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This Privacy Policy is issued pursuant to the Personal Data Protection Act 2012 of Singapore (PDPA) and sets out how Cashchanger Pte Ltd (trading as TrueHarbour Group) collects, uses, discloses and protects personal data in connection with our website and business activities.
Cashchanger Pte Ltd (Company Registration No. / UEN: 201922960M), trading as TrueHarbour Group, is a private limited company incorporated in Singapore ("we", "us" or "our"). We operate the website at trueharbourgroup.com and provide equity capital markets advisory services to corporate and institutional clients globally. For data protection enquiries, please write to privacy@trueharbourgroup.com.
We may collect the following categories of personal data:
We do not intentionally collect special categories of personal data and request that you refrain from including such information in correspondence with us.
We collect personal data through: the contact form on our website; direct correspondence by email, Telegram or other messaging platforms; business card exchange or professional introductions; referrals from third parties such as introducers or business partners; and automated technologies (cookies and analytics tools) when you visit our website.
We collect and use personal data for the following purposes:
We will not use your personal data for purposes materially different from those stated above without first notifying you and, where required, obtaining your consent.
We may disclose your personal data to: licensed market maker partners in Germany and the United States, subject to appropriate confidentiality obligations; professional advisers including lawyers and accountants on a need-to-know basis; service providers operating our website infrastructure, email systems and analytics tools; and regulators or law enforcement authorities where required by law. We do not sell, rent or trade your personal data to third parties for marketing purposes.
As we work with licensed market maker partners and service providers outside Singapore (including in Germany and the United States), your personal data may be transferred to, stored or processed in jurisdictions outside Singapore. Where such transfers occur, we will ensure the recipient provides a standard of protection comparable to that under the PDPA, in accordance with Part IX of the PDPA and the PDPC's advisory guidelines on cross-border transfers.
We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. In practice: enquiry data where no mandate is entered into — up to 2 years from last contact; data relating to completed mandates — up to 7 years from completion, in accordance with Singapore's Limitation Act 1959; technical/analytics data — as configured in the relevant analytics tool (typically up to 26 months). Once no longer required, personal data will be securely destroyed or anonymised.
We implement reasonable administrative, technical and physical security measures to protect personal data against unauthorised access, use, disclosure or modification. While we take reasonable precautions, no transmission over the internet is completely secure. You acknowledge this inherent risk when communicating personal data to us electronically.
Under the PDPA, you have the right to: access personal data we hold about you; correction of inaccurate or incomplete personal data; and withdrawal of consent to the collection, use or disclosure of your personal data, subject to reasonable notice and legal or contractual restrictions. To exercise these rights, write to privacy@trueharbourgroup.com. We will respond within 30 days. You also have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore at www.pdpc.gov.sg.
Our website may use cookies and similar tracking technologies to enhance your browsing experience and collect technical data. You may configure your browser to refuse cookies; however, some features may not function correctly if you do so. We may use third-party analytics services such as Google Analytics in aggregated, anonymised form. You may opt out via the Google Analytics Opt-Out Add-on.
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites and encourage you to review their privacy policies separately.
We may update this Privacy Policy from time to time. The revised version will be posted on this page with an updated "Last updated" date. Where changes are material, we will notify you by email (if we hold your email address) or by prominent notice on our website. Your continued use of our website after any update constitutes acceptance of the revised Policy.
This Privacy Policy is governed by and construed in accordance with the laws of the Republic of Singapore. Any dispute arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Singapore.
For questions, concerns or complaints regarding this Privacy Policy or our data protection practices: