Privacy Policy

What information we collect and store

We collect and process the following categories of personal data that you provide to us or that are generated automatically when you browse our Website:

• Identity data – your full name, e‑mail address, postal address and telephone number;
• Account credentials – such as your username and password (where you create an account);
• Marketing preferences and any correspondence you send to us;
• Transaction data relating to any payments or investments you make through the Website;
• Technical and usage data – including Internet Protocol (IP) address, browser type and version, time‑zone setting and location, browser plug‑in types, operating system and platform, device identifiers and information on how you interact with our Website; and
• Any other information that you choose to provide.

We do not intentionally collect any special categories of personal data (also called ‘sensitive personal data’) unless you choose to provide it.

With whom we share your personal data

We only disclose your personal data to:

• our group companies and affiliates on a need‑to‑know basis;
• trusted service providers who help us operate, maintain and secure the Website or who assist us with analytics, cloud hosting, payment processing, marketing and professional advice, subject to strict contractual obligations of confidentiality and data protection;
• competent regulatory, law‑enforcement and governmental authorities where we are legally obliged or authorised to do so; and
• any other third party where you have expressly consented or instructed us to make the disclosure.

We do not sell your personal data to third parties.

Children’s privacy

This Website is not directed at children under the age of 13 years (or 16 years for residents of the European Economic Area). We do not knowingly collect personal data from anyone in those age brackets. If you are a parent or guardian and believe that your child has provided us with personal data, please contact our Data Protection Officer and we will promptly delete such information.

Analytics programmes

This Website employs Google Analytics 4 to help us understand how users interact with the Website and to improve its performance. Google Analytics collects information about your device and browsing behaviour in a pseudonymised form. You may opt out of Google Analytics by installing the Google opt‑out browser add‑on available at https://tools.google.com/dlpage/gaoptout/.

Information retention

We retain personal data only for so long as is reasonably necessary to fulfil the purposes for which it was collected, to satisfy any legal, regulatory, tax, accounting or reporting requirements, or to resolve disputes. In determining appropriate retention periods we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use, the purposes of processing and whether those purposes can be achieved by other means. When retention is no longer justified, we securely delete or anonymise the data.

Direct marketing

We will send you electronic marketing communications only where we have obtained your express consent or where we are otherwise permitted to do so under Singapore’s Personal Data Protection Act 2012 (‘PDPA’) and applicable EU legislation. You may withdraw your consent or object to marketing at any time by following the unsubscribe instructions in the message or by contacting us using the details below. We will honour your choice within a reasonable period and in any event within 10 business days, in accordance with the PDPA’s Do Not Call provisions.

Your rights

Depending on your location, you may have one or more of the following rights in relation to your personal data:

• Access – to request a copy of the personal data we hold about you;
• Rectification – to correct inaccurate or incomplete personal data;
• Erasure – to request deletion of your personal data where the data is no longer necessary or where the processing is unlawful (‘right to be forgotten’);
• Restriction – to request that we restrict the processing of your personal data;
• Portability – to receive your personal data in a structured, commonly used and machine‑readable format and to transmit that data to another controller;
• Objection – to object at any time to processing carried out for direct marketing purposes or based on our legitimate interests;
• Automated decisions – not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects; and
• Complaint – to lodge a complaint with the Personal Data Protection Commission (Singapore) or with the supervisory authority in your habitual residence or place of work within the European Economic Area.

These rights are subject to certain limitations and exemptions under applicable data‑protection legislation.

Exercising your rights

To exercise any of these rights please contact our Data Protection Officer at legal@merifund.com or write to us at 16 Raffles Quay, Hong Leong Building, Singapore 048581. We may need to verify your identity before fulfilling your request and may ask for additional information solely for this purpose. We endeavour to respond to all legitimate requests within one calendar month. Where your request is particularly complex we will keep you informed and may extend this period by a further two months.

Location of data processing

Your personal data is processed in Singapore and Luxembourg.

Transferring data

If we transfer personal data from the European Economic Area (‘EEA’) or the United Kingdom to a country that has not been recognised by the European Commission as providing an adequate level of protection (such as Singapore), we implement appropriate safeguards, including the Standard Contractual Clauses approved by the European Commission, supplementary technical and organisational measures, and intra‑group data‑transfer agreements where relevant. A copy of the safeguards may be obtained by contacting us.