ATRAM Data Privacy Statement
The Board of Directors, shareholders, Management and employees of ATRAM Group (“ATRAM”) value the personal data of our customers and all stakeholders.
ATRAM is dedicated to operating the company according to the highest principles of accountability, honesty, integrity and ethics. The policies of ATRAM are geared towards the handling of accounts with confidentiality, scrupulous care, safety and prudent management of customers’ investments. ATRAM exerts all efforts in safeguarding personal data obtained in the performance of its business activities.
As an asset management firm, ATRAM collects various personal data such as personal information and sensitive personal information from prospective customers and existing clients pursuant to the requirements of regulatory bodies such as the BSP, AMLC, and SEC. ATRAM’s fiduciary responsibility is focused towards giving the best products and services suitable to the needs of our clients. This is done by having a gainful knowledge of the client’s financial needs and objectives.
The front-liners are primarily responsible for collecting personal data from customers through the client account opening forms, and through client encounters such as personal meetings, phone calls, or emails. As allowed by regulations, collecting of personal data may also be obtained electronically through an online platform.
ATRAM obtains personal information from prospective customers and existing clients as part of its Know Your Customer (“KYC”) process, which includes, among others:
As and when necessary, ATRAM also verifies or augments the foregoing information with third-party entities including government regulators, judicial, supervisory bodies, tax authorities or courts of competent jurisdiction and, in the process, gains additional client information.
ATRAM uses the information collected for the following purposes:
Access, Disclosure, and Sharing
ATRAM may share personal information it collects with its subsidiaries, affiliates and third parties, under an obligation of confidentiality.
Further, when a prospective customer or an existing client becomes or applies to become a client of any of ATRAM’s parent, subsidiaries and affiliates, such parent, subsidiaries and affiliates concerned has the option, but not the obligation to, rely upon, use, and share clients’ relevant personal and/or account information for any of the following purposes:
In cases where ATRAM needs to provide personal information and sensitive personal information as mentioned above, personal data shall only be given to appropriate recipients. ATRAM assures clients that we do not and will not sell personal data to any third parties. We fully uphold to our obligation to safeguard personal data obtained in the performance of our business activities, pursuant to the requirements of regulatory bodies and in compliance with applicable laws.
ATRAM implements security measures to protect the personal information and sensitive personal information of its clients. These measures may be organizational, physical, or technical. These are necessary to ensure the data’s availability, integrity, confidentiality and protect them from loss or destruction, unlawful access (e.g. hackers), illegal alteration and contamination.
The following security measures are being employed by ATRAM to protect personal data:
Retention and Disposal Procedure
ATRAM follows appropriate retention period pursuant to regulatory requirements. Generally, customer data shall be retained for five (5) years up to ten (10) years from account closure date, or as required by regulation. Proper disposal of personal data shall be observed at all times and performed in a secure manner to prevent illicit processing, unauthorized access and disclosure to other parties.
Inquiries and Complaints
Subject to legal and regulatory requirements, ATRAM’s clients shall have the following rights, such as:
ATRAM has policies and procedures to address customer inquiries and complaints as documented in its Financial Consumer Protection Manual. The same policies and procedures shall be followed to address inquiries and complaints related to personal data.
Reporting requirements, as mandated by the regulation, shall strictly be observed.
Changes to ATRAM Data Privacy Statement
ATRAM may update its Data Privacy Statement from time to time to ensure consistency with industry trends and relevant laws and regulations. Please check our website: www.atram.com.ph regularly for updates on how we collect, process, and use your personal information.
ATRAM Group or ATRAM shall refer to ATR Asset Management, Inc. and ATRAM Trust Corporation.
BSP shall refer to the Bangko Sentral ng Pilipinas.
AMLC shall refer to Anti-Money Laundering Council.
SEC shall refer to Securities and Exchange Commission.
Front-liner shall refer to the person or employee who is the first contact of the clients. They usually have the most direct interaction with clients. They are also referred to as “Sales” personnel. In ATRAM, front-liners are employees from ATRAM Solutions, ATRAM Funds, and ATRAM Wealth.
Personal data refers to all types of personal information
Personal Information refers to any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
Processing refers to any operation or any set of operations performed upon personal data including, but not limited to, the collection, recording, organization, storage, updating or modification, retrieval, consultation, use, consolidation, blocking, erasure or destruction of data. Processing may be performed through automated means, or manual processing, if the personal data are contained or are intended to be contained in a filing system.
Sensitive personal information refers to personal information:
(1) about an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical or political affiliations;
(2) about an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;
(3) issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and
(4) specifically established by an executive order or an act of Congress to be kept classified.