or safety;
(f) process employment applications;
(g) to provide you with news, general information about the Services and events which we offer that are similar to those that we have provided to you unless you have opted not to receive such information (including marketing any of TP ICAP Group entity’s services to you);
(h) to develop and display content and advertising (and work with third-party vendors who do so) tailored to your interests and/or location and to measure its effectiveness; and 
(i) to evaluate or conduct a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about you is among the assets transferred.

If you do not consent to our collection, use, disclosure or processing of your Personal Information, we may not be able to provide you with our Services or proceed with your recruitment application. 

By submitting your Personal Information to us, you acknowledge that certain authorised third parties may collect, use, disclose and process your Personal Information. We will ask all third parties to treat your Personal Information securely and in accordance with this Privacy Notice and will take reasonable steps to enforce this.

Personal Information from other sources

We may receive information from third parties that collect Personal Information from you and pass it on to us. For example, our clients, employees, publicly available sources or from third parties that collect Personal Information from you and pass it on to us: (a) in connection with Services that we provide to our clients; and (b) from past employers and others concerning your employment history when you apply for a job with us. 
Where this is the case, the third party is responsible for informing you that they have disclosed your Personal Information with us, direct you to this Privacy Notice and obtain any relevant consents from you as regards how your Personal Information may be used. However, once we are holding such Personal Information, we will only handle your Personal Information in accordance with this Privacy Notice.

Similarly, when you provide Personal Information on behalf of another individual, you are responsible for notifying that individual that you have provided their Personal Information to us and directing them to this Privacy Notice so they can see how we will collect, use, disclose or process their Personal Information. 
Where we receive data from an entity, such entities are responsible for ensuring that any such data is transferred to us in compliance with applicable data protection laws.

Where you or your employer (or any other entity you work for) provide services to us, you and/or they may provide us with some of your Personal Information in connection with the provision of such services. We will only collect, use, disclose or process such Personal Information in connection with the provision of the services and in accordance with this Privacy Notice.

Transfers of Personal Information overseas

We may transfer Personal Information overseas to any country in which TP ICAP Group operates for a purpose for which the data was collected or for a directly related purpose in providing our Services. We will take reasonable steps to ensure these procedures comply with applicable data protection laws, including our obligation to ensure that the recipient of the Personal Information is bound by legally enforceable obligations to provide such Personal Information a standard of protection that is at least comparable to the protection under applicable data protection laws.

Security Measures

We will take all reasonable steps to protect your Personal Information from unauthorised access and against unlawful collection, use, disclosure, processing, accidental loss, destruction, and damage. We maintain physical, electronic, and procedural safeguards to ensure the security of your Personal Information that we have collected and we restrict disclosure and access to your Personal Information only to recipients on a need to know basis for the purposes set out above through employee training, operating procedures and written policies, including this Privacy Notice. Where we become aware that your Personal Information has been compromised by a data breach (as defined by the applicable data protection laws), we will make reasonable efforts to notify you in a timely manner.

Further, we only retain your Personal Information for as long as we have a legitimate business interest to do and in line with applicable data protection laws.

Enquiries

Enquiries concerning the Personal Information provided to us, including lodgement of complaints,withdrawal of consent, or the request for deletion, access or corrections, should be addressed to: 

APAC Data Privacy Officer 

50 Raffles Place
#41-00 Singapore Land Tower
Singapore 048623
Tel: +65 6831 0888 
Email: APACDataPrivacy@tpicap.com