AdviserCOT | Privacy Policy

Last updated: 29 May 2025

This Privacy Policy explains how AdviserCOT's team (“we”, “our”, or “us”) through the use of our software collects, uses, discloses, and safeguards your personal data and your clients’ data when you use AdviserCOT (“the App”).

We are committed to protecting the privacy of financial advisers using the App in Singapore and the confidentiality of their clients' personal data.

1. Scope

This Policy applies to all users of the App, including web and mobile versions, and covers:

Your personal data as a user of the App

Personal data you upload or input into the CRM system, including your clients’ data

2. Types of Data Collected

2.1 Adviser Data (Your Data)

We may collect the following personal data from you when you register and use the App:

• Full name and professional details
• NRIC or license number (not at the time of writing)
• Email address and contact information
• Company or agency affiliation
• Login and usage activity
• Device information (e.g., IP address, browser type)
• Any other information you voluntarily provide or input during registration or use of the App

2.2 Client Data (CRM Data)

• Full name, date of birth, and contact information
• Financial and insurance information
• Meeting notes and documentation
• Other data entered voluntarily into the App
• You are responsible for ensuring that your clients have given consent for their data to be collected and processed via the App.

3. How We Use the Data

We use data to:

• Provide you with access to the App and CRM features
• Store and back up Client Data securely
• Improve our services and support
• Comply with legal and regulatory obligations
• We do not use your Client Data for marketing, profilling (other than profilling your clients solely for Your use), or resale.

4. Disclosure of Data

We shall not share or disclose your data or Client Data except in any of the following cases:-

• With your explicit permission
• When required by law or legal process
• To our service providers who assist in hosting, security, or operations (bound by strict confidentiality agreements)

5. Data Protection Measures

• Passwords are stored in an encrypted form and cannot be read by us or anyone else.
• All data is encrypted in transit using TLS/SSL protocols.
• More measures are planned to be implemented in the future as the app becomes available for public use.

6. Role-based access controls

• Secure infrastructure hosted on Railway.com, in data centers located in Singapore.
• Access to your data is restricted to you and authorized personnel only. The list of authorized personnel is maintained by the App's administrators and available upon request.
• However, no system is completely secure. Users are responsible for safeguarding their own credentials.

6. Data Retention

• Your account and data will be retained for as long as your account remains active or as required by law.
• Upon account deletion or termination, we will delete or anonymize your data within 60 days unless retention is legally required.
• You may request data export or deletion by contacting us.

7. Your Responsibilities

As a user of the App, you agree to:

• Obtain proper consent from clients before collecting or entering their personal data into the CRM
• Use the App in compliance with the Personal Data Protection Act 2012 (PDPA) and all MAS regulations

8. International Transfers

• All data is stored and processed in data centers located in Singapore. We do not transfer personal data overseas unless explicitly consented and protected by safeguards compliant with PDPA.

9. Access and Correction

You may:

• Access your own personal data in your account settings, or by contacting us with ample verification of your identity
• Request correction of inaccurate data
• Request export or deletion of CRM data you’ve uploaded (where legally permissible)
• Please contact us at the email below for assistance.

10. Updates to this Policy

We may update this Privacy Policy periodically. When we do, we will notify you through the App or email. Continued use of the App after changes constitutes your acceptance of the revised policy.

11. Contact Us

If you have questions or wish to exercise your rights under the PDPA, please contact our Data Protection Officer (DPO):

Email: admin@advisercot.com