Privacy Policy

Effective Date: 19th October 2016

The following Privacy Policy describes how Gateway Management Company Pte. Ltd. and GWP Management Limited (“Gateway” or “we“) collect, use, disclose, transfer and/or process data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which Gateway has or is likely to have access (“Personal Data“) in connection with the services available from Gateway through the website located at http://www.gatewayfund.net (“Site“). By visiting the Site, you consent to the collection, use, disclosure, transfer and/or processing of your Personal Data as described in this Privacy Policy.

GWP Management Limited (“Gateway Dubai“) is allowed to collect Personal Data by the Commissioner of Data Protection of the Dubai International Financial Centre (“DIFC”) and it processes, stores and transfers personal data in accordance with notification made to Commissioner of and in line with the DIFC Data Protection Law No. 1 of 2007 and its regulations thereunder.

On occasion, Gateway may revise this Privacy Policy to reflect changes in the law, our Personal Data processing practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect, use, disclose, transfer and/or process your Personal Data, those changes will be posted in this Privacy Policy and the effective date will be changed at the beginning of this Privacy Policy. If you do not agree with any changes or modifications to the Privacy Policy, please do not continue using the Site. You will be deemed to have consented to any modification of the Privacy Policy when you use the Site after the effective date of the modification.

 

Information We Collect

We may collect Personal Data about you that you provide to us when using the Site or when sent to us via other means, such as electronic mail or by agents whom you have authorised to release such data. Such information may include your name, phone number, physical address, net-assets, income and e-mail address. We assume all Personal Data provided by you is accurate and up-to-date.

We may also collect other information which may be linked to your Personal Data, including your IP address, geographic data, operating system type, and search preferences related to specific searches as well as other generic Internet usage related data.

 

How We Use and Disclose the Information We Collect

We may use Personal Data and other information collected through the Site for reasonable business purposes, including (a) to confirm your qualifications to access the Site; (b) to respond to your questions or comments submitted on the Site; (c) to build features that will make the services available on the Site easier to use; (d) for an improved user experience and general optimization purposes; and (e) to contact you from time to time.

We may share your Personal Data with third parties we appoint to perform services on our behalf, such as (a) web hosting; (b) data analysis; (c) search engine optimization; and (d) responding to queries received by you.  All such third parties will be under an obligation to maintain the security and confidentiality of the Personal Data, and to process the Personal Data only in accordance with our instructions.

Save for disclosures mentioned in this Privacy Policy or as required or permitted by law in any relevant jurisdiction, we will not disclose your Personal Data to third parties without your consent. However, we reserve the right to disclose your Personal Data to our affiliated (group) companies, including our affiliated (group) companies’ employees and our trusted agents and representatives who have access to this information with our permission and who need to know or have access to this information for selected purposes in and outside Singapore, Dubai and Cayman Islands. All such parties will be under an obligation to maintain the security and confidentiality of the Personal Data, and to process the Personal Data only in accordance with our instructions.

Gateway may, in compliance with applicable law, disclose Personal Data to protect ourselves against liability, to respond to subpoenas, judicial processes, lawsuits, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, or protect our legitimate interests.

 

Protecting Your Personal Data

To prevent unauthorized access to your Personal Data, we maintain reasonable physical, electronic and organizational procedures to protect Personal Data against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. Personal Data is stored in a secure database that is only accessible to authorised employees of Gateway and other members our affiliated (group) companies.

 

Retention of Your Personal Data

Gateway will retain Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of Gateway, or as required by relevant laws. 

When destroying Personal Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with applicable laws.

 

How You Can Access or Correct Your Personal Data

Under the Access and Correction Obligation, any member of the public may request access to their personal data under Gateway’s possession, enquire about the ways their personal data has been used over the past year, or submit a complaint with regards to Gateway’s application of the Personal Data Protection Act. To protect your privacy and security, we will verify your identity before granting access or making changes to your Personal Data.
Such requests or complaints should be directed to the Data Protection Officer in either Singapore or Dubai (contact details below).

All requests and/or complaints should be made via email. The requestor/complainant will be notified in advance of any administrative fee that will be imposed for such requests.

Requests and/or complaints will be promptly investigated by the relevant Data Protection Officer, and the requestor/complainant will receive a formal response following the completion of that investigation.

Singapore Data Protection Officer
Angelica Tan
#06-01A Suntec Tower Two
9 Temasek Blvd
Singapore 038989
Angelica.tan@gatewayfund.net

You may also contact our Singapore Data Protection Officer at the following number: +65 6908 7404 or any other number that we may advise from time to time.

Dubai Data Protection Officer
David Fennell
2203 North Tower
Emirates Financial Towers
DIFC, Dubai 507080
United Arab Emirates
David.fennell@gatewayfund.net

You may also contact our Dubai Data Protection Officer at the following number: +971 (0)4 518 5911 or any other number that we may advise from time to time.

 

Governing Law

You agree that this Privacy Policy and any disputes relating to this Privacy Policy shall be governed in all respects by the laws of Singapore. Any dispute relating to the above shall be subject to the exclusive jurisdiction of the Singapore courts.

 

Terms of Use

Please consult the Gateway Terms of Use for more details on using our Site. This Privacy Policy forms an integral part of our Terms of Use.