Privacy Policy

Last Updated: 24th January 2023

1. Overview

  1. 1.1

    We, KNIGHTSBRIDGE INTERMEDIARY PTE. LTD. (“Knightsbridge”, and references herein to “we”, “us” and “our” are to Knightsbridge), are committed to ensuring the safety and security of personal data.

  2. 1.2

    The purpose of this Privacy Policy (“Privacy Policy”) is to inform you as to how we manage, collect, use, and disclose personal data. In Singapore, such activities are subject to the Personal Data Protection Act 2012 of Singapore (the “PDPA”). We conduct our business in compliance with the PDPA and have implemented various measures to ensure that any personal data we collect, use and/or disclose, remains safe and secure.

  3. 1.3

    Subject to paragraph 1.5 below, your continued access and use of our website at (“Site”) and/or the Services shall constitute your agreement to our collection, use and/or disclosure of your Personal Data in accordance with this Privacy Policy, the use of Tracking Technologies and the applicable laws.

  4. 1.4

    If you are a Minor, your parent or legal guardian’s consent shall be required to consent to our collection, use and/or disclosure of your Personal Data.

2. Personal Data

In this Privacy Policy, “Personal Data” refers to 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 we have or are likely to have access, including data in our records as may be updated from time to time.

3. Collection of Personal Data, Cookies and Log Data

  1. 3.1

    The Personal Data that we may collect may include an individual’s name, email address, phone number, date of birth, residential address, personal identification number, information from the individual’s device or and any other Personal Data necessary for us to provide our services, including access and use of the Platform and/or Services.

  2. 3.2

    Typically, we will collect Personal Data from customers that has created an account and is a registered user of our Services (“Users”), business contacts, business partners, companies that we may invest in or any other third parties that we work with or from publicly available sources.

  3. 3.3

    Tracking Technologies. Unique identifiers such as cookies (which are small text files stored locally on your computer that help store user preferences and may be HTML files, Flash files, or other technology), web beacons, or clear gifs (which are small pieces of code placed on websites used to collect advertising metrics, such as counting page views, promotion views, or advertising responses, tags and scripts or similar technologies (collectively referred to as “Tracking Technologies”) are used by us and our marketing, analytics, or other service providers to understand Site usage, help customize our content, offerings or advertisements on the Site, personalize your experience on the Site (e.g., to recognize you by name when you return to the Site, save your password in password-protected areas, or save your online settings), analyze trends, allow users to move between associated websites without logging into each site, and other purposes related to our management and administration of the Site. In many Internet browsers, you can choose to delete, disable, turn off, or reject most Tracking Technologies through the “Internet Options” sub-option of the “Tools” menu option of your browser or otherwise as directed by your browser’s support feature. Additional information on deleting, disabling, rejecting, or turning off Tracking Technologies may be available through your browser’s support feature. Please consult the “Help” section of your browser for more information. Please know that certain areas and features of our Site can only be accessed in conjunction with cookies or similar devices, and you should be aware that disabling cookies or similar devices might prevent you from accessing some of our content.

  4. 3.4

    Log Files. Log data collected on web servers supplies us with aggregate information about the number of visits to different pages on our Site. We use such aggregate information to improve access to our content based on our visitors’ browsers and operating system types to make our content available to as many users as possible. We do not link the “log data” collected to Personal Data submitted by users when participating in our activities. This Privacy Policy covers the use of cookies by KNIGHTSBRIDGE and does not cover the use of cookies by any advertisers. Some of our third-party providers (e.g., third-party advertisers) may use cookies on our site. We have no access to or control over these cookies.

4. Use of Personal Data

  1. 4.1

    We may use and/or disclose Personal Data for:

    (a)   to operate the Site and provide the Services;

    (b)   to respond to your requests and inquiries;

    (c)   to contact you and to communicate with you about your use of the Services and your User account;

    (d)   to notify you about important changes to our Services, such as updates or revisions to this Privacy Policy or our
            Standard Terms, security announcements, or other similar messages;

    (e)   to review Site usage and operations and to improve the content and functionality of the Site and our Services; 

    (f)    to provide you with information and materials about our products and services; 

    (g)   to address problems with the Services;

    (h)   to protect the security or integrity of our Services, our Users and our business, or

    (i)    to conduct Know Your Customer due diligence checks;

    (j)    legal, regulatory and other compliance requirements (including providing assistance to law enforcement, judicial,
            regulatory or other government agencies and statutory bodies); 

    (k)   for marketing and advertising, and in this regard, to send you by various modes of communication marketing and
           promotional information and materials relating to products and/or services (including, without limitation, products
           and/or services of third parties) that we may be marketing or promoting, whether such products or services exist now
           or are created in the future;

    (l)    handling any reports or complaints received by us against a User; 

    (m)  other work and business related requirements; and

    (n)   any other purposes which we notify you of at the time of obtaining your consent,

    (collectively, the “Purposes” and each, a “Purpose”).

  2. 4.2

    We will not use Personal Data for purposes which we are not permitted to or required under the applicable personal data protection law and regulations.

  3. 4.3

    Notwithstanding the above, we may collect, use and/or disclose any Personal Data without your consent provided that such collection, use and/or disclosure is in accordance with any applicable laws, including but not limited to the PDPA.

5. Disclosure of Personal Data

  1. 5.1

    We may share and disclose Personal Data with:

    (a)   our partners and suppliers in connection with the provision of Services to our customers;

    (b)   partners, licensors, vendors, agents, contractors or third-party service providers who provide services to us including
            but not limited to insurance, consultancy, courier services, telecommunications, IT, payment, printing, billing, payroll
            processing, technical services, training, market research, call centre, security or other such services to us;

    (c)   a Complainant.

    (d)   in the event of an actual or prospective business asset transaction (such as any merger, acquisition, or asset sale),
            any business partner, investor, assignee, or transferee for the purposes of facilitating such a transaction; and/or

    (e)   any relevant government regulators, statutory boards or authorities, or law enforcement agencies as required by any
            laws, rules, guidelines, and regulations or schemes imposed by any government to bodies and authorities.

  2. 5.2

    Personal Data is disclosed to the above only for the Purposes or otherwise in accordance with the applicable personal data protection laws.

  3. 5.3
    In exceptional circumstances, we may also be required to disclose Personal Data where, amongst others, there are grounds to believe that disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes.
  4. 5.5
    We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations and shall ensure that any personal data transferred overseas will be made in accordance with the PDPA.

6. Accuracy and Updating of Personal Data

  1. 6.1
    We will strive to keep your Personal Data accurate. You will be given the ability to review and update your Personal Data that we have in our possession.
  2. 6.2
    You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Further, when you provide us with any Personal Data relating to a third party (including your spouse, children, parents, and/or employees), you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data unless otherwise provided in the PDPA.
  3. 6.3
    If there is any Personal Data relating to you that you are unable to update and which you wish to make corrections to, you may contact our Data Protection Officer (whose contact is set out below) and we will be happy to help you as best as we can.

7. Access to Personal Data and Respecting Individual’s Consent

  1. 7.1

    If you wish to access the Personal Data that we have relating to you, inquire about the way in which Personal Data relating to you has been used or disclosed by us in the past year, or wish to withdraw your consent to our use of such Personal Data, you may contact our Data Protection Officer (whose contact is set out below) and we will seek to attend to your request as best as we reasonably can. Please note that:

    (a)   in order for us to provide any personal data we will need to verify your identity and may request further
            information about your request;

    (b)   we may refuse access to your Personal Data if it would affect the privacy rights of other persons or if it breaches any
            confidentiality that attaches to that information;

    (c)   we may also refuse your request where we are legally permitted to do so and give you such reasons;

    (d)   you should be aware that we may take a reasonable time to process your application for access as we may need to
            retrieve information from storage and review the information in order to determine what information may be provided;

    (e)   we may have to charge you a reasonable administrative fee for retrieving Personal Data relating to you.

  2. 7.2

    For the avoidance of doubt, if we refuse to grant you access to your Personal Data, we shall preserve a complete and accurate copy of the Personal Data for a period of 30 days after the date on which we notify you of our refusal to do so.

8. Security of Personal Data

  1. 8.1
    Safeguarding and respecting the confidentiality of Personal Data is important to us. We will use our best efforts to protect Personal Data.
  2. 8.2
    The Personal Data provided to us are stored on secure servers. We also have security measures in place to protect against unauthorized access, loss, misuse, and alteration of Personal Data under our possession and/or control.
  3. 8.3
    Regardless of the precautions taken by us or by you, no data transmitted over the Internet or any other public network can be guaranteed to be 100% secure. We cannot ensure or warrant the security of any information you transmit to us and you provide all Personal Data via the Site at your own risk. You are responsible for maintaining the security of your User profile information, including your password, and for any and all activities that occur under your account. Do not share this information with anyone. We will never ask you to send your password or other sensitive information to us in an email, though we may ask you to enter this type of information on the Site. If you are sharing a computer with anyone you should always log out before leaving a site or service to protect access to your Personal Data from subsequent users.
  4. 8.4
    To the extent permissible under the applicable laws, we will not be held liable or responsible for any loss, misuse, or alteration of Personal Data that may be caused by third parties.

9. Retention of Personal Data

  1. 9.1

    We will only retain Personal Data for only as long as:

    (a)   the retention of the Personal Data continues to serve any Purpose; and
    (b)   there is a business or legal need.

  2. 9.2

    In the event that retention of Personal Data is no longer necessary for any business or legal purposes or when the purpose for which the Personal Data was collected is no longer being served by the retention of the Personal Data, we will remove, destroy or anonymise the Personal Data.

10. Transfer of Personal Data Outside Singapore

  1. 10.1
    Your Personal Data may be transferred to, stored, or processed outside of Singapore.
  2. 10.2
    We will only transfer your information overseas in accordance with the PDPA and will ensure that overseas organisations we work with observe strict confidentiality and are subject to data protection obligations.
  3. 10.3
    In particular, we will ensure that the overseas organisations we transfer your Personal Data to will provide a standard of protection comparable to the protection under the PDPA.

11. Breach of Personal Data

In the event of a data breach of your Personal Data (“Breach”), we will promptly conduct an assessment of whether the Breach is notifiable to the Personal Data Protection Commission (“PDPC”) in accordance with the PDPA. If the Breach is notifiable to the PDPC, we will also notify you of the occurrence of the Breach in accordance with the PDPA.

12. Disclosure of personal information policy and procedure of making a complaint

  1. 12.1
    If you believe that we have breached this Privacy Policy or any other applicable privacy or data protection laws or regulations which may apply to us, you should make a complaint to us in the first instance. You should address your complaint in writing to our Data Protection Officer (whose contact is set out below), and you should include as much detail as you can about the Personal Data affected, and the circumstances that you believe amount to a breach of this Privacy Policy or the PDPA.
  2. 12.2
    If you have any questions about our Privacy Policy or concerns about our commitment to your privacy, please feel free to email or write to the Data Protection Officer (whose contact details are set out below).

13. How to contact us

Please feel free to contact our Data Protection Officer at This email address is being protected from spambots. You need JavaScript enabled to view it..

14. Changes to the Privacy Policy

We reserve the right to modify and update this Privacy Policy at any time to ensure it is consistent with industry trends and/or any changes in legal or regulatory requirements.

15. Governing Law

This Privacy Policy shall be governed in all respects by the laws of Singapore.

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