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Privacy Policy

SJS Partners and its related bodies corporate (collectively, "SJS Partners", "we", "our", or "us") are committed to the rigorous protection of personal data. This Privacy Policy outlines our data governance framework governing the collection, processing, disclosure, and retention of personal information.

1. Introduction and Scope

This policy applies to our regional operations, including our presence in Singapore, Australia, Indonesia, and Malaysia, and is intended to support alignment with the Australian Privacy Principles (APPs) and the Singapore Personal Data Protection Act (PDPA).

2. The Information We Collect

In executing our corporate advisory, capital structuring, and platform administration mandates, we may collect the following classifications of personal data:

  • Identity & Onboarding Data: Full legal names, dates of birth, residential addresses, passport or national identification details, and corporate directorships required for Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Know Your Client (KYC) obligations.
  • Financial & Transactional Data: Asset registers, banking details, investment histories, source of wealth declarations, and tax residency information.
  • Professional Data: Employment history, professional affiliations, and qualifications relevant to determining Wholesale or Sophisticated Investor status.
  • Technical & Interaction Data: IP addresses, device identifiers, site telemetry, and records of correspondence, including securely recorded telecommunications where legally required or consented to.

3. Purpose of Collection and Processing

We adhere to the principle of data minimization. Your personal data is collected exclusively for legitimate business purposes, including:

  • Structuring and executing capital advisory mandates and investment platform administration.
  • Verifying your identity to satisfy statutory AML/CTF and sanctions compliance.
  • Assessing suitability for specific financial products, wholesale fund distributions, or structural formations.
  • Facilitating corporate actions, dividend payments, and trust operations.
  • Defending our legal rights and responding to lawful requests from regulatory authorities, including ASIC and MAS.

4. Cross-Border Disclosure of Data

Given SJS Partners' integrated operational structure across the Asia-Pacific, your data may be stored or processed in jurisdictions outside of your home country. We implement strict, legally binding data transfer agreements to help ensure that any overseas recipient maintains data protection standards commensurate with the APPs and the PDPA.

5. Third-Party Disclosures

SJS Partners maintains strict confidentiality protocols. We do not monetize your data. Disclosures are limited to:

  • Fiduciary partners, including custodians, registries, and legal counsel engaged in your specific mandate.
  • Regulators, tribunals, and law enforcement where mandated by statutory compulsion.
  • Reputable third-party infrastructure and compliance service providers.

6. Data Retention and Security

We deploy appropriate technical and organizational safeguards, including access controls and authentication measures, to prevent unauthorized access, modification, or data exfiltration. Personal data is retained only for the statutory periods required by relevant financial and corporate legislation, typically seven years post-engagement, after which it is securely destroyed or de-identified.

7. Your Rights

Subject to applicable laws, you hold the right to:

  • Request access to the personal data we hold about you.
  • Request correction of inaccurate or outdated information.
  • Withdraw consent for specific data processing activities, noting that this may impede our ability to execute services.

Contact

To exercise these rights, or to lodge a formal privacy complaint, please contact our Data Protection Officer at info@sjs.partners.