Privacy Policy

Introduction

Kelvin Strauss is committed to protecting the privacy and confidentiality of personal information provided by our clients and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in accordance with Singapore's Personal Data Protection Act 2012 (PDPA) and other applicable data protection regulations.

This policy applies to all information collected through our website, consulting services, and any related communications. By engaging with our services or using our website, you consent to the data practices described in this policy.

Information We Collect

Personal Contact Information

We collect personal information that you voluntarily provide when engaging with our consulting services or contacting us through our website:

• Full name and preferred form of address
• Email address and telephone numbers
• Postal address and location information
• Professional title and company affiliation where relevant
• Preferred communication methods and times

Financial Information

For clients engaged in consulting services, we collect financial information necessary to provide appropriate guidance:

• Details of existing investment holdings and accounts
• Financial objectives and stated priorities
• Income sources and ranges where relevant to planning
• Existing financial commitments and liabilities
• Documentation related to current financial position

Usage Data and Analytics

We automatically collect certain information about your interaction with our website:

• Browser type and version information
• Device type and operating system
• Pages visited and time spent on each page
• Referring website addresses
• Date and time of visits
• Aggregate user behavior patterns

Communication Records

We maintain records of communications between clients and our consulting team:

• Email correspondence and attachments
• Meeting notes and discussion summaries
• Consultation documentation and recommendations
• Questions submitted through contact forms

How We Use Your Information

We process personal information for the following purposes:

Service Provision

• Delivering consulting services as contracted
• Analyzing financial positions and developing recommendations
• Communicating regarding ongoing advisory relationships
• Providing documentation and reports
• Responding to inquiries and service requests

Client Relationship Management

• Maintaining continuity in advisory relationships
• Scheduling consultations and periodic reviews
• Following up on previous discussions
• Tracking service preferences and communication needs

Legal and Regulatory Compliance

• Meeting requirements under the Monetary Authority of Singapore regulations
• Maintaining records as required by financial services legislation
• Responding to regulatory inquiries where obligated
• Preventing fraud and ensuring security

Service Improvement

• Analyzing website usage to enhance user experience
• Understanding service effectiveness through client feedback
• Developing improved consulting methodologies
• Identifying areas for additional resources or documentation

Legal Basis for Processing

We process personal information under the following legal bases:

• Consent: You have explicitly consented to our collection and use of your information for specific purposes
• Contract Performance: Processing is necessary to fulfill our consulting engagement with you
• Legitimate Interests: Processing serves our legitimate business interests in providing quality consulting services while respecting your rights and expectations
• Legal Obligation: Processing is required to comply with applicable laws and regulations governing financial services in Singapore

Information Sharing and Disclosure

We do not sell, trade, or rent personal information to third parties. Information may be shared only in the following limited circumstances:

Service Providers

We may engage trusted third-party providers who assist in delivering our services:

• Secure cloud storage providers for document management
• Analytics services to understand website usage patterns
• Email and communication platforms
• Professional indemnity insurance providers

These providers are contractually bound to protect confidentiality and use information only for specified purposes.

Legal Requirements

We may disclose information when required by law or legal process:

• In response to valid legal requests from regulatory authorities
• To comply with court orders or legal proceedings
• To protect our legal rights and enforce our agreements
• To investigate potential violations or fraud

Business Transfers

In the unlikely event of a merger, acquisition, or sale of assets, client information may be transferred to the acquiring entity, subject to the same confidentiality protections outlined in this policy.

Data Retention

We retain personal information for different periods depending on the nature of the data and legal requirements:

• Client Consulting Records: Maintained for seven years following the conclusion of the advisory relationship, as required by financial services regulations
• Communication Records: Retained for the duration of the advisory relationship plus seven years
• Website Analytics Data: Aggregated data retained indefinitely; individual user data retained for 24 months
• Marketing Communications: Retained until you request removal from our contact lists

Following retention periods, information is securely deleted or anonymized beyond reconstruction.

Data Security Measures

We implement comprehensive security measures to protect personal information:

Technical Safeguards

• Encryption of data in transit and at rest
• Secure socket layer (SSL) technology for website communications
• Regular security assessments and vulnerability testing
• Firewall protection and intrusion detection systems
• Secure backup procedures with encrypted storage

Administrative Controls

• Access limited to personnel directly involved in your advisory relationship
• Confidentiality agreements for all team members
• Regular staff training on data protection practices
• Documented information security policies and procedures

Breach Response

In the event of a data breach affecting personal information, we will notify affected individuals and relevant authorities in accordance with Singapore's PDPA requirements, typically within 72 hours of discovering the breach.

Your Rights and Choices

Under Singapore's Personal Data Protection Act, you have the following rights:

Access and Correction

You may request access to your personal information and request corrections to inaccurate or incomplete data. We will respond to access requests within 30 days.

Withdrawal of Consent

You may withdraw consent for non-essential processing at any time. Note that withdrawal may affect our ability to provide certain services where processing is necessary for service delivery.

Data Portability

You may request copies of your information in commonly used formats for transfer to another service provider.

Restriction of Processing

You may request limits on how we process your information in certain circumstances, such as while we verify accuracy of disputed data.

Deletion

You may request deletion of your personal information, subject to legal obligations requiring retention for specified periods under financial services regulations.

Cookies and Tracking Technologies

Our website uses cookies and similar technologies. For detailed information about our cookie practices, please refer to our Cookie Policy.

International Data Transfers

While we primarily operate within Singapore, some service providers may process data in other jurisdictions. When transferring data internationally, we ensure:

• Adequate protection through appropriate safeguards
• Compliance with Singapore's PDPA requirements for overseas transfers
• Contractual commitments from recipients to maintain equivalent protection
• Adherence to relevant international data protection frameworks

Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that information has been collected from someone under 18, we will delete it promptly.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. Material changes will be communicated through:

• Prominent notice on our website
• Email notification to clients with active advisory relationships
• Updated "Last Modified" date at the top of this policy

Continued use of our services following notification constitutes acceptance of the updated policy.

Contact Information

For questions about this Privacy Policy or to exercise your data protection rights, please contact:

We will respond to privacy inquiries within 30 days of receipt.

Complaints and Dispute Resolution

If you believe we have not adequately addressed your privacy concerns, you may:

1. Submit a written complaint to our Privacy Officer at the contact information above
2. Lodge a complaint with Singapore's Personal Data Protection Commission (PDPC)
3. Seek recourse through appropriate legal channels if the matter remains unresolved