Privacy Policy

1. Introduction
   • Lanturn Pte. Ltd. and Lanturn Fund Services Pte. Ltd. (“Lanturn”, “we”, “us” or “our”) comply with Singapore’s Personal Data Protection Act 2012 (“PDPA”). We recognise the importance of the personal data that you have provided to us and believe that it is our responsibility to properly manage, protect and process your personal data. Please read this Privacy and Data Protection Policy (“Policy”) to understand what personal data is collected or processed by us, and for what purposes it is used.
   • Personal data is defined in the PDPA as “data, whether true or not, about an individual who can be identified — (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access”.
   • The purpose of this Policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process your personal data. Any changes to this Policy will take effect upon publication on our Website. We recommend that you check this page from time to time.
   • By providing personal data to us, you acknowledge that we may collect, use, disclose and process your personal data in accordance with this Policy and the applicable laws. You are responsible for ensuring that all personal data provided to us is accurate, complete and up to date, and for informing us promptly of any changes.
2. Collection of Information
   • We may collect and process personal data including:

• Full name;
• Copy of NRIC and other government-issued identification details, where required by law or where necessary to establish or verify an individual’s identity;
• Copy of passport or other identification document;
• Telephone number(s);
• Residential address;
• Email address;
• Other personal information required by government agencies;
• Signature; and / or
• Photo/video of yourself and your identification document.
  • We collect, use and process personal data for the purposes of providing our corporate, accounting, payroll, employment agency, nominee director, registered address and related services; communicating with clients; conducting customer due diligence and anti-money laundering checks; complying with legal and regulatory obligations; maintaining client records; processing payments; administering the Platform; improving our services; and, where permitted by law, sending marketing communications regarding our products and services.
  • The data protection provisions in the PDPA (parts III to VI) do not apply to:
• Any public agency or organisation in the course of acting on behalf of a public agency in relation to the collection, use or disclosure of the personal data.
• Business contact information. This refers to an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his or her personal purposes.
  • Our Website is set up to automatically collect anonymous information about visitors to help us understand our website visitors and their traffic patterns, to determine when visitors access our Website, which devices they use for statistical purposes and to improve our service.
  • We do not sell personal data and will only disclose personal data to authorised third parties for legitimate business, legal, regulatory or service delivery purposes.
  • We use email, the Platform and messaging applications to communicate with clients regarding their requests and the services provided.
  • We will occasionally notify you of our new services and corporate special offers via email updates. You may opt out of receiving marketing communications at any time.
  • We will notify you in advance when we collect information for the purposes other than listed above.

3. Disclosure

Except as set out below, or where required or permitted by applicable law, Lanturn will not disclose your personal data to third parties without your consent. The information provided by you may be disclosed by Lanturn to:

• government bodies and regulatory authorities;
• lawyers / accountants / auditors or other advisors of Lanturn;
• third party service providers, including cloud hosting, software, technology, communications, document management, accounting, payroll, customer relationship management, electronic signature and infrastructure providers engaged by Lanturn to provide, support and improve our services;
• any agents acting on our behalf; and / or
• other professional advisers / business partners / credit information companies / bureaus for the purpose of credit evaluation and debt recovery or collection.

4. Retention Limitation
   • We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws and regulations, including:

• Specific business requirements of services we provide to you; and
• Legal or regulatory requirements requiring us to retain the personal data after our business relationship has ended.
  • We may retain personal data after the termination of our relationship where required to comply with legal, regulatory, accounting, tax, anti-money laundering, corporate secretarial, audit or dispute resolution requirements.

5. Protection

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to secure the information.

6. Your Rights
   • You may request:

• access to your personal data;
• correction of inaccurate personal data;
• information regarding how we have used or disclosed your personal data; and / or
• withdrawal of consent (subject to legal and contractual restrictions).
  • Please note that withdrawal of consent may affect our ability to continue providing certain services or complying with our legal and regulatory obligations.

7. Overseas Transfers

Personal data may be transferred to and processed outside Singapore where our service providers, cloud infrastructure providers or business partners are located. Where we do so, we will take reasonable steps to ensure a standard of protection comparable to that required under the PDPA.

For further information, or to make a request relating to your personal data, please contact our Data Protection Officer at dpo@golanturn.com.