This Privacy Policy explains what you can expect from us and what we need from you in relation to your personal data. Please read this carefully as this Privacy Policy is legally binding when you use our Services.

​​We want you to understand why and how Bowen and Fitzhugh Holdings Pte Ltd. and Bowen and Fitzhugh Asset Management  Limited (“BFAML”, “we”, “us” and/or “our”) collects, uses, discloses and or/processes your Personal Data (as defined below) under Singapore’s Personal Data Protection Act 2012 (the “PDPA”), Hong Kong’s Personal Data Privacy Ordinance (Cap. 486) (the “PDPO”) and the European General Data Protection Regulation (the “GDPR”).

​This Privacy Policy (“Policy”) applies to you and all Individuals (as defined below) who provides BFAML with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by  BFAML in connection with and/or for the purposes of its operations.

​This Policy supplements but does not supersede or replace any previous consent which you may have provided to BFAML, nor does it affect any legal rights that BFAML may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data.

BFAML may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at the BFAML website. Notification of any material revisions will also be published on the BFAML Website. You shall be deemed to have accepted the Policy as amended by continuing your relationship with Sleek after any amendments have been published on the BFAML Website.

​This Policy forms part of the terms and conditions, if any, governing your specific relationship with BFAML (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

​Our principles of data protection:

​At BFAML, we adhere to three fundamental principles that guide our approach to data protection. These principles form the foundation of all our activities involving personal data.

1. User Empowerment: We believe in granting individuals complete control over their data. You have the authority to make changes and decisions regarding your personal information as you see fit.

2. Transparency: Our commitment to data processing is rooted in openness, honesty, and transparency. We take a human-centric approach, ensuring you are fully informed about how we handle your personal data.

3. Security: We employ industry-leading measures to safeguard the personal data entrusted to us. Your privacy and the protection of your information are of utmost importance to us.

Definitions: For the purpose of this policy:

• “Individual” (or “you”) refers to a natural person, whether alive or deceased. “Individuals” (and “your”) are used accordingly.

• “Personal Data” refers to data that can identify an individual, either on its own or when combined with other accessible data held by BFAML.

• “Personnel” encompasses all individuals engaged under a contract of service with BFAML, including permanent or temporary employees, trainees, and interns.

• “Potential Personnel” refers to individuals who have submitted applications to be engaged as personnel at BFAML.

Purposes for collecting, using, and disclosing Personal Data:

BFAML will only collect, use, and disclose Personal Data related to an individual when it is reasonably necessary for the relevant purposes underlying such actions. These purposes may include, but are not limited to:

a) Facilitating the provision of BFAML’s products and services to you, including occasional newsletters, marketing materials, and pertinent information.
b) Engaging in communication with you to address your inquiries and provide assistance.
c) Managing administrative matters related to the products and services you have purchased or subscribed to.
d) Conducting market research and customer satisfaction surveys.
e) Notifying you of any other purposes for which we seek your consent (collectively referred to as the “Purposes”).

Collection of Personal Data:

BFAML generally collects Personal Data from individuals through one or more of the following methods or circumstances:

a) Direct provision of information: You may be requested to provide Personal Data when you visit or use specific parts of our websites or services. While it is not mandatory to provide your Personal Data, doing so may limit your access to certain areas or functionalities.

b) Automatic collection of information: Some information is collected automatically, such as IP addresses and device types, when you visit our websites or use our services. This information helps us better understand your interaction with our platforms and optimize your overall experience.

c) Information from third parties: While the majority of data is collected directly from you, we may also obtain information from other sources, such as publicly available information or trusted third parties. This data supplements the Personal Data we have collected from you.

When collecting Personal Data from third parties, we only use it if you have provided consent to both the third party and BFAML for processing your Personal Data. Alternatively, we may rely on our legitimate interest to use the Personal Data in evaluating your relationship with us.

The information we collect may include personal details such as your full name, contact information, copies of identification documents (e.g., NRIC or passport), telephone numbers, residential address, email address, biometric data, and other data required by government agencies. Additionally, we may collect information about your product and service preferences, as well as other data that can identify you. The collection of personal data occurs at various points, including but not limited to the following:

• Correspondence with you as a customer or prospective customer.

• Visiting our website or using our platform.

• Utilizing our software or services.

• Registering as an end-user and creating an account.

• Opting-in to our newsletter program.

• Participating in surveys.

• Voluntarily providing your information through our landing pages.

As part of our onboarding process, we are legally obligated to collect specific information from you due to regulation by the relevant authorities. To facilitate this, we may engage independent providers to perform identity checks on our behalf. During this process, you may be redirected outside of the BFAML platform. The information required depends on the specific check being conducted and may include images of identification documents, live videos, or other necessary data.

We encourage you to familiarize yourself with the privacy policy of the provider to gain a better understanding of how your data is processed.

Processing of Personal Data:
When we collect Personal Data, we will only process it:

a) To fulfill a contract with you.
b) When we have a legitimate interest in protecting the Personal Data that is not overridden by your rights.
c) In compliance with legal obligations.
d) With your consent.

Please note that if you choose not to provide us with your Personal Data or withdraw your consent for us to process it, we may be unable to provide some or all of our services to you or fulfill your requests. For job applicants, theprocessing of personal data is necessary for the evaluation of your application and potential employment with BFAML.

Disclosure of Personal Data:
BFAML may disclose your Personal Data to third parties in the following circumstances:

a) Service Providers: We may engage third-party service providers, contractors, or agents to perform services on our behalf or to assist us in providing our products and services to you. These service providers are bound by confidentiality obligations and are only authorized to use the Personal Data for the specified purposes.

b) Business Partners: We may disclose Personal Data to our business partners in connection with joint marketing initiatives or collaborations, provided that they agree to handle the information in accordance with applicable data protection laws.

c) Legal Compliance and Protection: We may disclose Personal Data if required to do so by law or if we believe that such disclosure is necessary to comply with legal obligations, protect our rights, property, or safety, or the rights, property, or safety of others.

d) Corporate Transactions: In the event of a merger, acquisition, or sale of all or a portion of our assets, Personal Data may be transferred as part of the transaction. We will take appropriate steps to ensure the security and confidentiality of the Personal Data during the transfer process.

e) With your Consent: We may disclose Personal Data to other third parties with your explicit consent.

International Transfers of Personal Data:

BFAML operates globally, and as such, your Personal Data may be transferred to, processed, and stored in countries outside of your own, including countries that may have different data protection laws from those in your jurisdiction. We will take appropriate measures to ensure that such transfers comply with applicable data protection laws and provide adequate protection for your Personal Data.

Retention of Personal Data:

BFAML retains Personal Data for as long as it is necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. The criteria used to determine the appropriate retention period include the nature of the Personal Data, the purposes for which it was collected, legal obligations, and business needs.

Your Rights and Choices:
As an individual whose Personal Data is processed by BFAML, you have certain rights and choices regarding your data:

a) Access and Correction: You have the right to access and update your Personal Data held by BFAML. If you believe that any information we hold about you is inaccurate or incomplete, please contact us to request its correction.

b) Withdrawal of Consent: You have the right to withdraw your consent for the processing of your Personal Data. Please note that withdrawing consent may affect our ability to provide certain services to you.

c) Object to Processing: You have the right to object to the processing of your Personal Data based on legitimate interests. We will assess your objection and, if justified, cease processing your Personal Data, unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms or if required for legal claims.

d) Erasure: You have the right to request the erasure of your Personal Data held by BFAML, subject to legal obligations and legitimate interests. We will assess your request and take appropriate action within a reasonable timeframe.

e) Restriction of Processing: You have the right to request the restriction of the processing of your Personal Data in certain circumstances. We will assess your request and, if applicable, limit the processing of your Personal Data.

f) Data Portability: You have the right to receive a copy of your Personal Data in a structured, commonly used, and machine-readable format and to transmit that data to another data controller, where technically feasible.

g) Marketing Communications: You have the right to opt-out of receiving marketing communications from us at any time. You can exercise this right by following the opt-out instructions provided in the communication or by contacting us directly.

h) Complaints: If you have concerns about how we handle your Personal Data or believe that we have not adequately addressed your data protection rights, you have the right to lodge a complaint with the appropriate data protection authority in your jurisdiction.

Updates to this Privacy Policy:
We may update this Privacy Policy from time to time to reflect changes in our data protection practices or legal obligations. We encourage you to review this policy periodically for any updates.

Contact Us:
If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your Personal Data by BFAML, please contact us using the contact information provided on our website. We will respond to your inquiry or request as soon as reasonably possible.

Please note that this is a general overview of our principles of data protection, and the specific details and practices may vary depending on the jurisdiction and applicable laws. It is always recommended to review the complete and up-to-date privacy policy provided by BFAML for the most accurate and detailed information.

If any provision of this Policy shall be held to be illegal, void, invalid, or unenforceable under the laws of any jurisdiction, the legality, validity, and enforceability of the remainder of this Policy in that jurisdiction shall not be affected, and the legality, validity, and enforceability of the whole of this Policy in any other jurisdiction shall not be affected.

Nothing in this Policy shall be construed as BFAML providing an indemnity to any Customer in relation to any Customer Data or use thereof. BFAML expressly excludes liability for any losses that the Customer may suffer on account of BFAML’s collection, storage, or use of Customer Data in accordance with this Policy. In any event, BFAML expressly excludes any liability to the Customer that is in the nature of indirect or consequential losses, special losses, loss of profits, loss of contracts, loss of reputation or goodwill, or other tangential or intangible losses that a Customer may suffer on account of a breach of this Policy by BFAML or any of its agents or service providers.