Privacy Policy
This Privacy Policy explains how Silverwing Investment Ltd. collects, uses, discloses, and protects personal data when you visit swilservices.com or otherwise interact with us.
Introduction
This Privacy Policy explains how Silverwing Investment Ltd. (“Silverwing”, “the Firm”, “we”, “us”, or “our”) collects, uses, discloses, and protects personal data when you visit swilservices.com (the “Website”) or otherwise interact with us.
We are committed to handling your personal data responsibly and in accordance with applicable data protection laws, including the Singapore Personal Data Protection Act 2012 (PDPA) and, where relevant, the General Data Protection Regulation (GDPR) for visitors in the European Union and the United Kingdom.
By using this Website or submitting information to us, you acknowledge that you have read and understood this Policy.
Who We Are
ilverwing Investment Ltd. is an investment holding and advisory firm operating across the Asia-Pacific region. For the purposes of this Policy, we act as the data controller responsible for your personal data.
Contact for privacy matters: legal@silverwing.asia
Who We Are
We collect personal data in the following ways:
- Information you provide directly. When you complete an enquiry form, contact us by email, or otherwise correspond with us, we may collect your name, email address, telephone number, company or organisation, job title, and the content of your message or enquiry. Our forms are provided through JotForm, and data submitted through them is processed on our behalf.
- Information collected automatically. When you visit the Website, we collect certain technical and usage data through cookies and analytics tools. This may include your IP address, browser type and version, device type, operating system, referring website, pages viewed, time spent on pages, and general location inferred from your IP address.
- We do not intentionally collect sensitive personal data through the Website. Please do not submit sensitive information (such as financial account details, identification numbers, or health information) through our enquiry forms.
How We Use Your Personal Data
We use personal data for the following purposes:
- to respond to your enquiries and communicate with you about your request;
- to provide, operate, and improve the Website and understand how visitors use it;
- to assess and pursue potential business, investment, and advisory opportunities where you have engaged with us in that context;
- to maintain records and manage our business relationships;
- to comply with legal, regulatory, and internal governance obligations; and
- to protect the security and integrity of the Website.
Where the GDPR applies, we rely on the following legal bases: your consent, our legitimate interests in operating and growing our business, the performance of steps taken at your request prior to entering an agreement, and compliance with legal obligations.
Cookies and Analytics
The Website uses cookies and similar technologies to function correctly and to help us understand visitor activity.
We use Google Analytics to collect aggregated statistics about how visitors use the Website, such as pages viewed, session duration, and bounce rate. Google Analytics sets cookies and processes usage data on our behalf. You can find information on how Google handles data at Google’s own privacy resources, and you may opt out of Google Analytics using Google’s browser add-on.
You can control or disable cookies through your browser settings. Restricting cookies may affect how parts of the Website function.
Disclosure of Personal Data
We do not sell your personal data. We may share personal data in the following limited circumstances:
- with service providers who support the operation of the Website and our business, including our hosting provider, form provider (JotForm), and analytics provider (Google), acting on our instructions;
- with professional advisers such as lawyers, accountants, and auditors where reasonably necessary;
- with regulators, law enforcement, or other authorities where required by law or to protect our legal rights; and
in connection with a corporate transaction, such as a reorganisation, merger, or transfer of assets, where personal data may form part of the transferred business.
We require our service providers to protect personal data and to use it only for the purposes for which it was disclosed.
International Transfers of Data
We operate across multiple jurisdictions, and our service providers may process data outside the country in which you are located. Where personal data is transferred across borders, we take reasonable steps to ensure it receives a standard of protection comparable to that required under applicable law, including the PDPA and, where relevant, the GDPR.
Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to respond to enquiries, maintain business relationships, and meet legal, regulatory, and accounting requirements. When personal data is no longer required, we take reasonable steps to delete or anonymise it.
Security
We apply reasonable administrative, technical, and physical safeguards to protect personal data against unauthorised access, disclosure, alteration, and loss. No method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
Your Rights
Depending on your location and applicable law, you may have the right to:
- request access to the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- withdraw consent to our use of your data, where processing is based on consent;
- request deletion of your data in certain circumstances;
- object to or restrict certain processing; and
- request a copy of your data in a portable format, where the GDPR applies.
To exercise any of these rights, please contact us at legal@silverwing.asia. We will respond within the timeframe required by applicable law. If you are in the EU or UK and believe we have not handled your data properly, you may lodge a complaint with your local supervisory authority. If the PDPA applies, you may contact Singapore’s Personal Data Protection Commission.
Third Party Links
The Website may contain links to third party websites, including professional platforms such as LinkedIn. We are not responsible for the privacy practices or content of those sites, and we encourage you to review their privacy policies.
Children
The Website is intended for business and professional audiences and is not directed at children. We do not knowingly collect personal data from individuals under the age of 18.
Changes to This Policy
We may update this Policy from time to time to reflect changes in our practices or legal requirements. The current version will always be posted on this page with the “Last updated” date. Material changes will take effect when the revised Policy is published.
Contact Us
If you have any questions about this Policy or how we handle your personal data, please contact:
Silverwing Investment Ltd.
Email: legal@silverwing.asia