Privacy Policy

1. Who is responsible for your data

This Site is operated by NIIU CAPITAL PTE. LTD. (UEN 202116898G), a company incorporated in Singapore with its registered address at Level 42, Suntec Tower Three, 8 Temasek Boulevard, Singapore 038988. In this policy, “srs.sg”, “we”, “us” and “our” mean NIIU CAPITAL PTE. LTD. That company is the organisation responsible under the PDPA for personal data collected through the Site.

We have designated a Data Protection Officer. All questions, access and correction requests, withdrawals of consent and complaints about personal data should be sent to the Data Protection Officer at info@srs.sg, or by post to the address above. We aim to acknowledge within 3 business days and to respond substantively within 30 days.

2. What we collect, and when

We collect only what you give us. We do not buy personal data, and we do not collect it from third parties.

• Calculators and reports. The figures you enter are processed in your browser to show a result. When you ask us to email you a report, we collect your name, email address and mobile number, and record that you gave consent and when.
• Contact form. Your name, email address, mobile number, the enquiry type you chose, and anything you write in the message box.
• Booking a review. Your name, email address and mobile number. If — and only if — you tick the separate box asking us to send your figures ahead, we also store the calculator figures behind that booking so the adviser has them before the call.
• Newsletter. Your email address only.
• Will writing.The information needed to produce a will: your name, identification number, gender, marital status, and contact details; your assets and how you wish to distribute them; and the names, identification numbers and relationships of your beneficiaries, executors, trustees, guardians and children (including a child’s date of birth). See section 4.
• Adviser referral. Where you are routed to adviser assistance, your name, email address and mobile number.
• Technical data. Your IP address is used transiently to rate-limit form submissions and to verify the anti-bot check; we do not build a profile from it. Our analytics provider collects aggregate usage data about pages and visits.

Do not send us more than we ask for. Please do not include account numbers, passwords, health information or other sensitive details in a free-text message box.

3. Why we use it

We use personal data only for the purpose you gave it for:

• to produce and send the report, plan or document you asked for;
• to respond to your enquiry, and to arrange and conduct a review you booked;
• where you consented, to have a licensed adviser from our panel contact you about retirement and financial planning, and to pass them what they need to do so;
• to send the newsletter, where you subscribed to it;
• to operate, secure and improve the Site, including preventing spam and abuse;
• to keep records of consent, and to comply with legal obligations.

We do not use your data to make automated decisions that produce legal effects. The calculators do arithmetic on figures you supply; they do not assess or score you.

4. Identification numbers, and the will flow

The Personal Data Protection Commission restricts the collection of NRIC and FIN numbers to situations where it is required by law, or necessary to identify a person to a high degree of fidelity. A will is such a situation: it must identify the testator and each beneficiary unambiguously, or the gift may fail. We therefore collect identification numbers only within the will-writing flow, and only for the people who must appear in the document.

• No other tool on this Site asks for an identification number, and you should never enter one anywhere else on the Site.
• If you hold a FIN, the will tool does not apply to you and your identification number is never collected. You are routed to adviser assistance instead, where we take only your name, email address and mobile number.
• You are providing other people’s personal data — your beneficiaries, executors and children. Please only provide what is needed, and only where you are entitled to. Where a child is named, you are providing that data as their parent or guardian.
• A will in progress is held so you can come back to it. The “continue my will” link is secured by a one-time token, of which we store only a hash, and which is cleared once used. Anyone holding that link may see what you entered, so keep it private.
• We do not store your signed will. The document is yours once you download it, and we cannot produce a copy for you or for your estate.

5. Who we share it with

We do not sell personal data, and we do not share it for anyone else’s marketing. We disclose it only as follows.

• A licensed financial adviser from our panel, where you consented to be contacted. They receive your name, contact details, which tool you came through, and — if you ticked the box for it — your calculator figures. Once they hold it, they are responsible for it as a separate organisation under the PDPA. As stated in our Terms of Use, we receive no commission or referral fee for this.
• Service providers who operate the Site for us, acting on our instructions: website hosting, the database, transactional email delivery, appointment scheduling, bot protection and rate-limiting, and analytics. They may process data only to provide those services.
• Where the law requires it, or to establish, exercise or defend legal claims.

Sponsors do not receive your personal data. Sponsorship and paid content fund the Site, as our Terms of Use explain, but a sponsor gets no access to enquiries, leads or anything you enter.

6. Transfers outside Singapore

Some of the service providers above store or process data outside Singapore. Where personal data is transferred out of Singapore, we take reasonable steps to ensure it receives a standard of protection comparable to that under the PDPA, including by contract with the provider. You may ask us for more detail about a particular transfer.

7. Consent, and how to withdraw it

We rely on your consent, given by ticking a box that says what it is for. Providing your data is voluntary — but if you do not provide what a tool needs, we may not be able to give you the report, document or response you asked for.

Do Not Call. Where you tick a consent box to be contacted, that is treated as clear and unambiguous consent in evidential form for the purposes of the Do Not Call provisions of the PDPA, and allows us and the adviser to contact you by telephone, text message and email about your enquiry, notwithstanding any registration on the Do Not Call Registry. This is the same position stated in our Terms of Use.

You may withdraw consent at any time by writing to info@srs.sg, or by using the unsubscribe link in any newsletter. We will act on it within a reasonable period, usually 10 business days for marketing and 30 days generally. Withdrawal is not retrospective: it does not undo what was already done, and we may still need to contact you about something already underway, or keep records we are required to keep.

8. Your rights of access and correction

You may ask us what personal data we hold about you and how it has been used or disclosed in the past year, and you may ask us to correct anything inaccurate. Write to the Data Protection Officer at info@srs.sg. We may need to verify your identity first, and we may charge a reasonable fee for an access request, telling you the amount before we proceed. In limited cases the PDPA permits us to refuse a request; if so, we will tell you why.

You may also ask us to delete your data. Where we no longer need it for the purpose it was given, and no legal obligation requires us to keep it, we will.

9. How long we keep it

• Leads and enquiries are kept while the enquiry is open and for up to 24 months after the last contact, so an adviser has context if you come back. Archived leads keep the record of your consent — which is itself a PDPA requirement — until deletion.
• Calculator figures attached to a booking are a snapshot, overwritten by a later booking and deleted with the lead.
• Will data is kept while you are writing the will and for a limited period afterwards so you can resume. Ask us and we will delete it sooner.
• Newsletter subscriptions are kept until you unsubscribe.
• We cease to retain personal data when the purpose it was collected for no longer applies and retention is no longer necessary for legal or business purposes.

10. How we protect it

We take reasonable technical and organisational measures to protect personal data: encrypted connections, access controls that limit each adviser to the leads assigned to them, hashed credentials and one-time links, rate limiting and bot protection on public forms, and administrative access restricted to those who need it.

No system is perfectly secure, and we cannot guarantee the security of data in transit over the internet. If a data breach occurs that is likely to result in significant harm, or that meets the notifiable threshold under the PDPA, we will notify the Personal Data Protection Commission and affected individuals as the Act requires.

11. Cookies and analytics

The Site uses cookies and similar technologies that are necessary for it to function, and an analytics service that helps us understand which pages are used. Analytics data is aggregate and is not used to identify you. You can block or delete cookies in your browser settings; parts of the Site may not work correctly if you do.

12. Children

The Site is intended for adults. The will-writing tool requires you to be at least 21. We do not knowingly collect personal data directly from anyone under 18. Where a child’s details appear in a will, they are provided by the parent or guardian writing it, not by the child.

13. Third-party sites

The Site may link to other websites. This policy does not apply to them, and we are not responsible for their handling of your data. Read their policies before giving them anything.

14. Changes to this policy

We may update this policy from time to time. The date at the top shows when it was last changed. Where a change materially affects how we use your data, we will take reasonable steps to bring it to your attention.

15. Complaints

If you are unhappy with how we have handled your personal data, please tell our Data Protection Officer at info@srs.sg so we can put it right. If you remain dissatisfied, you may complain to the Personal Data Protection Commission of Singapore.

16. Contact

Data Protection Officer, NIIU CAPITAL PTE. LTD. (UEN 202116898G), Level 42, Suntec Tower Three, 8 Temasek Boulevard, Singapore 038988 — info@srs.sg — or through our contact page.