Privacy Policy
Barbican Advisory Holdings Pte. Limited (registration number 202334086G), registered in Singapore at 8 Cross St, #24-03/04 Manulife Tower, Singapore (“Barbican”) operates the website www.barbicanadvisory.com (the “Site”). Barbican may refer to Barbican Advisory Holdings Pte. Limited, its subsidiaries and group members.
Barbican is committed to protecting personal data and privacy in accordance with applicable data protection laws, including the Personal Data Protection Act in Singapore, EU General Data Protection Regulation 2016/679, as incorporated into UK legislation ("GDPR"), Personal Data (Privacy) Ordinance in Hong Kong and legislation in which Barbican’s group members and subsidiaries operate (“Relevant Legislation”).
Barbican will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this Policy.
Collection of Data
Barbican collects, receives, stores and processes information about individuals which may constitute personal data under Relevant Legislation. This includes the following information:
Information you provide when using the Site, including information you provide when you register for access on this site, information you supply when contacting us through this site, and information you provide when sending communications to us;
Information you provide when applying for a job at Barbican, including information provided in your CV or application;
Information needed to perform services requested by you, including contact details, financial information, billing information.
The information supplied for the above purposes may include names, addresses, telephone numbers, email addresses, dates of birth, educational details, banking and financial details and any other additional information that you may supply, or which may be otherwise processed.
The legal basis for the collection of data includes one or more of the following:
Necessary for entering into or performing a contract, to administer and operate services in accordance with the contract, and for carrying out our obligations under such a contract
Necessary for compliance with a legal obligation which requires us to process your personal data.
Necessary for the purposes of legitimate interests, including:
Responding to requests and enquiries
Maintaining client relationships
Informing you about our services
For recruitment purposes, including confirming your background and references and to consider your suitability for current or future recruitment requirements
To carry out an employment relationship and fulfil our duties as an employer (for employees)
Exercising and defending our legal rights including in relation to any litigation, disputes or contentious matter we and/or to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals, subject to applicable law
To carry out money laundering and conflict checks for fraud and financial crime purposes
Ensuring our operations are conducted in an efficient manner
This is provided we have established that those interests do not override your rights, including your right to have your personal data protected.
In some circumstances, we may ask for your consent to process your personal data in a particular way. You will have the right to withdraw this consent at any time.
Disclosure of Personal Data to Third Parties
Barbican does not sell, rent or trade your personal data.
We may disclose personal data to third parties when we have your consent.
We may disclose personal data to third parties in cases where we have engaged the third party specifically to assist with our firm’s activities to satisfy the purpose for which the personal data was initially collected. Any such third parties whom we engage will be bound contractually to keep all information confidential.
We may disclose personal data to other member firms of Barbican, where it is necessary (i) to meet the purpose for which you have submitted the information; or (ii) for the purposes described above. We may also transfer all data in our possession to a successor-in-interest to our business or assets. This will be only in circumstances where the successor-in-interest has agreed to the same standards as set out in this policy.
We may be required by law to disclose your personal data to a regulatory body, government agency, court of competent jurisdiction, regulatory body or law enforcement agency in response to a lawful request.
Some of these third parties may not be in jurisdictions that provide a level of data protection equivalent to GDPR. Barbican ensures that all transfers to third parties in non-equivalent jurisdictions are subject to adequate safeguards required under Relevant Legislation.
Your Rights
Access to Personal Data
Upon request, we will provide you with access to your personal data or other appropriate information on your personal data in accordance with the requirements of the Relevant Legislation.
Withdrawal of Consent
Upon reasonable notice being given of your withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of your personal data, we will inform you of the possible consequences of withdrawing your consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorized under applicable laws.
Accuracy and Correction of Personal Data
We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete. If your personal data is found to be inaccurate, we will correct any inaccuracies or mistakes in a timely fashion.
Erasure or Objection to Processing of Personal Data
In certain circumstances, you have the right to request that personal data we hold about you is erased. In certain circumstances, you have the right to object to our processing of your personal data by contacting us using the details at the bottom of this page.
Data Portability
In certain circumstances, you have a right to receive any personal data that we hold about you in a structured, commonly used and machine-readable format, provided you have provided the data to us previously; and it is processed by us using automated means.
Processing
In certain circumstances, you have the right to object to our processing of your personal data and/or the right to restrict our use of your personal data by contacting us using the details at the bottom of this page.
Children
We understand the need to protect children's privacy. We do not knowingly collect or use any personal information from children. We do not knowingly allow children to visit our website or use our services.
Security and Protection of Personal Data
We maintain appropriate physical, administrative, and technical safeguards to protect your personal information and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Barbican follows a dedicated IT security policy. Only authorized Barbican personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.
We have measures to detect, investigate and report data breaches. We will notify you in a timely manner if any unauthorized access to your personal data has been detected.
Retention of Personal Data
We will cease to retain your personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention or such retention is no longer necessary for legal or business purposes.
Personal information must be kept to be available for legal or regulatory compliance reasons (in which case Barbican will archive such information and implement reasonable measures to prevent the information from any further processing). Retention deadlines vary depending on the type of data and the need to delete obsolete data is assessed on a case-by-case basis.
Data Processed During Provision of Services
When we provide our services, we may control or process personal data on people who are subjects of, or related to, those services. Barbican may be deemed the controller or processor of this data depending on nature of the data and the project.
Generally, we do not rely on consent as a legal basis for processing personal data because it would interfere with the purpose the processing of such data in relation to providing due diligence services. We handle all such data according to GDPR or other applicable data protection laws.
Personal data obtained typically includes information on an individual’s profile or reputation. This data is obtained from interviews and open-source information (such as court records, corporate records, news articles, social media, and specialised databases).
The lawful basis of the collection or processing of such data depends on the nature of the data and the project, but may include:
Necessary for our or our client’s legitimate interests. These reasons may be to ensure the client toes not take actions that result in legal liability, adverse reputation, or other negative outcomes;
Necessary to prevent, detect or identify an illegal act;
Necessary to establish, exercise or protect a legal right;
Where it is in the vital interest of the subject or a third party;
Where the data subject has already shared the data publicly.
We may share the data with third parties, including other Barbican parties, our client and their advisers who have a legal basis to use this data, and our partners who help us collect the information.
Individuals whose data is processed when we serve our clients have the same rights as any other data subjects and we protect their data as required by the law and this Privacy Policy. Please see above for more information, and the Contact section below for how to exercise your rights.
Data Protection Officer
If you believe that information we hold about you is incorrect or out of date, or if you have concerns or further queries about how we are handling your personal data, or any problem or complaint about such matters, please contact our Data Protection Officer.
When you contact us, we will ask you to verify your identity.
Contact name: Data Protection Officer
Email: DPO (at) barbicanadvisory.com
Post: 8 Cross St, #24-03/04 Manulife Tower, Singapore
This Privacy Policy is subject to changes and amendments from time to time.
Get in Touch
We are always happy to talk through issues and discuss potential strategies. Don’t hesitate to contact us and find out more about how we can help.
