Privacy Policy



As required under the Singapore Personal Data Protection Act (“PDPA”) of Singapore, this policy is to inform you how DAVOS Custody manages your Personal Data.



Privacy Policy



Davos Custody Pte. Ltd. (“DAC”) recognises the importance and sensitivity of Personal Data and is fully committed to protecting the privacy interests of individuals who provide confidential information to DAC, as we consider privacy to be a fundamental aspect of our relationship with our clients, service providers and business associates.


By interacting and corresponding with DAC (via electronic means, telephone or face-to-face meetings), accessing and using DAC’s website, submitting information to DAC, or signing up for any products or services offered by DAC, you agree and consent to DAC collecting, using and disclosing and sharing your Personal Data to DAC’s authorised service providers and relevant third parties in the manner contemplated in this Data Protection Policy.


This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to DAC in respect of your Personal Data, and your consents are additional to any rights which DAC may have at law to collect, use and disclose your Personal Data.


DAC may from time to time update this Data Protection Policy to ensure compliance and consistency with any future developments or changes in legal or regulatory requirements. By continuing to engage DAC’s services, to use DAC’s website (davos.sg) or communicate with DAC subsequent to any updates, you agree to be bound by the updates to this Data Protection Policy.



Governing Law



This Data Protection Policy shall be governed by and construed in accordance with the laws of Singapore.



Data Privacy Notice for purposes of European General Data Protection Regulations as applicable to personal data of EU persons



The DAC is responsible for ensuring that it uses your personal data in compliance with data protection law and the DAC takes your data privacy seriously. The purpose of this Privacy Notice is to explain what personal data the DAC collects and how the DAC uses it. For the purposes of data protection law, the DAC is a data controller in respect of your personal data. “Personal data” is any data that can be used to identify you and the DAC has in its possession or under its control. In this Privacy Notice when we refer to “the DAC” or “we”, “our” or “us”, we mean DAVOS Custody Pte Ltd.



1. What personal data do we collect?



The DAC will collect and process personal data about you that we obtain from you or someone acting on your behalf in the context of our business relationship, by filling in forms, by communicating with the DAC, whether face-to-face, by phone, e-mail, or otherwise. Personal data which we collect and process includes:


  • personal details such as your name, address and other contact details (e.g. e-mail address and phone number), date and place of birth, nationality, and documents evidencing the information (including passport or national ID card details), authentication data (e.g. signature), and family details such as the name of your spouse, partner or children;
  • financial information, including information relating to your assets (including fixed assets), the origin of your assets, revenues, earnings, and investments;
  • educational and professional information about you;
  • tax residence and other tax related information and documentation;
  • records of meetings and phone calls/video calls between you and the DAC;
  • identifiers which we assign to you, such as your client number; and
  • when you access our websites, the type of device you use to access the websites, your IP address and your geographic location, the operating system and version, your browser type, the content you view and features you access on our websites, the web pages and the search terms you enter on our websites; and

In some cases, we collect this information from publicly accessible sources (including press, internet, or beneficial ownership and other registers), third party sources, such as referrals from intermediaries (e.g. professional advisors) or financial crime screening services and other The DAC Group entities.


If relevant, we will also collect information about dependants and family members, trust related third parties, such as protectors, advisors, co-trustees, retiring trustees, but also business partners (including other shareholders or beneficial owners). Before providing the DAC with this information, you should provide a copy of this notice to those individuals.



2. On what legal basis and for which purposes do we process personal data?



2.1 Legal basis for processing

Depending on the purpose of the processing activity (see section 2.2), the legal basis of the processing of your personal data will be one of the following:

  • legitimate interest – we may use your personal data for our legitimate interest, without unduly affecting your interests or fundamental rights and freedoms (some examples are given below);
  • performance of a contract – we may need to collect and use your personal data to enter into a contract with you or to perform the services which you request, or for carrying out our obligations and duties under such a contract;
  • compliance with law and regulation – we may use your personal data to meet our legal and regulatory responsibilities;
  • public interest – we may use your personal data for the performance of a task carried out in the public interest; and
  • consent - we may process personal data based on your consent which we obtain from you from time to time (for instance where required by law), or in the case of special categories of personal data.

2.2 Purposes of processing

Your personal data is processed for specific purposes, and the processing is limited to what is necessary in relation to these purposes. Such purposes are:

  • to on-board you as client, this includes the verification of your address and to assess your application for setting up an account with the DAC (as per the General Business Conditions), and to conduct legal and other regulatory compliance checks to comply with anti-money laundering, counter-terrorist financing, anti-tax evasion and prevention of fraud regulations;
  • provide the services set out in the General Business Conditions to you and ensuring the proper fulfilment of our fiduciary and other duties under the trust arrangement and other fiduciary services;
  • to manage the relationship with you and to communicate with you in relation to the trust arrangement and other fiduciary services;
  • to meet our ongoing compliance and regulatory obligations, such as anti-money laundering, counter-terrorist financing, anti-tax evasion and prevention of fraud regulations, automatic exchange of information, including disclosures to financial service/anti-money laundering regulators, tax authorities, and other regulatory and governmental bodies;
  • for the DAC Group’s prudential and operational management (including risk management, audit etc.); and
  • any other purposes which we notify to you from time to time.

2.3. Am I obliged to provide personal data?

In the context of our business relationship, you must provide all personal data that is required for accepting and carrying out trust arrangement and other fiduciary services or that we are legally obliged to collect. Without this personal data, we are not in a position to enter into or continue a trust arrangement and other fiduciary or business relationship with you.



3. To whom are personal data disclosed?



3.1 The DAC

We may share personal data with other the DAC entities which have a role in the provision of services but also for the fulfilment of regulatory and legal obligations.


3.2 The DAC Group

The DAC may disclose personal data to the DAC Group to provide the services or perform its obligations in connection with the provision of the services set out in the General Business Conditions, or for the management and administration of internal policies and procedures within the DAC Group.


3.3 Third parties

The DAC may disclose personal data outside the DAC Group, including as follows:

  • to third parties relevant to the provision of the services set out in the General Business Conditions. This may include for example registered agents, banks, professional advisors, or accountants;
  • to service providers, third party agents or contractors such as IT, communication services, fraud prevention, and others. When we do share personal data with such service providers, we ensure that they meet our data security standards;
  • to the extent required by law, regulation or court order for example if the DAC is under a duty to disclose personal data to public authorities, regulators or governmental bodies in order to comply with any legal or regulatory obligation;
  • in order to establish, exercise or defend the DAC’s legal rights, for example if the DAC needs to obtain external legal advice or provide personal data in connection with judicial proceedings; and
  • to the prospective buyer, for due diligence purposes, if the DAC and/or the DAC Group restructure or sell any of its business or assets.


4. International transfers of personal data



The recipients referred to in section 3 above may be located outside Switzerland, the European Economic Area (“EEA”) or in a country not approved by European Commission. The DAC requires such recipients to comply with appropriate measures designed to protect personal data. This may be achieved by a binding legal agreement based on “model contractual clauses” approved by the European Commission, obliging the recipients to protect the personal data that they receive, or where the recipient is located in the US, it might be a certified member of the EU-US or Swiss-US Privacy Shield scheme, or any other appropriate measure.


You can obtain further details of the specific safeguards applied to the international transfer of your personal data by contacting the DAC in accordance with the “Contacting the DAC” section below.



5. For how long will my data be stored?



How long the DAC will hold personal data will vary. The retention period will be determined by various criteria including:

  • the purpose for which the DAC has collected and is using it – the DAC will need to keep the data for as long as is necessary for that purpose; and
  • compliance with legal, regulatory or internal policy requirements – laws or regulations may set a minimum period for which the DAC has to retain personal data.


6. What rights in relation to personal data do I have?



You have a number of legal rights in relation to the personal data which the DAC holds about you. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which the DAC holds about you;
  • the right to request that the DAC rectify your personal data if it is inaccurate or incomplete;
  • the right to request that the DAC erase your personal data in certain circumstances. Please note that there may be circumstances where you ask the DAC to erase your personal data but the DAC is legally entitled to retain it;
  • the right to object to, and the right to request that the DAC restrict its processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask the DAC to restrict its processing of your personal data but the DAC is legally entitled to continue processing your personal data and/or to refuse your request;
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that the DAC transmit such data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to the DAC;
  • the right to withdraw your consent, although in certain circumstances it may be lawful for the DAC to continue processing your data where the DAC has another legitimate reason (other than consent) for doing so. Please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal; and
  • the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by the DAC.

You can exercise the rights set out above by contacting the DAC using the details set out in the “Contacting the DAC” section below.



7. Contacting the DAC



If you would like further information about the DAC’s processing of your personal data or the exercise of any of the rights referred to above, please address questions, comments and requests to:


Data Protection Officer

DAVOS Custody Pte Ltd

32 Changi North Crescent, #02-01

Singapore, 499643