01
Definitions
For clarity, the following terms are used in this policy to describe data, processing and participant roles. These definitions align with common data protection terminology used in Singapore and international privacy practices.
Personal data means any information that relates to an identified or identifiable individual, including name, contact details, identification numbers, transaction records and any other information that can be reasonably linked to a person.
Processing refers to any operation performed on personal data, including collection, recording, organisation, structuring, storage, retrieval, consultation, use, disclosure, combination, restriction, erasure or destruction.
User means any visitor to WealthLtopCore.click or a client of WealthLtopCore who provides personal information for the purpose of receiving information, using tools or engaging advisory services.
Service refers to the functions and features offered by WealthLtopCore through our website, digital materials and advisory interactions that support purpose-driven wealth planning.
Cookies are small text files placed on a device to store information about website visits. They support essential functionality, analytics and preferences management.
02
Data collection and categories
We collect data that is necessary for the operation of our site and the delivery of services. Collection methods include direct user input, automated technologies and third-party sources where applicable.
Data you provide directly
When you interact with our site or engage services, you may provide the following categories of personal data:
- Contact information (name, email address, phone number).
- Professional and employment details relevant to planning discussions.
- Business and demographic information voluntarily supplied for assessment and planning.
- Communications content such as messages, feedback and form responses.
- Account credentials and profile preferences where you create an account or subscribe to materials.
- Any documents or files uploaded for the purpose of receiving advisory services.
Data collected automatically
Certain technical data is collected automatically when you visit the site to support functionality, security and analytics.
- Device and browser information (device type, operating system, browser version).
- IP address and approximate geolocation for security and fraud prevention.
- Usage data such as pages visited, time on site and navigation paths.
- Cookies and similar identifiers used for site functionality and performance measurement.
- Error logs and diagnostic data related to site performance.
- Referrer and campaign parameters where applicable.
Third-party sources
We may receive data about you from trusted third parties to support services or verify information where you have consented or where permitted by law.
- Payment processors and service providers involved in transactions.
- Professional advisors or custodians where information is shared to facilitate planning.
- Publicly available sources and data providers for verification and enrichment.
03
Purposes of processing
We process personal data to perform essential functions and to provide optional services requested by users. Primary purposes include:
- Providing and administering the website, tools and resources offered by WealthLtopCore.
- Delivering advisory services, analyses and reports based on information supplied by the user.
- Communicating updates, account information and requested materials.
- Processing payments and managing billing where applicable.
- Maintaining security, fraud prevention and legal compliance.
- Measuring and improving website performance and user experience through analytics.
- Managing marketing and informational communications for users who opt in.
- Responding to requests, enquiries and regulatory or legal obligations.
Legal bases for processing
Processing is carried out on lawful bases appropriate to the purpose and jurisdiction. Typical legal bases include:
- Performance of a contract where data is necessary to provide the requested service.
- Compliance with legal obligations applicable to our operations.
- Legitimate interests, such as security, site operation and fraud prevention, balanced against individual rights.
- Consent, where users have given clear permission for specific uses of their personal data (for example marketing communications).
Applicable rights
Where relevant laws apply, including cross-border contexts, individuals have recognized rights. WealthLtopCore observes rights consistent with international best practice.
- Right to access: you may request a copy of personal data we hold about you.
- Right to rectification: you may request correction of inaccurate or incomplete data.
- Right to erasure: in certain circumstances you may request deletion of your personal data.
- Right to restriction: you may request limitation of processing in defined situations.
- Right to data portability: where applicable, you may request transfer of data in a structured, machine-readable format.
- Right to object: you may object to processing based on legitimate interests or for direct marketing.
04
Cookies and similar technologies
Cookies are used to enable core site functions, improve performance and deliver analytics. You can manage cookie preferences through your browser or device settings.
Types of cookies used include strictly necessary cookies for site operation, performance cookies for analytics, and preference cookies for user settings.
We categorise cookies as necessary (essential features), performance (usage analytics) and optional (preferences and marketing where applicable).
Users can set browser controls to block or delete cookies. Note that blocking essential cookies may affect site functionality. Detailed controls are provided in browser settings and some cookie banners.
Full cookie policy
Data sharing and disclosures
We disclose data only as necessary to deliver services and comply with legal obligations. Shared recipients are limited and subject to contractual protections.
- Service providers engaged to perform functions on our behalf (hosting, analytics, payment processing).
- Professional advisers and business institutions where sharing is required to fulfil a requested service.
- Legal or regulatory bodies when disclosure is necessary to comply with lawful requests.
- Affiliates and partners under strict data processing agreements where relevant.
- Law enforcement or courts in response to valid legal processes.
- Other parties with user consent for specific transfers or disclosures.
International transfers
Where personal data is transferred outside Singapore, transfers are made in accordance with applicable law and with appropriate safeguards such as standard contractual clauses, where required.
Safeguards may include contractual protections, data processing agreements and technical measures (encryption, access controls) to maintain an appropriate level of protection.
Data retention
We retain personal data only for as long as necessary to fulfil processing purposes, meet statutory obligations and address disputes or inquiries.
Account and profile information is retained while your account is active and for a reasonable period after account closure to meet legal and operational needs.
Communications and correspondence are retained for a period aligned with service delivery and potential dispute resolution needs.
System logs and technical records are retained for security and diagnostic purposes for a defined period consistent with operational requirements.
When retention periods expire or upon verified deletion requests, personal data is disposed of securely using appropriate deletion or anonymisation techniques.
Security measures
We implement administrative, technical and physical measures designed to protect personal data against unauthorised access, disclosure, alteration and destruction. Measures are reviewed periodically and updated as appropriate to evolving risks.
- Access controls and role-based permissions limiting internal access to necessary personnel.
- Encryption of data in transit and storage where appropriate, using industry-standard protocols.
- Regular security reviews, patching and monitoring to detect and respond to incidents.
05
User rights and how to exercise them
Individuals have rights to exercise control over their personal data and to seek further information about processing activities.
- Access to the personal data we hold about you.
- Correction or update of inaccurate or incomplete information.
- Request deletion where legal grounds apply and retention is no longer necessary.
- Object to certain processing activities, including direct marketing.
- Request restriction of processing in specific circumstances.
- Receive a portable copy of data where technically feasible.
- Withdraw consent for processing operations that rely on consent, without affecting prior processing.
- Lodge a complaint with a supervisory authority if you consider your rights have been breached.
How to submit a rights request
To exercise any data subject right, submit a request in writing to the contact details below. Requests should include sufficient information to verify your identity and the data or action you are requesting.
[email protected]
We aim to respond to valid rights requests within a reasonable timeframe consistent with applicable law. Response times may vary depending on the nature of the request and verification requirements.
