1. These Terms of Use are an integral part of the agreement between you and us in relation to any work we perform for you.


2. You must read the following information before proceeding. It provides information on some of the laws and regulations applicable to this website. By accessing this website and any pages thereof, you acknowledge that you have read the following information and accept the terms and conditions set out below and on the relevant pages of this website and agree to be bound by such terms and conditions. If you do not agree to such terms and conditions below, do not access this website, or any pages thereof. These Terms of Use are in addition to any other agreements between you and Finexis Asset Management Pte. Ltd. (“we” or “us”, (“FAM”), including any customer or account agreements, and any other agreements that govern your use of FAM’s products, services, content, tools, and information available on this website.


Your use of this website is governed by the version of the Terms of Use in effect on the date this website is accessed by you. The information contained in this website is current as at the date of publication but we reserve the right to change the website and the Terms of Use at any time without notice. If you use the website after the amended Terms of Use have been published, you will be deemed to have agreed to the Terms of Use, as amended.


Additional Terms


3. Certain sections or pages on this website may contain separate terms and conditions, which are in addition to these Terms of Use. In the event of a conflict, the additional terms and conditions will govern for those sections or pages.


Issuer of Website


4. The information contained herein is issued by FAM. FAM which is a financial entity regulated by the Monetary Authority of Singapore (“MAS”), which has authorised the funds mentioned herein (except those specifically referred to as funds which have not been authorised by the MAS). However, the MAS takes no responsibility for the information contained herein, the soundness of the authorised unit trusts or mutual funds and does not imply that investment in them is recommended by the MAS.


Authorised Users and Authorised Use


5. Authorised Users

None of the funds mentioned herein have been approved for sale or purchase by any authority outside Singapore. This website is not directed to any person in any jurisdiction where (by reason of that person’s nationality, residence or otherwise) the publication or availability of this website is prohibited. Persons in respect of whom such prohibitions apply must not access this website. It is the responsibility of any persons who access the information contained herein to observe all applicable laws and regulations of their relevant jurisdiction. By proceeding, you are representing and warranting that the applicable laws and regulations of your jurisdiction allow you to access the information.


6. Authorised Use – No solicitations

The information contained in this website does not constitute a distribution, an offer to sell or the solicitation of an offer to buy any securities in any jurisdiction outside Singapore. In particular, the information herein is not for distribution and does not constitute an offer to sell or the solicitation of any offer to buy any securities in the United States of America, Canada, Australia, Hong Kong, Malaysia, Korea and India, to or for the benefit of United States persons (being residents of the United States of America or partnerships or corporations organised under the laws of the United States of America or any state, territory or possession thereof) and persons of any of the aforesaid countries.


7. Authorised Use – No investment recommendations or professional advice

The information contained in this website does not constitute investment advice. An investment in funds mentioned in this website may not be suitable for all investors and if you are unclear about any of the information on this website, please consult your stockbroker, lawyer, accountant, bank manager or other professional adviser.


While certain tools available on the website may provide general investment or financial analyses based upon your personalised input, such results are not to be construed as our providing investment recommendations or advice. Unless otherwise agreed by FAM in writing, you alone are solely responsible for your investment decisions based on your investment objectives and personal and financial situation.


Prohibited Uses, Means of Access and Password Protected Areas


8. Because all servers have limited capacity and are used by many people, you may not use the website in any manner that would damage or overburden any FAM server, or any network connected to any FAM server. You may not use the website in any manner that would interfere with any other party’s use of the website.


9. This site is optimised for viewing with Microsoft Internet Explorer (version 6.0 SP1 or above) or Netscape Navigator (version 4.76 or above). Recommended screen resolution is 1024 x 768. Although you may use other means to access the website, be aware that the website may not appear accurately through other access methods, and you use them only at your own risk. You are responsible for setting the cache settings on your browsers to ensure that you are receiving the most recent data.


Password Protected Areas


10. Access to and use of password-protected and/or secure areas of the website are restricted to authorised users only. You may not obtain or attempt to obtain unauthorised access to such parts of our website, or to any other protected materials or information, through any means not intentionally made available by us for your specific use. Unauthorised individuals attempting to access, or accessing, these areas may be subject to criminal and/or civil prosecution.


Content and Downloading Disclaimers


11. FAM believes that the information contained on the website is accurate as at the date of publication, however no warranty is made as to the accuracy, suitability, usefulness, reliability or completeness of any such information and no liability in respect of any errors or omissions (including any third-party liability) is accepted by FAM or its affiliates or any director or employee of FAM or its affiliates. The use of this website and the delivery (“Delivery”) of information or documents by FAM or its agents through this website or via electronic mail or other modes of delivery, is at your own risk. No warranty is given that the content of this website and the Delivery (including any such information) will be error free or that this website or any servers that operate it or the Delivery are free of computer viruses or other harmful components.


Reasonable precautions have been taken to ensure that website content, including account information and pricing data, are complete and accurate. However, due to the nature of information delivery technology and the necessity of using multiple data sources, including third party content, FAM is unable to assure the accuracy of the data you access through or download from this website. Website content (including any documents available from the website) is presented only as of the date published or indicated and may be superseded by subsequent market events or other reasons. FAM has no duty to update this website or any website content. FAM shall not be liable to you or any third party for any damages arising from any actions or investment decisions taken by you based on the accuracy (or otherwise) of the data presented through or downloaded from this website. FAM or its affiliates and their directors and employees may or may not have a position in or with respect to the securities mentioned herein.


FAM does not warrant that any downloads from this website will meet your needs or expectations, or be uninterrupted, secure or error free or that any files available for downloading through this website are free of computer viruses or other harmful components. You alone are responsible for ensuring adequate protection and backup of data, software, computer and other equipment is made and appropriate safeguard is in place to detect, prevent and eliminate computer viruses and other harmful effects. FAM or its affiliates will not be responsible for any costs or expenses which may be incurred if your use of this website or the Delivery or downloads results in any servicing or replacement of property, material, equipment or data.


Third Party Content Providers, Sites, Referrals, Hyperlink Policy, and Disclaimers


12. For informational or educational purposes, or as a service and convenience to you, this website may provide referral information, third party content or live links to a regulatory agency, non-profit organisation, or other unaffiliated third party and their websites, including companies that have a relationship with FAM.


Our decision to provide referral information to a third party or to pass on an offer made by a third-party vendor or to provide a link from our website to a third-party website is not an endorsement of the third party, their products or services, or their website accessed through any such links. We are not responsible for the opinions, ideas, products, information, or services offered at such sites. While we would generally only provide such information from, or links to, sources considered reliable, we do not conduct independent investigations and accordingly we make no representations or warranties, express or implied, as to third party products, services, content, tools, information and website, and do not guarantee their accuracy, timeliness, completeness, reliability, suitability or usefulness for any particular purpose as we have no control over the content on such non FAM websites. We advise and encourage you to do your own research and make your own assessment.


Although third party content may be displayed, framed-in or provided in a pop-up box on the website, or available through a live link from our website to a third-party website, FAM does not prepare, edit, guarantee or endorse, approve, recommend or introduce any third-party content. By clicking on a link from our website to any third-party website, you will leave this website (even if, for your convenience, a second browser window is opened). When viewing third party content through such a link, keep in mind that the third party’s website terms and conditions, privacy and security policies, or other legal information may be different from those of FAM website. We are not liable for any direct or indirect technical or system issues, consequences, or damages arising from your use of any third-party website or information provided by third party. We do not warrant that such site or content is free from any claims of copyright, trademark, or other infringement of the rights of third parties or that such site or content is devoid of viruses or other contamination. Your access, use and reliance upon such content, products or services is at your own risk.


Limitation of Liability on System and Transmission over the Internet


13. FAM or its affiliates, or any of their respective directors, officers, employees or agents shall not liable for any event of Force Majeure, any virus or other harmful component affecting the website or any server that operates it, any interception of data or communications in connection with the public nature of the internet, any problems or technical malfunction of any telephone network or lines, computer online systems, servers or providers, computer equipment, software failure of any email or entry to be received on account of technical problems or traffic congestion on the Internet, telephone lines or at any website, or any combination thereof, including any loss of opportunities or profit arising from any time delay, system disruption or interruption, transmission blackout, delayed transmission or any incorrect data transmission, or any injury or damage to the computer or other electronic devices or property of any person accessing their website or any other person related to or resulting from accessing the websites or downloading any materials from the website of FAM or any third party.


FAM or its affiliates, or any of their respective directors, officers, employees or agents shall not be liable for any and all losses, injury (including special, indirect and consequential losses), damages, rights, claims and actions of any kind resulting from accessing or downloading any materials from the website of FAM or any third party, including without limitation, personal injuries, death and property damage.




Offering Documents and Investment Risks


14. Units or shares in funds mentioned on this website may only be bought and sold on the terms set out in the relevant explanatory memorandum or Singapore offering documents, as applicable. Investments in emerging markets and smaller companies may involve a higher degree of risk and are usually more sensitive to price movements. Past performance is not a guide to future returns and investors should be aware that the value of units or shares and the income from them may fall as well as rise and they may not get back the full amount invested. Exchange rates may also cause the value of the underlying overseas investments to go up or down. Prospective investors should consult their own professional advisers on the legal and tax implications of making an investment in, holding, or disposing of any securities mentioned herein and the receipt of distributions with respect to such a fund.


Copyright, Trademark, Logo, Patent, Intellectual and Other Property Rights


15. All copyright, trademark, logo, patent, intellectual and other property rights in the information contained herein is owned by FAM or its affiliates. No rights of any kind are licensed or assigned or shall otherwise pass to persons accessing such information. Under no circumstances should information contained herein or any part of it be copied, reproduced, or redistributed without FAM ‘s express written consent.


You acknowledge that content on the Site or otherwise available from FAM through any other Dealing Facility (“Content”) is subject to copyright and possibly other intellectual property rights (“IPRs”). Unless expressly permitted by law, the applicant shall not, and shall not permit any other person to, sell, modify, copy, reproduce, distribute, display, or publish any Content which the applicant does not own or hold under licence or otherwise infringe the IPRs of any person in using the Site or any other Dealing Facility or any Content.


16. The website may contain Content posted, emailed, or otherwise submitted by you and/or, in the case of the website, by other users of the website (“User Content”). FAM has the right to access and examine any User Content and may in its absolute discretion move, remove, or disable access to User Content or cause the same to be done. You grant FAM a perpetual, irrevocable, royalty free licence to use, reproduce, modify, adapt, publish, translate, incorporate in other works, distribute, and display any information posted, emailed or otherwise submitted by you, in whole or in part.


Computer Equipment, Browser Access, and Internet Services


17. You are responsible for obtaining, installing, maintaining, and operating all software, hardware, or other equipment (collectively, “System”) necessary for you to access and use and access this website. This responsibility includes, without limitation, your utilising up to date web-browsers and the best commercially available encryption, antivirus, anti-spyware, and internet security software. You are additionally responsible for obtaining Internet services via the Internet service provider of your choice, for any and all fees imposed by such Internet service provider and any associated communications service provider charges. You acknowledge that there is certain security, corruption, transmission error, and access availability risks associated with using open networks such as the Internet and you hereby expressly assume such risks, including, but not limited to those we may disclose in our materials. You acknowledge that you are responsible for the data security of the Systems used to access this website, and for the transmission and receipt of information using such Systems. You acknowledge that you have requested access to the website for your convenience, have made your own independent assessment of the adequacy of the Internet and Systems and that you are satisfied with that assessment. FAM is not responsible for any errors or problems that arise from the malfunction or failure of the Internet, or your Systems nor are we responsible for notifying you of any upgrades, fixes, or enhancements to, or for providing technical or other support for your Systems. Although we may provide a link to a third- party site where you may download software, we make no endorsement of any specific software, hardware or Internet Service Provider and your use of any such software, hardware or service may also be subject to the license or other agreements of that provider, in addition to these Terms of Use.




18. You hereby agree to fully indemnify, defend and hold harmless FAM and its third party providers from and against any and all damages, losses, liabilities, costs and expenses (including but not limited to legal fees and disbursements) arising from or in connection with: (i) your access to or use of this website and/or online facilities; (ii) your breach of any of these Terms of Use.




19. If any provision of these terms and conditions is held to be invalid, unenforceable,or illegal for any reason, such provision shall be deemed severed from the remaining provisions which will nevertheless continue in full force and effect.


 20. In case of discrepancies between the English and other language versions of these Terms of Use and content of this website, the English version shall prevail.


Governing Law

21. These Terms of Use shall be governed in all respects by the laws of Singapore.


You shall comply with all laws, rules and regulations by any governmental authority or agency which govern or apply to the operation and use of this website. These Terms of Use inures to the benefit of FAM, its successors and assigns. You may not assign these Terms of Use. No waiver to these Terms of Use shall be effective unless agreed in writing by FAM. All rights not expressly granted herein are reserved by FAM.





1. Policy


1.1 This is the privacy policy of Finexis Asset Management Pte. Ltd. (“FAM”) a company incorporated in Singapore. The terms “we”, and “our” in this Policy refer to FAM


1.2 FINEXIS ASSET MANAGEMENT PTE. LTD. (“FAM”) is fully committed to protecting the privacy interests of individuals who provide us with information about themselves. In doing so, we instruct our staff to comply with strict internal standards of security and confidentiality.


1.3 This Policy applies to all personal data you provide to us, or that we may collect about you. Please do not provide any personal data to us if you do not accept this Policy.


We may also require you to accept this Policy when you contact, interact, transact, or deal with us, or when you access and use our websites, applications, or services. If you notify us that you do not accept this Policy, we may not be able to establish a relationship with you or be able to service your requests.


If you have any feedback in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact our Data Protection Officer whose contact details are set out below


Justin Tan, Data Protection Officer

Email address: justin.tan@finexisam.com


We may amend this Policy from time to time without notice to you, to comply with applicable laws or as we update our data usage and handling processes. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously


2. Personal Data


2.1 What personal data we collect

The personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. This may include your name, address, contact information (e.g. telephone number and email address), identification number, photograph, video image and any other information that may identify you or is personal to you.


2.2 How we collect personal data

We collect personal data relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, including when:

  • you use our services or enter into transactions with us (or express interest in doing so);
  • you respond to our promotions, or subscribe to our mailing lists;
  • you visit our websites, download or use our mobile applications;
  • you register an account with us through our websites or applications;
  • you contact us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;
  • your images are captured via photographs or videos taken by us or our representatives when you are within our premises or attend events organised by us;
  • you participate in events and programs, competitions, contests or games organised by us;
  • we seek information about you and receive your personal data in connection with your relationship with us, for example, if you are a jobseeker, investor or shareholder; or
  • you submit your personal data to us for any other reason.


Depending on your relationship with us, we may also collect your personal data from third parties, including:

  • from your family members or friends who provide your personal data to us on your behalf; and
  • from public agencies or other public sources.


Our website and applications may also contain or involve certain technologies that automate the collection of data (including personal data). These technologies include cookies, web beacons and web analytics. If you do not wish to have your data collected through such technologies you may disable the operation of these technologies on your devices (where possible), or you may refrain from using our websites and applications.


2.3 Voluntary provision of personal data

. Your provision of personal data to us is voluntary and you have the right to withdraw your consent for us to use your personal data at any time by contacting and submitting a request to us. Your withdrawal will take effect after your request is processed. However, if you choose not to provide us with the personal data we require, it may not be possible for us to fulfil the purposes for which we require the personal data, including providing products and services which you need from us.


2.4 Providing personal data belonging to others

. In certain circumstances, you may also provide the personal data of persons other than yourself (including your family members). If you do so, you are responsible for informing him / her of the purposes for which we require his/her personal data and warrant that you are validly acting on behalf of him / her to consent to our collection, use and disclosure of his / her personal data.


2.5 Accuracy and Completeness of personal data

. You must ensure that all personal data that you provide is true, accurate and complete and promptly inform us of any changes to the personal data.


2.6 Minor

. If you are a child, minor or not of legal age, please inform and seek the consent of your parent or guardian, before you provide your personal data to us. If you

are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us to request for erasure of their personal data.


3 Purposes


3.1 We collect, use and disclose your personal data where:

  • you have given us consent;
  • necessary to comply with our legal or regulatory obligations, e.g. anti-money laundering and “know your customer” checks;
  • necessary for our legitimate business interests, provided that this does not override your interests or rights; and/or
  • necessary to perform a contract or transaction you have entered into with  us or provide a service that you have requested or require from us.


3.2 General purposes. Generally, we collect, use and disclose your personal data for purposes connected or relevant to our business, including:

  • processing your transactions with us, or to provide products and services to you;
  • managing your relationship with us;
  • facilitating your use of our platforms and services;
  • assisting you with your requests, enquiries and feedback;
  • administrative purposes,  e.g. accounting, risk management and record keeping, business research, data, planning and statistical analysis, and staff training;
  • security and safety purposes, e.g. protecting our platforms from
  • unauthorised access or usage and to monitor for security threats, and capturing of your image on security cameras;
  • carrying out research, data and statistical analysis;
  • compliance with laws and regulations, internal policies and procedures, e.g. audit, accounting, risk management and record keeping;
  • enforcing legal obligations owed to us, or responding to complaints, litigation or investigations concerning us;
  • managing and engaging third parties or data processors that provide services to us, e.g. IT services, data analytics, marketing, and other professional services;
  • such purposes that may be informed to you when your personal data is collected;
  • carrying out our legitimate business interests (listed below); and/or
  • any other reasonable purposes related to the aforesaid


3.3 Marketing purposes. If you have provided us with your consent, your personal data may be used for the purposes of marketing our products, events, and services and those of our strategic partners and business associates (e.g. insurance companies, banks and financial institutions). For us to market products, events and services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us, or data collected from your interactions with us.


If you would like to withdraw your consent given to us, please email the Data Protection Officer at the email address set out in paragraph 1.3, and we will process your request accordingly.


3.4 Legitimate business interests.


Our legitimate business interests include:

  • managing our business and relationship with you, and providing services to our users and customers;
  • protecting our rights and interests and those of our users and customers;
  • preventing and investigating possible misuse of our websites, applications and services;
  • understanding and responding to inquiries and feedback;
  • understanding how our users use our websites, applications and services; identifying what our users want and improving our websites, applications, services and offerings;
  • enforcing obligations owed to us, or protecting ourselves from legal liability; and
  • sharing data in connection with acquisitions and transfers of our business.


3.5 Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law.


3.6 Contacting you. When using your personal data to contact you for the above purposes, we may contact you via email, e-mail, SMS, telephone, pop-up notifications (when you are using our applications), or any other means.


We will not contact you for marketing purposes unless with your consent, or we are exempted by applicable law from having to obtain consent. When contacting you for marketing purposes, we will not contact you through your telephone number, unless you have specifically consented to such a mode of communication. If you do not wish to receive any communication or information from us or wish to restrict the manner by which we may contact or send you information, you may contact us to do so.

3.7 Please note that should you not consent to provide us with the relevant personal data to fulfil the purposes of collection, use and disclosure of your personal information, it may hinder our ability to continue to service or interact with you.


3.8 Where consent is not obtained, we may collect, use, and disclose your Personal Data pursuant to an exception under the PDPA or other written law when the use is necessary.


4. Disclosure of Personal Data

We may also disclose or share your personal data in connection with the purposes described in paragraphs 2, 3.3 and 3.4 above, including to the following parties:

  • third parties who are appointed to provide services to us, e.g., IT vendors, marketing companies and event organisers;
  • third parties that we conduct joint marketing and cross promotions with; and/or
  • regulatory authorities and public agencies.


When disclosing personal data to third parties, we will (where appropriate and required by applicable law) enter into contracts with these third parties to protect your personal data in a manner that is consistent with applicable laws and/or ensure that they only process your personal data in accordance with our instructions.


5. Cross Jurisdiction Transfers of Personal Data

Safeguards. We may transfer your personal data out of Singapore for the purposes set out in paragraph 3 When transferring personal data outside Singapore, we will require recipients of the personal data to protect personal data at a standard comparable to that under the laws of Singapore. For example, we may enter into legally enforceable agreements with the recipients to ensure that they protect your personal data. You may obtain details of these safeguards by contacting us.


6. Protection of Personal Data


6.1 Period of retention. We keep your personal data only for so long as we need the data to fulfil the purposes we collected it for, and to satisfy our business and legal purposes, including audit, accounting or reporting requirements.

How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Certain information may also be retained for longer, e.g. where we are required to do so by law. Typically, our data retention period is from 6 years upwards, depending on the limitation period. In the absence of a need to retain personal data, we will either delete or aggregate it or, if this is not possible then we will securely store your personal data and isolate it from any further processing until deletion is possible.


6.2 Anonymised data. In some circumstances we may anonymise your personal data so that it no longer identifies you, in which case we are entitled to retain and use such anonymised data without restriction, including for data analytics.


6.3 Unauthorised access and vulnerabilities. While we take reasonable precautions to safeguard your personal data in our possession or under our control, we cannot be held responsible for unauthorised or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.


7. Your Rights


7.1 You enjoy certain rights at law in relation to your personal data that we hold or control. These rights include:


  • Withdrawal of consent: you may withdraw consent for our use of your personal data.
  • Correction. you may request that any incomplete or inaccurate data that we hold, or control be corrected
  • Access. you may ask if we hold or control your personal data and if we are, you can request access or a copy of such data. You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

Requests for withdrawal of consent, correction and access to your personal data are to be forwarded to the Data Protection Officer (DPO) at justin.tan@finexisam.com. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. We will seek to complete your request within 30 calendar days once we have sufficient information from you to deal with the request.


7.2 Other rights.  Depending on the laws applicable to you, you may also enjoy additional rights. For example, if you are resident in the European Union, you may also enjoy certain additional rights, including:


  • Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.
  • Restriction: you may withdraw consent for our use of your personal data or ask us to suspend the processing of certain of your personal data about you, for example if you want us to establish its accuracy.
  • Portability: you may request the transfer of certain of your personal data to another party under certain conditions.
  • Objection: where we are processing your personal data based on a legitimate interest (or those of a third party) you may object to processing on this ground.


7.3 Exercising your rights. If you wish to exercise your rights, you may contact us to do so (see paragraph 3 above for contact details). We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may charge you a fee to process your request.

We may also be permitted under applicable laws to refuse a request.


7.4 Limitations. We may be permitted under applicable laws to refuse your request to exercise your rights, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.