Privacy Policy (Singapore)

This Privacy Notice explains how GAM Investments (Singapore) Pte. Ltd. (“GAM Singapore”, “we”, “us” or “our”) collects, uses, discloses, transfers, and protects personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”), and in a manner consistent with the Monetary Authority of Singapore (“MAS”) Technology Risk Management Guidelines and MAS Guidelines on Outsourcing.

This notice applies to individuals in Singapore who interact with GAM through this website, including current, prospective, and former clients, investors, counterparties, and other business contacts.

1. Organisation responsible for personal data

The organisation responsible for personal data collected through this website and during the normal conduct of business is:

GAM Investments (Singapore) Pte. Ltd.
Level 11, Tower 1, Marina Bay Financial Centre
8 Marina Boulevard
Singapore 018981

GAM Singapore is part of the GAM group of companies headed by GAM Holding AG (“GAM Group”). Where appropriate and lawful, personal data may be shared within the GAM Group, subject to appropriate governance, security, and confidentiality controls consistent with MAS regulatory expectations.

2. Personal data we collect

We may collect personal data including, where relevant:

• Name and business contact information
• Professional and organisational details
• Information provided through enquiries, registrations, or subscriptions
• Website usage and technical information (including IP address and device information)
• Any other personal data voluntarily provided to us

We do not intentionally collect sensitive personal data through this website.

3. Purposes of collection, use, and disclosure

Personal data may be collected, used, and disclosed for purposes that a reasonable person would consider appropriate, including:

• Conducting GAM Singapore’s regulated business activities
• Managing client, investor, and business relationships
• Responding to enquiries and providing requested information
• Providing information on GAM products, services, events, and publications (subject to consent where required)
• Operating, administering, and securing our website and systems
• Monitoring, managing, and mitigating technology, operational, and security risks
• Complying with legal, regulatory, supervisory, and compliance obligations
• Preventing, detecting, and investigating fraud, financial crime, cyber incidents, and other misconduct

These purposes are aligned with MAS expectations on risk management, information security, and operational resilience.

4. Consent and lawful basis

Where required under the PDPA, GAM Singapore will obtain your consent before collecting, using, or disclosing personal data.

You may withdraw consent at any time by contacting us (see section 11). Withdrawal of consent may affect our ability to provide certain products or services.

Consent can be deemed in certain circumstances, such as when you voluntarily provide data for a purpose and it is reasonable for that data to be processed by us or where such processing would be necessary for contractual performance.

Personal data may also be collected and processed without consent where the legitimate interests of our organisation outweigh any adverse effects on you as an individual. Where we place reliance upon legitimate interest, an assessment will be performed.

5. Disclosure to third parties and outsourcing arrangements

Personal data may be disclosed to:

• Other GAM Group entities
• Third party service providers, agents, or professional advisers who support our operations (including IT, data hosting, communications, legal, compliance, and risk management services)
• Regulators or authorities where required by law

Where third parties process personal data on our behalf, GAM Singapore remains accountable for the protection of such data and implements governance, contractual, and oversight measures consistent with MAS Outsourcing Guidelines, including confidentiality, security, audit, and access controls.

6. Cross border transfer of personal data

Personal data may be transferred, stored, or processed outside Singapore, including within the GAM Group or by third party service providers.

Where personal data is transferred outside Singapore, GAM Singapore takes reasonable steps to ensure that the receiving party provides a standard of protection comparable to that required under the PDPA, including through contractual safeguards and risk based assessments consistent with MAS TRM and Outsourcing expectations.

7. Direct marketing and communications

Subject to applicable laws and consent requirements, GAM Singapore may send information about GAM products, services, events, and publications.

You may opt out at any time using the unsubscribe mechanism in communications or by contacting us.

Where applicable, we comply with Singapore’s Do Not Call Registry requirements.

8. Cookies and website monitoring

We use cookies and similar technologies to support website functionality, security monitoring, analytics, and user experience.

Further details are available in our Cookies Notice, published on this website

9. Data security and technology risk management

GAM Singapore implements reasonable technical and organisational measures to protect personal data against unauthorised access, use, disclosure, alteration, loss, or destruction.

These measures are designed in accordance with:

• PDPA security obligations
• MAS Technology Risk Management Guidelines on information security, access controls, monitoring, and incident management

10. Data retention and incident management

Personal data is retained only for as long as necessary to fulfil business, legal, and regulatory purposes.

GAM Singapore maintains processes to identify, assess, and respond to data breaches and security incidents, including escalation and notification where required under the PDPA and applicable MAS supervisory expectations.

11. Your rights under the PDPA

You have the right to:

• Request access to personal data held about you
• Request correction of inaccurate or incomplete data
• Withdraw consent (subject to legal and contractual limitations)
• Be informed about GAM Singapore’s data protection policies and practices

A reasonable fee may be charged for access requests, as permitted by the PDPA.

12. Data Protection Officer

For questions, requests, or concerns relating to personal data:

Data Protection Officer
GAM Investments (Singapore) Pte. Ltd.
Email: dataprotectionofficer@gam.com

Postal address:
FAO: Data Protection Officer
GAM Investment (Singapore) Pte. Ltd.
Level 11, Tower 1, Marina Bay Financial Centre
8 Marina Boulevard
Singapore 018981

13. Updates to this notice

This Privacy Notice may be updated periodically to reflect changes in legal, regulatory, or business requirements.

The latest version will be made available on this website.