Privacy & Cookies Policy

PARAGON CAPITAL MANAGEMENT SINGAPORE PTE. LTD. a company registered in Singapore, bearing UEN number 201726091H, and having its registered address at 1 Wallich Street #25-03 | Guoco Tower | Singapore 078881, Singapore (the “Company“, “we“, “us” and “our“) is committed to visitors and registered users’ (“You” or “Your“) personal information. This privacy notice discloses the privacy practices (“Privacy Policy“) of and applies solely to the information collected on the Company’s website and the various forms, means and / or methods set out under the section headed “Collection of Personal Data” below (collectively referred to as the “Site“). The Privacy Policy describes how the Company uses and protects the information that You give while using the Site and intends to provide You of the Company’s Site with clear and complete information about the data and information that collected and the way that data and information is stored and used. The Company values the privacy of its users. Your privacy is important to us. We may need to make revision to our Privacy Policy (see the section headed Changes to this Privacy Policy below); so please check the Site for updates from time to time. If there are important changes to how we handle Your personal information, we may contact You to let You know. Please also note that we use cookies (“Cookies“) to store information about how You use the Site and see the section headed “Cookies” below for further clarification. Before using the Site, we advise You to read this Privacy Policy and contact us at the e-mail address at if You have any questions or concerns. By interacting with us and by submitting information to us, or signing up for any services offered by us, You agree and consent to the Company, its related corporations as well as the Company’s representatives collecting, using, disclosing and sharing amongst themselves Your data in strict accordance with the terms of this Privacy Policy. For avoidance of doubt, this Privacy Policy forms a part of the Company’s Site Terms of Use. In the event of any conflict between this Privacy Policy and the Terms of Use, the Privacy Policy will prevail in relation to the usage of Your Personal Data, as defined below. All defined terms in the Terms and Conditions shall apply to this Privacy Policy unless specifically stated.

I. Information Collected:

The Company only collects information wherever it is essential and only where it is relevant to our operations so as to be able to provide You with the best experience and service. The Company shall not collect, use or disclose Your personal information unless You give consent to us for the collection, use or disclosure of Your personal information. The Company promises to only collect and use personal information as mentioned below:

  1. Your personal information which identifies You, including Your name, birth date, IP address, login information, browser details and settings and details regarding Your operating system;
  2. contact information such as e-mail addresses and telephone numbers;
  3. information on how You subscribe tothe Company’s financial products and services;
  4. information if You visit our office e.g. visual images collected via closed circuit television (CCTV);
  5. information classified as “sensitive” personal information e.g. relating to Your health;
  6. Your Payment related information including Your bank account number and Your credit or debit card details; and
  7. Children are not able to buy products and services from the Company. However, on instruction from a parent or guardian, a child can also be named as a beneficiary on some funds and trusts. In these cases, we collect limited personal information to identify the child (such as his / her name, age, gender).

The items so collected shall constitute “Personal Data“, which is defined under the Personal Data Protection Act of Singapore (the “PDPA“) to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. Personal Data collected by the Company shall be subject to complete protection by the Company in accordance with applicable law.

II. Collection of Personal Data

Generally, the Company will collect Personal Data when You:

  1. register on the Site;
  2. submit Personal Data to us voluntarily;
  3. make payments to us, through our Site or otherwise;
  4. use the Company’s services orsubscribe to the Company’s products;
  5. establish contact with us through the Site, by telephone, post, e-mail or through any other means;
  6. an application form for a product or service;
  7. meet with one of our business development or relationship personnel;
  8. register for one of our events;
  9. participate in competitions e.g. to win tickets to a sporting event which we sponsor;
  10. use one of our online services such as the Site (which includes the Company’s website, social media and mobile device applications);
  11. provide information in the business directories and other commercially or publicly available sources;
  12. if you have a financial adviser, the information we collect and use will most likely have been provided by them on your behalf; or
  13. participate in research surveys to help us understand You better and improve our products and services.

When You browse our Site, You generally do so anonymously. You will not be required to provide any personal details while browsing the Site.

The Company collects Personal Data in two ways. The first is when You provide us with information while using the Site, including filling out forms or contacting the Company using the given contact details. The second is when You browse the Site, where technical non-identifiable data is collected. You should ensure that all Personal Data that You submit to us is complete, accurate, true and correct. Failure on Your part to submit this information accurately may result in our inability to provide You with the best possible experience while using our Site and any of our products.

III. Information Protection

Browsing the Site will not require You to provide any personal details, so no sensitive Personal Data is automatically collected. You will remain anonymous and You will remain unidentified until You choose to register an account or make an enquiry by leaving Your details on the Site. The Company will protect Your Personal Data in strict accordance with applicable laws, including in accordance with the provisions of the PDPA. Nevertheless, You acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to the Company is done so at Your own risk. The Company does not warrant or guarantee that the information You provide will not be accessed, copied, used, or disposed of in breach of its security measures, and You agree not to hold us liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, the Company will, as far as reasonably possible, promptly notify all affected persons, including You. Unless required by law or a Court order or direction, or unless as relevant for the purpose stated:

  1. The Company will not sell, share or trade Your Personal Data collected online with third parties, except unless strictly necessary to complete a payment or under a direction by a court of law or judicial authority; and
  2. Personal Data collected online will be for internal Company use only, and will be viewed by Company employees on a strict need to know basis only.

By accepting these conditions, and by continuing to use the Site, You agree and accept that all information provided by You will be true and will be kept up to date during Your continuing use of the Site.

IV. Your / User Undertaking

You agree to provide up to date, accurate and correct personal information details, as requested by the Company. You agree that the Company shall not be liable for the misuse of any such details unless the misuse is as a result of the Company’s actions or proven gross negligence.

V. Age of Consent

By using the Site, You represent that You are at least the age of 18 years old, or You have given us Your consent to allow any of Your minor dependents to use the Site as the case may be. The Company strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Site are not intended for use by minors, the Company respects the privacy of minors who may inadvertently use the internet or the mobile application.

VI. Company Undertaking

The Company will endeavour to ensure that the Personal Data collected is safely stored. The Company will protect all information by:

  1. Implementing and maintaining security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of Your information;
  2. Restricting third party access to Your Personal Data unless absolutely necessary; and
  3. Not retaining Your Personal Data for any time period longer than required to fulfil the purpose(s) listed below.

VII. Collection and Use of Data:

The Company may use Your Personal Data for the purposes below if we deem it necessary to do so for its legitimate interests. If You are not satisfied by this, You have the right to object in certain circumstances (see the section headed “Data Protection Rights” below).

A. Purposes for Collecting Personal Information

Generally, the Company may use Your information for:

  1. Responding to queries and questions;
  2. Verifying Your identity;
  3. Providing You with: our onlineportal, login authentication, age verification, remembering Your settings, processing payments and hosting back end infrastructure;
  4. Managingthe infrastructure and the business operations of the Company;
  5. Protecting and enforcing the Company’s legal rights and obligations;
  6. Compliance with applicable rules, laws and regulations, codes of practice or guidelines;
  7. To maintain Your account with us;
  8. To verify Your particulars and payments in relation to the services we provide to You;
  9. To provide You with the services You have signed up for and for improving and developing the Company’s products, services and Site;
  10. Traffic optimization, data analytics and research, including profiling and the use of services such as Google Analytics, managing landing pages and heat mapping our Site;
  11. Sending You communications about our services, products and features that You have agreed to receive;
  12. Communicating with You, if required, to inform You of any new services or developments relating to the Company or the services we provide; or
  13. Any purpose relating to the above.

B. Additional Purposes:

In addition, where permitted by applicable law, the Company may also collect and use data collected from You for:

  1. Providing services, products and benefits to You;
  2. Sending You details of additional products, services that may be of use to You and that may enhance the quality of the product that the Company delivers to You; and
  3. In relation to particular products and services or in Your interactions with the Company, we may also specifically notify You of other purposes for which we collect, use and disclose Your Personal Data for these Additional Purposes as well.

VIII. Exceptions:

The Company is committed in its endeavour to comply with applicable law governing the protection of Personal Data. However, in exceptional circumstances, if the Company is required by law or by a court order or direction to disclose personal information, we will do so.

IX. Disclosure of Personal Data:

The Company will take reasonable steps to protect Your Personal Data against unauthorised disclosure. Subject to the provisions of applicable law, the Personal Data will be used only for the purposes stated in the section headed “Collection and Use of Data” above or to the following third parties, wherever located:

  1. Company Affiliates. The Company will share information with its affiliates, who help us to provide and support our services and other business-related functions;
  2. Banks, Agents, Contractors or Service Providers.The Company will share information with its third-party service providers, who help us provide and support our services and other business-related functions (including but not limited to trustees, custodians, fund administrators and transfer agents);
  3. Professional advisors such as lawyers or auditors;
  4. Relevant government regulators, authorities, law enforcement agencies, credit reference agenciesor a court of law. The Company will only disclose Personal Data when we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, (iii) to conduct a credit check and ID verification or (iii) to protect Your vital interest or those of any other person; and
  5. Any other person with Your consent. The Company will only disclose Your Personal Data with Your express consent, to any service provider appointed or nominated by You and with whom we or the service providers have to interact in the course of providing our services and products to or in any of our transactions and dealings with You.

X. Additional Privacy Policy for the Site and Service Users

Persons who have subscribed for our updates on the Site (“Subscribers“) Note:

This section applies to all Subscribers:

As part of the signing-up process that is available to Subscribers on the Site, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.

All the statements in this Privacy Policy apply to all Subscribers, and all Subscribers are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Data or sensitive personal information to the Company, failing which they are required to leave the Site immediately.

If You have inadvertently submitted any such information to the Company prior to reading the privacy statements set out herein, and You do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then You may access, modify and delete such information by using options provided on the Site. In addition, You can, by sending an e-mail to, inquire whether the Company is in possession of Your Personal Data, and You may also require us to delete and destroy all such information.

The Company will communicate with the Subscribers through e-mail. The Subscribers can change their e-mail address by re-subscribing and sending an e-mail to for the deletion of previous e-mail.

All of the Company’s employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.

To the extent necessary to provide Subscribers with our services, the Company may provide their Personal Data to third party contractors who work on behalf of or with us to provide Subscribers with our services, to help us communicate with Subscribers or to maintain the Site. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Site, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these services in accordance with their own privacy policies. In such circumstances, You consent to us disclosing Your personal information to contractors, solely for the intended purposes only.

Subscribers may choose to unsubscribe from marketing communications that they receive from the Company or manage their preferences via the links provided at the end of every such e-mail and/or promotional communication.

If You have voluntarily provided Your Personal Data to us for any of the purposes stated above, You hereby consent to such collection and use of such information by us.

Collection, use and disclosure of information which has been designated as Personal Data under the PDPA requires Your express consent. By affirming Your assent to this Privacy Policy, You provide Your consent to such use, collection and disclosure as required under applicable law. Our services may be unavailable to You in the event such consent through an e-mail is not given.

You are responsible for maintaining the accuracy of the information You submit to us, such as Your contact information provided as part of account registration. If Your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on Your account page or by contacting us at We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If You provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or we have reasonable grounds to suspect that the information provided by You is untrue, inaccurate, out of date or incomplete, we may, at our sole discretion, discontinue the provision of our services to You. There may be circumstances where we will not correct, delete or update Your Personal Data, including (i) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (ii) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

If You wish to cancel Your account or request that we no longer use Your information to provide You services, contact us through We will retain Your information for as long as Your account with the Services is active and as needed to provide You the services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, Your data may be anonymised and aggregated, and then may be held by us as long as necessary for us to provide our services effectively, but our use of the anonymised data will be solely for analytic purposes. Please note that Your withdrawal of consent, or cancellation of account may result in us being unable to provide You with our services or to terminate any existing relationship we may have with You.

If You wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the services, You may do so via Your e-mail and/or account.

XI. Third-Party Sites

This Privacy Policy applies to services that are owned and operated by us. We do not exercise control over the websites displayed as search results or links from within its services. These other websites may place their own cookies or other files on the Your computer, collect data or solicit personal information from You, for which we are not responsible or liable. Accordingly, we do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by us of the website, the website’s provider, or the information on the website. If You decide to visit a third party website linked to our Site, You do this entirely at Your own risk. We encourage the You to read the privacy policies of that third party website.

We do not collect information about the visitors of the Site from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration as an User (the collection, use, storage and disclosure of which each User must agree to in order for us to effectively render the services).

XII. Anti-Spam

We maintain a strict “No-Spam” policy, which means that we do not intend to sell, rent or otherwise give Your e-mail address to a third party without Your consent.

XIII. Data Security

We have implemented the best international market practices and security policies, rules and technical measures to protect the Personal Data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorised access from Your electronic devices through which You avail the services, we shall not be held liable for any loss whatsoever incurred by You. We implement reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of our business. The reasonable security practices and procedures implemented by us include, but not limited to: ensuring that any Personal Data is protected by password. No administrator at the Company will have knowledge of your password. You accept that you are responsible for keeping confidential Your username and password to your account with the Company. Be sure to log off from the log-in Site when finished. The Company does not undertake any liability for any unauthorised use of your account and password. If You suspect any unauthorised use of Your account, You must immediately notify the Company by sending an email to You shall be liable to indemnify the Company due to any loss suffered by it due to such unauthorised use of your account and password. We take Your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose Your Personal Data in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when we, in our sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the terms under this Privacy Policy. We take all reasonable steps to ensure that all unsolicited information is destroyed immediately. Casual Visitors Note: No sensitive personal data or information is automatically collected by us from any Visitors of the Site, who are merely perusing the Site. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such visitors are also required to read and understand the privacy statements set out herein, failing which they are required to exit the Site immediately. If You, as a Visitor, have inadvertently browsed any other page of this Site prior to reading the privacy statements set out herein, and You do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by us. All Visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as we cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Site. You are not a Visitor if You have willingly submitted any Personal Data or personal information to us through any means, including e-mail or through the registration process on the Site. All such visitors will be deemed to be, and will be treated as, Members for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.

XIV. Transfer & Storage of Personal Data

Personal Data collected in accordance with this Privacy Policy may be transferred, stored, or processed outside of Singapore. We will comply with our obligations under the PDPA and Personal Data Protection Regulations 2014 in relation to Personal Data transferred, stored, or processed outside Singapore for as long as the data remains in our possession or control during the transfer. We will take appropriate steps to ensure that, the recipient of the Personal Data who is located outside Singapore is legally obliged to provide to the Personal Data a comparable a standard of protection. However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore, in order to provide You with the services You request, You are deemed to consent to such transfer, storage, or processing in providing Your Personal Data to us during Your use of the Site. You may at any time inform us that You wish to withdraw Your consent to such transfer, storage, or processing of Your Personal Data. There are appropriate safeguards applied by the Company on the Personal Data collected, recorded and used in any mode, whether on paper, online or any other media are in line with our data protection obligations. The Personal Data is protected by controls designed to minimise loss or damage through accident, negligence or deliberate actions. The Company’s employees also protect sensitive and personal information when storing or transferring information electronically and undertake annual training on this. Our security controls are aligned to industry standards and good practice; providing a control environment that effectively manages risks to the confidentiality, integrity and availability of Personal Data. Note to residents of the European Union (EU) Whenever the Company needs to transfer Your Personal Data out of the EU, we will require Your explicit consent. Please contact the Company if You want further information on the specific mechanism used by us when transferring Your Personal Data out of the EU.

XV. Data Protection Rights

You have the following data protection rights:

  1. Right to Access. The right to request (i) copies of the Personal Data the Company holds about You at any time, or (ii) that the Company modify, update or delete such information. If the Company provides You with access to the Personal Data the Company holds about You, the Company will not charge for this, unless Your request is ‘manifestly unfounded or excessive.’ In situations where the Company is legally permitted to do so, we may refuse Your request. If the Company refuses Your request, we will tell You the reasons why;
  2. Right to Correct. The right to have Your Personal Data rectified if it is inaccurate or incomplete;
  3. Right to Erasure. The right to request that the Company delete or remove Your Personal Data from its systems;
  4. Right to Restrict. The right to request that the Company restrict the processing of Your Personal Data;
  5. Right to Data Portability. The right to request that the Company move, copy or transfer Your Personal Data;
  6. Right to Object. The right to object to the Company’s use of Your Personal Data, including where we use it for its legitimate interests;
  7. Withdrawal of Consent. Similarly, if Personal Data is collected or processed on the basis of consent, You can withdraw Your consent at any time. Withdrawing Your consent will not affect the lawfulness of any processing the Company conducted prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on lawful processing grounds other than consent;
  8. Right to be protected from automated decision making (including profiling). The right not to be subjected to automated decision making (including profiling) which significantly or legally affects you; and
  9. Right to Complain to a data protection authority. The right to complain to a data protection authority about the collection and use of Personal Data. For Singapore residents, please contact the Personal Data Protection Commission. Contact details for data protection authorities in the EEA are available here. For residents of jurisdictions other than Singapore or the EEA, please contact Yourlocal data protection authority.

Please contact the Company at if You wish to exercise any of Your rights above. Furthermore, if You believe, that Your Personal Data may have been, or may imminently be in danger of being breached, or if You have reason to believe that such data may, for some reason, soon be breached please immediately contact the Company. The Company may need to request specific information from You to help us confirm Your identity and ensure Your Right to Access Your Personal Data (or to exercise any of Your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. The Company will try to respond to all legitimate requests within one (1) month. Occasionally it may take longer than that if the request is particularly complex or You have made a number of requests. In this case, the Company will notify You and keep You updated.

XVI. Cookies:

When You interact with us on our Site, You understand and accept that the Company uses “Cookies“, where a small data file is sent to Your browser to store and track certain anonymous information such as number of users, frequency of use and the number of page views (or page impressions) that occur on the Site (“Aggregate Information“) about You when You use the Site. Your Personal Data is not at risk in any way due to the implementation of the Cookies. You can accept or delete cookies. For security reasons, You may wish to deactivate the storing of cookies or adjust Your browser to inform You before the cookies are stored on Your computer. However, please note that if You do erase or block the cookies, You may not be able to utilise some features on the Site. In such situations, we shall not be held liable for any loss or damage resulting from Your inability to use those features. The Company may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). The Company collects your IP address in order to facilitate its administration and improvement of the Platforms. The information derived from your IP address can help the Company diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Platforms.

We use the following cookies:

  1. Strictly necessary cookies. These are cookies that are required for the operation of the They include, for example, cookies that enable You to log into secure areas of the Site, using our online payment services;
  2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the websites when they are using it. This helps us to improve the way the Sitework, for example, by ensuring that users are able to use custom features;
  3. Functionality cookies. These are used to recognise Youwhen You return to our Site. This enables us to personalise its content for You, greet You by name and remember Your preferences (for example, Your choice of language or region); and
  4. Targeting cookies. These cookies record Yourvisit to the Site, the pages You have visited and the links You have followed. We will use this information to make the Site and the advertisements targeted more relevant to Your We may also share this information with third parties for this purpose.

Our Site may include certain social media features, such as the Facebook, Twitter, LinkedIn buttons and widgets. These features may collect Your IP address, which page You are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the third party website providing such features.

XVII. Changes to this Privacy Policy

The Company may update this Privacy Policy at any time, with or without advance notice. As always, if You object to any of the changes to our terms, and You no longer wish to use the services, You may contact us at Unless stated otherwise, the Company’s current Privacy Policy applies to all information that we have about You and/or Your account. If You use the Site; or access the Site after a notice of changes has been sent to You, or published on the Site, You hereby provide Your consent to the changed terms.

XVIII. Contact Information

Should You have any questions about this Privacy Policy or the Company’s information collection, use and disclosure practices, or if You would like to access, correct, amend or delete any Personal Data the Company may have about You, register a complaint, or simply want more information, please contact the Company at:

We will use reasonable efforts to respond promptly to any requests, questions or concerns, which You may have regarding our use of Your Personal Data.