Milltrust International Group understands that your privacy is important to you and that you care about how your personal datais used and shared online. We respect and value the privacy of everyone who visits this website, www.milltrust.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Milltrust International Group” means Milltrust International Group (Singapore) Pte. Ltd, a limited company registered in the Republic of Singapore under company number 201026816M, whose registered address is 160 Robinson Road #17-01, SBF Center, Singapore 068914, and whose main trading address is 39B Tras St, Singapore, 078978; “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”); and “We/Us/Our” means Milltrust International Group, and the following group companies:
Milltrust International LLP, a limited liability partnership registered in England under company number OC344800, whose registered address is 5 Market Yard Mews, 194-204 Bermondsey Street, London SE1 3TQ, United Kingdom, and whose main trading address is 6 Stratton Street, London W1J 8LD, United Kingdom;
East India Capital Management Pte. Ltd, a limited company registered in the Republic of Singapore under company number 201209230E, whose registered address is 160 Robinson Road #17-01, SBF Center, Singapore 068914, and whose main trading address is 39B Tras St, Singapore, 078978; and
Milltrust Agricultural Investments Limited, a limited company registered in England under company number 9892345, whose registered address is 5 Market Yard Mews, 194-204 Bermondsey Street, London SE1 3TQ, United Kingdom, and whose main trading address is 6 Stratton Street, London W1J 8LD, United Kingdom.
2. Information About Us
2.1 Our Site is owned and operated by Milltrust International Group (Singapore) Pte. Ltd.
2.2 We can be contacted by email at firstname.lastname@example.org, by telephone on +65 6225 3052 or +44 0208 123 8369, or by post at 39B Tras St, Singapore 078978 or 6 Stratton Street, London, W1J 8LD, United Kingdom.
2.3 Milltrust International LLP is authorised and regulated by the Financial Conduct Authority (FRN: 505716). East India Capital Management Pte. Ltd is a subsidiary of Milltrust International LLP and is registered with the Monetary Authority of Singapore as a Registered Fund Management Company (RFMC).
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you (see section 12);
4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13);
4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using your personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of Our Site, We may collect some or all of the following personal and non-personal data:
5.2 business/company name
5.3 job title;
5.4 contact information such as email addresses and telephone numbers;
5.5 demographic information such as post code;
5.6 IP address;
5.7 web browser type and version;
5.8 operating system; and
5.9 a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
6.2.1 Supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
6.2.2 Personalising and tailoring Our services for you;
6.2.3 Replying to emails from you;
6.2.4 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by checking the “unsubscribe” link in our emails.
6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone, or post with information and news on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
6.4 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
6.5 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
6.5.1 Where there is a legal or regulatory requirement to retain data for a specific period, we will retain your data only for as long as prescribed by these requirements;
6.5.2 If you ask to delete your personal data, and there is no legal or regulatory requirement to retain this data, we will do so within 7 days of receiving your request.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
7.3 Where data is stored by Milltrust companies located in Singapore, those companies comply with the GDPR as is they were located in the EEA.
7.4 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
7.5 Steps We take to secure and protect your data include identifying any third parties who may store your data, and ensuring that they have data protection policies and procedures in place which are equivalent to those required under the GDPR.
8. Do We Share Your Data?
8.1 We may share your data with the other companies in Our group listed under definitions above.
8.2 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.3 We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR.
8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. You will retain the option to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 When you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in section 14.
13.2 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
13.3 Before Cookies are placed on your computer or device, you will be shown a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
13.4 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in section 13.5. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.6, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
13.5 The following first-party Cookies may be placed on your computer or device:
|Google Analytics||Helps us track visitors to our site.|
|Google Tag Manager||Helps us understand what parts of the site people are visiting.|
13.6 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
13.7 You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
13.8 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
14. Contacting Us
Milltrust International Group (Singapore) Pte. Ltd