ASG2 Business Customer Privacy Notice

ASG2 Pte. Ltd. ("ASG2", "we", "our", or "us") is committed to protecting the personal data of individuals associated with our business customers. This Privacy Notice explains how we collect, use, disclose, and protect personal data in the context of providing investment and financial services to business clients.

1. Data Controller

In this notice, "we," "our" or "us" refers to ASG2 Pte. Ltd., a company incorporated in Singapore and licensed by the Monetary Authority of Singapore (MAS) to carry out regulated investment activities. If you are acting on behalf of a business (e.g. a director, shareholder, or authorized representative), we refer to you as a "Representative."

Representatives may authorize other individuals ("Authorised Users") to access or use ASG2 services on behalf of the business.

• If you are a Representative, ASG2 is the data controller.
• If you are an Authorised User, your employer or the business entity is the primary data controller, and ASG2 may act as a joint or independent data controller where required (e.g., for KYC/AML purposes).

2. Personal Data We Collect About You

2.1 Information You Provide

We collect personal data you or your business provides directly to us, including:

• Name, date of birth, nationality, and contact details
• Identification documents (e.g., NRIC, passport, proof of address)
• Employment or professional role (e.g., job title, business affiliation)
• Information about shareholders and directors (including beneficial owners)
• Source of funds or wealth
• Communications with us (emails, calls, messages)

If you provide personal data about someone else, you confirm you have obtained their consent to share this information.

2.2 Information Collected from Your Use of Our Services

• Transaction records and payment instructions
• IP address, device data, browser type, access logs
• Usage analytics (e.g., time spent, page interaction)
• Login behavior or biometrics (e.g., keystroke or mouse movement patterns)

2.3 Information from Third Parties

• Identity verification providers and sanctions screening databases
• Public databases (e.g., ACRA, court filings)
• Other financial institutions or payment platforms

2.4 Social Media and Marketing Platforms

• Profile or contact data from social login (if used)
• Interactions with ASG2 social media pages or ads

3. How We Use Your Personal Data

Legal Bases:

• Contractual necessity – to onboard and service your business
• Legal obligation – to meet regulatory obligations (e.g., AML/CFT)
• Legitimate interests – fraud prevention, service improvement, marketing
• Consent – where required (e.g., for marketing or biometric processing)

Purposes:

• Conduct KYC/AML checks and onboard your business
• Deliver financial or investment services
• Monitor and improve platform functionality and security
• Communicate service updates and marketing (where permitted)
• Fulfill legal, tax, and regulatory reporting duties

4. Sharing Your Personal Data

We may share your data with:

• Regulatory bodies (e.g., MAS, IRAS, law enforcement)
• Banks, brokers, custodians, or payment service providers
• Technology and cloud service providers
• External auditors, legal advisors, and consultants
• Third parties with your consent or when legally required

All third parties are bound by confidentiality and data protection obligations.

5. International Data Transfers

Your personal data may be transferred outside Singapore for storage or processing. We ensure all transfers comply with PDPA requirements and that appropriate safeguards are in place (e.g., contractual clauses).

6. Data Retention

We retain personal data for as long as necessary to:

• Fulfill the purpose it was collected for
• Comply with MAS and other regulatory requirements (typically at least 5 years)
• Resolve disputes and enforce legal rights

7. Your Rights

You may:

• Request access or correction of your data
• Withdraw consent (subject to legal obligations)
• Lodge a complaint with the Personal Data Protection Commission (PDPC)

To exercise these rights, contact our Data Protection Officer at [Insert DPO Email].

8. Security Measures

We implement industry-standard technical and organizational measures to protect your data, including:

• Data encryption and secure servers
• Role-based access control
• Regular audits and staff training

9. Cookies

Our website uses cookies to enhance user experience and analyze traffic. You may disable cookies in your browser settings, but some features may be unavailable as a result. 

10. Updates to This Notice

We may update this Privacy Notice periodically. Material changes will be communicated appropriately, and the most current version will always be available on our website.

11. Contact Us

For questions or concerns about this notice or how we handle your personal data:

Data Protection Officer
ASG2 Pte. Ltd.

158 Cecil Street, #09-01, Singapore 069545
📧 Email: aftsg2.dpo@aspireapp.com