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Privacy Policy
Last updated: December 15, 2024
1. Introduction
TitulMogli Financial Planning ("we," "our," or "us") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website titulmogli.com or use our financial planning services.
2. Information We Collect
2.1 Personal Information
We may collect the following types of personal information:
Contact Information: Name, email address, phone number, mailing address
Financial Information: Income, assets, liabilities, investment goals, risk tolerance
Identification Information: NRIC number, passport details, date of birth
Professional Information: Employment details, occupation, employer information
Family Information: Marital status, dependents, beneficiary details
2.2 Automatically Collected Information
When you visit our website, we may automatically collect:
IP address and browser information
Pages visited and time spent on our website
Referring website or source
Device type and operating system
Cookies and similar tracking technologies
3. How We Use Your Information
We use your personal information for the following purposes:
3.1 Service Provision
Providing financial planning and advisory services
Conducting financial analysis and creating personalized recommendations
Managing your account and maintaining client records
Processing transactions and managing investments
3.2 Communication
Responding to your inquiries and requests
Sending service-related notifications and updates
Providing educational content and market insights
Marketing our services (with your consent)
3.3 Legal and Regulatory Compliance
Complying with Singapore's Personal Data Protection Act (PDPA)
Meeting regulatory requirements by the Monetary Authority of Singapore (MAS)
Preventing fraud and ensuring security
Maintaining records as required by law
4. Legal Basis for Processing
We process your personal information based on:
Consent: You have given clear consent for specific purposes
Contract: Processing is necessary for our service agreement
Legal Obligation: Required by Singapore law or regulation
Legitimate Interest: For our business operations and your benefit
5. Information Sharing and Disclosure
5.1 We may share your information with:
Service Providers: Third-party vendors who assist in our operations
Financial Institutions: Banks, insurance companies, investment platforms
Professional Partners: Lawyers, accountants, other financial advisors
Regulatory Bodies: MAS, IRAS, and other authorities as required
5.2 We do not sell or rent your personal information to third parties for marketing purposes.
6. Data Security
We implement appropriate technical and organizational measures to protect your personal information:
Encryption of sensitive data in transit and at rest
Secure servers and databases with restricted access
Regular security assessments and updates
Employee training on data protection practices
Multi-factor authentication for system access
7. Data Retention
We retain your personal information for as long as necessary to:
Provide ongoing services to you
Comply with legal and regulatory requirements
Resolve disputes and enforce agreements
Meet professional indemnity insurance requirements
Generally, we retain client records for at least 7 years after the end of our relationship, or as required by applicable laws.
8. Your Rights
Under Singapore's PDPA, you have the following rights:
8.1 Right to Access
Request information about the personal data we hold about you
8.2 Right to Correction
Request correction of inaccurate or incomplete personal data
8.3 Right to Withdraw Consent
Withdraw your consent for specific processing activities
8.4 Right to Data Portability
Request transfer of your data in a structured, machine-readable format
8.5 Right to Object
Object to processing based on legitimate interests or direct marketing
To exercise these rights, please contact us using the information provided below.
9. Cookies and Tracking Technologies
9.1 Types of Cookies We Use:
Essential Cookies: Necessary for website functionality
Analytics Cookies: Help us understand website usage
Marketing Cookies: Used for targeted advertising (with consent)
9.2 Managing Cookies
You can control cookies through your browser settings. However, disabling certain cookies may affect website functionality.
10. International Data Transfers
If we transfer your personal information outside Singapore, we ensure appropriate safeguards are in place:
Adequacy decisions by relevant authorities
Standard contractual clauses
Binding corporate rules
Certification schemes
11. Children's Privacy
Our services are not directed to individuals under 18. We do not knowingly collect personal information from children without parental consent.
12. Updates to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by:
Posting the updated policy on our website
Sending email notifications to registered users
Providing notice during your next interaction with us
13. Contact Information
If you have questions about this Privacy Policy or our data practices, please contact us:
14. Complaint Resolution
If you believe we have not handled your personal information appropriately, you may file a complaint with:
Our Data Protection Officer (contact details above)
Personal Data Protection Commission Singapore (PDPC)
Monetary Authority of Singapore (MAS) for financial services matters