These Terms and Conditions, its Schedules and application form(s) submitted by you (including any terms and conditions or disclaimers thereto) (read and construed together collectively as forming this “Agreement”) between you and Endow.us Pte. Ltd. (Company No. 201708816N) (“Endowus”) shall constitute the legal agreement between us. 

By electronically accepting or acknowledging this Agreement, using our Services or signing up for an Account with Endowus, you represent and undertake, and are deemed to have read, accepted and agreed to the terms of this Agreement.

1. Introduction
   1. In this Agreement, unless the context otherwise requires, the terms, words and expressions used in this Agreement shall have meanings set out in Schedule 1.
   2. Endowus provides the Services to you through your usage of the Platform and the relationship between you and Endowus is governed by this Agreement. This Agreement shall apply to and govern our provision of the Services to you, your Account with us and all Transactions carried out through your Account. The terms of use of the Platform are set out in the Platform Agreement. In the event of any conflict or inconsistency between any provisions of this Agreement and the Platform Agreement, the terms of the Platform Agreement shall prevail in respect of the matters contained therein to the extent of such conflict or inconsistency. 
   3. Your use of our Services is subject to you fulfilling the following general criteria, and upon our request, providing us with such information and documents to prove that you fulfil the criteria:
      1. you shall have completed an application or registration form required by us through our website;
      2. you have received an acceptance notice from us confirming that you may use and access the Platform, your Account and/or our Services; 
      3. you have completed the Needs Analysis and Customer Knowledge Assessment form, where applicable; and
      4. such other criteria as we may determine from time to time.
   4. For the avoidance of doubt, we are not obliged to open any Account for you or provide you with any Service and we are not required to provide you with any reasons should we choose not to do so. 
   5. You shall be taken to have accepted the terms and conditions of this Agreement upon your first access and use of your Account and/or our Services.
   6. The Account which we grant to you also belongs exclusively to you and is not transferable to any other person.
   7. You undertake not to register for more than one Account or register an Account on behalf of any person other than yourself.
2. General terms and conditions
   1. The General Terms and Conditions are found in Schedule 2.
3. Financial advice and investment recommendations
   1. Endowus provides financial advisory services to you through your usage of the Platform, including financial profiling, financial advice, investment portfolio recommendation, trade execution and rebalancing of your investment portfolio (the "Services"). For the avoidance of doubt, Endowus does not conduct discretionary portfolio management. Trade execution and rebalancing of your Investment Portfolio will only be carried out in accordance with your investment portfolio selection. 
   2. Any financial advice and investment portfolio recommendation is based on the information provided by you. Any inaccurate or incomplete information provided by you may adversely affect the suitability of advice of recommendations. Therefore, you are recommended to update Endowus as soon as possible where there are any material changes to the information provided by you. 
   3. You may notify Endowus of any change in your profile or information and request that we review and reconstruct your investment portfolio at any point in time.  
   4. Without prejudice to any provisions in this Agreement, where you fail to update Endowus as soon as possible (including as contemplated under paragraph 3.2) or where you elect not to provide Endowus with the required information to form the basis of its financial advice or recommendation and/or if you choose to adopt an investment portfolio that differs from our recommendation, Endowus shall not be responsible or liable for any Losses resulting from such election. 
4. Needs Analysis / Customer Knowledge Assessment
   1. You agree and acknowledge that in making any recommendation, we may be required to take into account and give due consideration to your investment knowledge and experience (“Customer Knowledge Assessment” or “CKA”), or of your investment profile, financial objectives, financial situation, and particular needs (the “Needs Analysis”) before or while providing any Services, opening any Account or to entering into any Transaction for your Account. The CKA and Needs Analysis may be recorded in such document as we may require from time to time. Pursuant to such CKA and Needs Analysis, we may collect information about your investment objectives, financial situation and particular needs, including but not limited to the following:
      1. your financial objectives;
      2. your risk tolerance;
      3. your employment status;
      4. your financial situation, including your assets, liabilities, cash flow and income;
      5. the source and amount of your regular income;
      6. your financial commitments;
      7. your current investment portfolio, including any life policy;
      8. whether the amount to be invested is a substantial portion of your assets;  
      9. whether you hold a diploma or have higher qualifications in accountancy, actuarial science, business/business administration/business management/business studies, capital markets, commerce, economics, finance, financial engineering, financial planning, computational finance and insurance;
      10. whether you have a professional finance-related qualification; 
      11. whether you have invested in certain collective investment schemes or investment-linked policies at least 6 times in the preceding 3 years, or any other unlisted Specified Investment Products at least 6 times in the preceding 3 years; and
      12. whether you have a minimum of 3 consecutive years of working experience in the past 10 years in the development of, structuring of, management of, sale of, trading of, research on and analysis of investment products or the provision of training in investment products, including any work experience in accountancy, actuarial science, treasury or financial risk management activities.
   2. You warrant and represent to us, and shall be deemed to warrant and represent to us on each occasion that any information is provided to us for purposes of determining your investment knowledge and experience or Needs Analysis, that all such information provided to us is accurate, correct, complete, and up-to-date.
   3. You hereby agree and confirm that:
      1. the information provided by you will be the basis on which our recommendations to you will be made;
      2. we are entitled to rely and act, and continue to rely and act, on the information you provide to us without verifying such information, and without any further inquiry or investigation;
      3. you are, at all times, responsible and liable for the accuracy, correctness, and completeness of the information;
      4. you will promptly update and inform us of any change in such information; 
      5. inaccurate and incomplete information provided may therefore affect the suitability of our recommendations; and
      6. if you do not provide the information requested by us, or if you provide us with incorrect or incomplete information, we may recommend an Investment Portfolio to you based only on the information you have provided. In such case, you shall be solely responsible for ensuring that the Investment Portfolio (even if it is Recommended Investment Portfolio (as defined below)) is suitable and appropriate for you, taking into account your specific objectives, financial situation, investment experience, knowledge and particular needs. Further, we may also elect not to provide or continue to provide you with our Services.
         
         Notwithstanding the above, you agree that we may at any time confirm with you that there are no material changes to the information provided to us for purposes of determining your investment knowledge and experience or Needs Analysis.
   4. Where you are an Accredited Investor, you agree and acknowledge that Endowus may, but shall not be required to, carry out CKA or the Needs Analysis and this paragraph shall not apply to you. You will be regarded as having the relevant knowledge and experience to assess the suitability of our recommendation. You will accept full responsibility for assessing and determining whether any recommendations are suitable and appropriate for you.
5. Investment portfolio recommendation
   1. Based on the CKA and Needs Analysis, general market and economic condition, and any other factors which we consider to be relevant, we may recommend an investment portfolio to you ("Recommended Investment Portfolio"). In creating the Recommended Investment Portfolio and determining if the relevant products in your Investment Portfolio are suitable for you, we may take into consideration the nature of the products, key risks and other features, including the investment tenor, fees and liquidity required. 
   2. The Recommended Investment Portfolio may include a summary of information gathered pursuant to the CKA/ Needs Analysis in paragraph 4.1 of this Agreement and the basis of the recommendations made to you. If we are unable to identify a Recommended Investment Portfolio based on the information you have provided, we will inform you.
   3. You agree that you are not obliged to accept any advice provided by, or recommendation made by us (including any Recommended Investment Portfolio) and you shall be entitled to determine, in your sole discretion, whether to accept, reject or implement an advice, recommendation or opinion (including any Recommended Investment Portfolio) made by us. If you wish to elect not to adopt the Recommended Investment Portfolio, or if at any time you wish to vary the Recommended Investment Portfolio, you may do so by contacting Endowus to adjust and construct your own proposed investment portfolio ("Self-Select Portfolio"). In such case, however, we may, but shall not be obliged to agree to provide the Services to you. 
   4. In electing the Self-Select Portfolio, you understand that you are choosing not to accept our recommendation, and that proceeding with the Transaction(s) relating to the Self-Select Portfolio are not recommended by us. Further even if we do agree to proceed with such Transactions, you hereby acknowledge and confirm that you shall be solely responsible for ensuring that your Self-Select Portfolio and Investments entered into are suitable and appropriate for you, taking into account your specific objectives, financial situation, investment experience, knowledge and particular needs.
   5. We may recommend changes to the Investment Portfolio agreed between you and us due to changes in your specific objectives, financial situation, investment experience, knowledge and particular needs, general economic or market conditions, or any other factors which we consider to be relevant. For the avoidance of doubt, you agree that in recommending such changes, we are entitled to rely and act on the information you provided to us previously without verifying such information, and without any further inquiry or investigation.
   6. Until we provide such recommendation as referred to in paragraph 5.5 above to you, you agree, that we shall be entitled to act on the previously agreed Investment Portfolio.
   7. If you refuse to provide such information relating to specific objectives, financial situation, investment experience, knowledge, educational qualifications, work experience and particular needs, general economic or market conditions or any other factors which we consider to be relevant, changes to such information or if any such information is omitted, we may not be able to provide you with suitable recommendations or construct a Recommended Investment Portfolio for you. In such case, you will need to contact Endowus to create a Self-Select Portfolio in order to proceed with Transactions and in doing so, you will be taken to have chosen not to receive any recommendations from us. Do note that in such cases, Endowus may elect not to allow you to proceed further.
   8. Our Investment Portfolios may include investment products which are considered to be Specified Investment Products that are neither listed for quotation nor quoted on a securities market or futures market under the MAS FAA Notice on Recommendations on Investment Products, as may be amended from time to time ("unlisted SIP"). Where your Investment Portfolio includes an unlisted SIP, we are required to consider whether you have the relevant educational qualifications, investment experience and work experience for such product.  
      1. Where we have determined that you do NOT have the relevant knowledge or experience, we will need to ensure the following requirements are met: 
         1. If you have been assessed NOT to have the relevant knowledge and experience, you will not be allowed to transact in such unlisted SIPs. If you have not provided any relevant information on your educational qualifications, investment experience and work experience, you will be automatically be deemed NOT to possess the relevant knowledge and experience. 
         2. In such case, the Investment Portfolios will not be suitable for you. In such case, Endowus may not accept you as a customer. 
         3. However, if you wish for your Investment Portfolio to include unlisted SIPs and wish to proceed in spite of the above, you will need to contact Endowus and opt for the Self-Select Portfolio.  
         4. Before we allow you to proceed with the Self-Select Portfolio including unlisted SIPs, you will need to provide written confirmation that: (i) you understand that you have been assessed as not possessing the knowledge or experience in the unlisted SIP; (ii) nonetheless, you still intend to proceed despite such assessment; and (iii) you will accept full responsibility to ensure the suitability of the unlisted SIP. In providing such confirmation, you understand that you are proceeding at your own risk. 
      2. Where you have been determined to have the relevant knowledge or experience, and Endowus has included unlisted SIPs in your Recommended Investment Portfolio, you hereby confirm and acknowledge that Endowus has advised you on the unlisted SIP. You are advised to take note of the relevant information on the unlisted SIP. However, if you choose to increase your investments in unlisted SIPs or you otherwise choose the Self-Select Portfolio option, you hereby acknowledge and confirm that: 
         1. you do not wish to receive any advice concerning the unlisted SIP;
         2. you understand it is your responsibility to ensure suitability of the unlisted SIP provided; and
         3. you understand that in doing so, you will not be able to rely on Section 27 of the FAA to file a civil claim in the event that you allege you suffer a loss. You are still advised to take note of the relevant information on the unlisted SIP. 
         4. Endowus refreshes its CKA on a periodic basis. If you fail to provide Endowus with the required information for its CKA refresher on a timely basis, Endowus may need to cease any Transactions in unlisted SIPs in your Investment Portfolio and in such case, you accept full risk and liability for any Losses that may be incurred as a result. 
   9. When making a recommendation in relation to a collective investment scheme, Endowus may be required to provide you with a copy of the prospectus/profile statement and Product Highlights Sheet (if applicable) in respect of the collective investment scheme and/or any other offer document as may be prescribed by the relevant laws, including any supplementary prospectus/profile statement or replacement prospectus/profile statement in respect of the collective investment scheme. By signing these terms, you hereby agree and consent to Endowus providing you with an abridged version of the document or statement, where applicable. 
   10. Where you are an Accredited Investor, you agree and acknowledge that this paragraph does not apply to you. Endowus may, but shall not be required to, provide a reasonable basis for its recommendations. You will accept full responsibility for assessing and determining whether any recommendations are suitable and appropriate for you.
6. Authorization
   1. You authorize Endowus to: 
      1. recommend Investments to you or otherwise manage your Account and Assets in accordance with the Investment Portfolio and you authorize us to withdraw and invest monies in your Account, as your agent and at your sole risk and account, in the Investments;
      2. execute, approve and effect Transactions or other investment trades on your behalf in connection with the Investment Portfolio and to take any other such actions as may be required in order to do so, including closing out and unwinding Transactions, facilitating payments, dealing with your Assets, liquidating the Investment Portfolio (or part thereof) and taking all routine or day-to-day decisions and otherwise act as we may consider appropriate in its our discretion; and
      3. we may determine how Transactions are to be carried out including investment timing and duration, or decide to use or refrain from using measures to hedge against price, currency or interest risks, choose investment instruments which appear appropriate for hedging and use any other measures to optimize returns on existing investments as we may in its absolute discretion, deem fit provided always that the Transactions, arrangements and actions taken on your behalf are within the relevant Investment Portfolio.
   2. We may pool together or aggregate Transactions executed on behalf of our other clients with Transactions to be executed on your behalf. Therefore, the precise proportion of your Assets allocated to each type of Investment may vary slightly from any illustration or representations of the Recommended or Self-Select Portfolio, save that under no circumstances, will the proportion of your Assets allocated to each type of Investments deviate by more than 20% of what was represented to you, for more than seven (7) consecutive Business Days.
7. Capital injection and Withdrawal 
   1. Injection of funds or monies into your Account as investment capital can be made anytime through the Platform. Endowus will facilitate the Transactions in the next available market day or as soon as practical for any funds credited into or booked into your Account before such times as may be notified to you from time to time. 
   2. Withdrawal of your funds or cash balance in your Account can be made anytime through the Platform. Endowus will facilitate the withdrawal of your Investment Portfolio cash balance and/or liquidation or your Assets in the Investment Portfolio, in full or in part, whichever is applicable, on the next available market day or as soon as practical for any withdrawal request made through the Platform on or before such times as may be notified to you from time to time. For the avoidance of doubt, such withdrawal will be subject to the deduction of any outstanding Fees as described in paragraph 10 of this Agreement.
8. Brokerage and custody arrangement
   1. You agree that Transactions to be executed and/or Investments to be purchased or sold in relation to the Investment Portfolio shall be done through or by any of our nominee, agent or broker as may be appointed from time to time ("Broker").  
   2. Pursuant to Applicable Laws, custody of the Assets (including monies) will be carried out through an appropriately licensed custodian regulated to deal in securities and perform custodial services and where the Investments or assets are denominated in a foreign currency, the Investments may be held with an entity which is licensed, registered or authorised to act as a custodian in the country or territory where the Assets are held (the "Custodian"). 
   3. You agree that we may appoint the same entity to be both Broker and Custodian, but may not necessarily do so. While we may assist you with appointing, opening accounts with the Broker and/or Custodian and providing instructions on your behalf, you will have a direct relationship with each the Broker and/or Custodian. Therefore, Endowus shall not be liable for any Losses arising out of or in connection with the custody of your Assets or execution of Transactions by or through the Broker and/or Custodian. 
   4. In addition to the Broker and Custodian, we may rely on other third party intermediaries, such as agents, nominees, independent investment research houses, exchanges, sub-custodians, depositaries, clearing houses or other services providers ("Intermediaries") in connection with our provision of the Services to you. Notwithstanding any other provision to this Agreement, you hereby acknowledge and agree that provided that we have selected or engaged such Intermediar(ies) in good faith, we shall not be liable to you for any and all Losses suffered or incurred by you as a result of any act, omission, default, insolvency, error or negligence of such Intermediar(ies).  
   5. You acknowledge that the Investment Portfolio Assets and any cash balance may be held in SGD and/or USD terms (or such other currencies as Endowus may deem appropriate) for cost efficacy. 
   6. Without prejudice to any other provision in this Agreement, you agree that:
      1. the Broker and/or Custodian may hold Investments purchased for you in an omnibus account with another Intermediary aggregated with other Investments of other customers; and
      2. your Investments may be treated as fungible with other Investments in the omnibus account and therefore, we are not obliged to deliver any specific Investments to you and may instead sell the Investments at your expense and transfer the credit balance to your Account. 
   7. You also acknowledge and consent to the fact that there is a risk that such Brokers may regard any Investments which we purchase on your behalf, as investments which we purchase for ourselves. This may in some instances result in prejudice to you. For example, there is a risk that your Investments may potentially be used by the Brokers to satisfy our obligations or obligations of our other customers. You accept that this is a necessary risk of dealing in such jurisdictions through us.
   8. For the avoidance of doubt, you agree that neither us nor our appointed Broker shall provide any margin facility to you in respect of the Investments.
9. Risk acknowledgement
   1. You acknowledge and accept the risks set out in the Risk Disclosure Statement in Schedule 2 which forms part of this Agreement. 
   2. Endowus may notify you in writing of any changes to the risks set out in the Risk Disclosure Statement. Unless you object to such changes and terminate within thirty (30) calendar days, you will be deemed to have expressly agreed and accepted such changes and the new Risk Disclosure Statement shall supersede the previous Risk Disclosure Statement to form part of the Agreement. 
10. Fees and charges
    1. The fee payable by you to us for the Services is specified in the Fee Schedule available at www.endowus.com/pricing (“Fees”) as may be amended from time to time. 
    2. We may deduct your Account with the full amount of any Fees payable by you, or any other monies owed by you to us pursuant to any liability of any nature arising in respect of the Account or otherwise. In the event of insufficient cash balance in your Account, we may liquidate your positions in your Investment Portfolio or collect any uninvested cash in your Account to satisfy any shortfall. 
    3. You shall make all payments due under this Agreement free and clear of, and without deduction, withholding or set-off on account of, any tax or levy or any other charges present and future.
    4. You shall be liable for any goods and services tax, value-added tax or any other tax of a similar nature chargeable by law on any payment you are required to make to us. If we are required by Applicable Laws to collect and make payment in respect of such tax, you will indemnify us against such payments. 
11. Referrals
    1. You may have been introduced to us by a third party. We may share our Fees with or provide such other benefit as we may deem appropriate to such third party or any other third party in relation to such introduction. For the avoidance of doubt, we do not accept responsibility for any conduct, action, representation or statement of such third party.
12. Your data and our privacy policy
    1. As a customer of Endowus, you will need to provide us with your information. Such information may be considered to be personal data or personal information protected under the Personal Data Protection Act (No. 26 of 2012) of Singapore. By providing us with your personal data or information, you acknowledge and consent to our collection, use, disclosure and/or processing of your personal data/ information for the purposes set out below: 
       1. client onboarding and facilitating your usage of the Platform and your Account;
       2. providing the Services to you, including providing financial advisory services and recommendations, facilitating Transactions, managing the Assets and Investments;
       3. providing you with information, materials and/or documents for information updating, marketing, advertising and/or promotional purposes relating to our Services, whether the services currently exist or are created in the future; 
       4. comply with Applicable Laws, including client onboarding, compliance procedures, capital injections and/or withdrawals, enforcement of legal rights, disclosure to law enforcement agencies and authorities for crime prevention and detection; 
       5. administration and/or managing of the relationship between you and Endowus; and
       6. any other purposes as reasonably incidental to the above. 
    2. You further agree and acknowledge that Endowus may share your personal data/information with any third parties, including the Broker, Custodian, the CPF Board and any other Intermediaries, where required to do so in connection with the permitted purposes in paragraph 12.1 of this Agreement. Specifically, you hereby acknowledge that Endowus may share your information including, name, unique identification number, address, other client information, transaction information etc. with the Broker, Custodian, CPF Board or such other Intermediaries for the purpose of due diligence, client onboarding, investment trade execution, custody of your Assets and otherwise in connection with providing the Services under this Agreement. 
    3. The foregoing provisions in this paragraph 12 supplements and shall be read and construed together with the Privacy Policy in Schedule 4. 
13. Disclosure of representative information to client 
    1. Endowus holds a Financial Advisers Licence issued by the Monetary Authority of Singapore (MAS). We are authorised to provide the following financial advisory services:
       1. Advising on Investment Products - Collective Investment Schemes
       2. Issuing or Promulgating Analyses/ Reports on Investment Products - Collective Investment Schemes
    2. Financial Adviser Representatives have been appointed by Endowus to provide financial advice. An updated list of our appointed Financial Adviser Representatives may be found at https://endowus.com/support/900001022966-who-are-the-mas-appointed-representatives-for-endow.us-pte-ltd. All Representatives have a Representative ID and have their names listed on the MAS’ Public Register of Representatives. Please refer to the regulatory profile for information about our Representatives.
    3. The types of financial advisory services allowed by the Representatives: 
       1. Advising on Investment Products (Collective investment schemes)
       2. Issuing or Promulgating Analyses/Reports on Investment Products (Collective investment schemes)

SCHEDULE 1 - DEFINITIONS

In this Agreement, where the context so admits, the words and expressions used in this Agreement shall have the following meaning:

“Account” means the account which we have set up and granted to you for your use and access to the Platform and Services pursuant to this Agreement;

“Access Method(s)” means any user identification, passwords and other security credentials assigned to you and required to access and use the Platform using your Account;

"Accredited Investor" has the meaning ascribed to it in section 4A of the Securities and Futures Act (Cap. 289) of Singapore, as may be amended from time to time, and as set out in the Accredited Investor Declaration Form; 

“Affiliates” has the meaning ascribed to it in paragraph 13 of Schedule 2;

“Applicable Laws” means all applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority (including the MAS and IRAS) whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time;

“Asset(s)” means all moneys, cash, interests in collective investment schemes, or other financial instruments or products, and other property of yours held with us or through us;

"Broker" has the meaning ascribed in paragraph 8.1 of this Agreement.

“Business Day” means a day, other than a Saturday or Sunday or public holiday in Singapore; 

"CPF" means the Central Provident Fund; 

"Custodian" has the meaning ascribed in paragraph 8.2 of this Agreement. 

“FAA” means the Financial Advisers Act (Cap. 110) of Singapore;

“Instructions” means any communication, instruction, order, message data or information received by us through or pursuant to the Platform or otherwise referable to your Access Methods, and any information delivered to us offline by any methods as we may agree to;

"Intermediaries" has the meaning ascribed in paragraph 8.3 of this Agreement.

“Investment Portfolio” means Recommended Investment Portfolio and/or Self-Select Portfolio, as the case may be;

“Investments” means any collective investment schemes, interests in unit trusts or mutual trusts, or other financial instruments or investment products which we may purchase or sell on your behalf pursuant to the Investment Portfolio Recommendation or otherwise;

“IRAS” means Inland Revenue Authority of Singapore;

"Loss(es)" means any losses, damages, costs (including legal costs on a full indemnity basis), fines, expenses, fees, charges, actions, suits, proceedings, claims, claims for an account or equitable compensation or equitable lien, any other demands or remedy whatsoever, or any diminution in the value of or loss or damage to any property or security or any lost opportunity whereby the value of the same could have been increased or otherwise, including any direct, indirect, incidental, special and consequential or punitive damages (including losses arising from counterparty risk, investment losses, economic losses or lost profits);

“MAS” means the Monetary Authority of Singapore;

“Personal Data” has the meaning ascribed to it in the Personal Data Protection Act (No. 26 of 2012) of Singapore;

“Platform” means the Endowus online platform (accessible through our website at www.endowus.com or through our mobile application) operated by us including any software or information provided as part of or in connection with the Platform;

“Privacy Policy” means the policy on the privacy and protection of Personal Data adopted by us as made available at Schedule 4, as may be supplemented, amended or varied from time to time upon our notification to you; 

"Recommended Investment Portfolio" shall have the meaning ascribed in paragraph 5.1 of this Agreement;

"Regulatory Body" shall mean any financial, tax, accounting, statutory or other governmental body whether in Singapore or from another jurisdiction, including MAS and IRAS. 

"Self-Select Portfolio" has the meaning ascribed in paragraph 5.3 of this Agreement;

“Service” has the meaning ascribed to it under means any service provided by us pursuant to this Agreement;

 “System” means the hardware, software and telecommunication links or any part thereof used from time to time for the purpose of providing, supporting, accessing and/or otherwise referable to the Platform;

“Transactions” means transactions in such Investments as we may carry out on your behalf under this Agreement; and

"unlisted SIPs" has the meaning ascribed in paragraph 5.8 of this Agreement. 

The words “we”, “us”, “our” or any of their derivatives refer to Endowus and its successors and any novatee, assignee, transferee or purchaser of Endowus’ rights and/or obligations hereunder and any reference to Endowus includes a reference to such successor, novatee, assignee, transferee or purchaser.

The words “you”, “your”, “yours” or any of their derivatives refer to the person who opened the Account and/or uses or intends to use our Services and shall include, as the context may require, executors and administrators (as the case may be).

In this Agreement, unless the context otherwise requires: 

1. references to "include", "includes" and "including" as they appear in this Agreement are not limiting and are deemed in each instance to be followed by the words "without limitation"; 
2. any headings in the Agreement are for ease of reference only and shall not be relied upon in the construction of any of the provisions of the Agreement; 
3. any reference to Schedules shall be references to Schedules to this Agreement; 
4. any document or agreement (including the Agreement and its Schedules) shall be deemed to include reference to such document or agreement as amended, novated, supplemented or replaced from time to time; and 
5. any determination to be made by Endowus or any exercise by Endowus of any rights or entitlement may be made at the sole and absolute discretion of Endowus and, in every case, shall be conclusive and binding on you.



SCHEDULE 2 - GENERAL TERMS AND CONDITIONS

1. Representations
   1. You represent and warrant that:
      1. you are an individual, and the legal and beneficial owner of the Account;
      2. all information and documents provided to us, including the information contained in the application forms completed by you prior to you opening an Account with us, are true, correct and complete and not misleading or incomplete in any material way;
      3. you have provided us with all material information and undertake to update us as soon as possible if there are any material changes to the information and/or document provided to us, otherwise you continue to represent and warrant that all such information provided are and will continue to be true, correct, complete and not misleading or incomplete in any material way; 
      4. you have the capacity, power and authority to enter into, exercise your rights and perform and comply with your obligations under this Agreement;
      5. all actions, conditions and things required to be taken, fulfilled and done, in order: (i) to enable you to lawfully enter into, exercise your rights and perform and comply with your obligations under this Agreement, and (ii) to ensure that those obligations are valid, legally binding and enforceable, have been taken, fulfilled and done;
      6. your obligations under this Agreement are valid, binding and enforceable;
      7. you are solvent, able to pay your debts as they fall due and are a going concern or not an undischarged bankrupt;
      8. your entry into, exercise of your rights and/or performance of or compliance with your obligations under this Agreement does not and will not: (i) violate any agreement to which you or where applicable, any of your affiliates, is a party or which is binding on any of you or your respective assets, or (ii) result in the existence of, or oblige any of you to create, any security over those assets;
      9. you have obtained all consents, licences, approvals or authorisations of, exemptions by or registrations with or declarations by, any governmental or other authority that you require, and these are valid and subsisting and will not be contravened by the execution or performance of this Agreement;
      10. your use of our Services complies with all Applicable Laws; 
      11. (where you elect to invest your CPF savings), that you have sufficient monies in your CPF Account which have been allocated to the CPF Investment Scheme, you meet the requirements for investing in CPF Investment Scheme and comply with applicable CPF rules, regulations and requirements; and
      12. you will inform yourself and, if necessary, consult your own professional advisers as to the relevant legal, tax and exchange control regulations in force in the countries of your citizenship, incorporation, residence or domicile.
2. Compliance with law and tax implications
   1. The provision of all Services by us to you, any Account and Transaction and the relationship between us and you shall be subject to all Applicable Laws. For the avoidance of doubt, we shall not incur any liability to you as a result of acting in accordance with any Applicable Laws (including guidelines, codes or other information, whether having the force of law or otherwise). To the extent that any provision of this Agreement is inconsistent with the requirements of any Applicable Laws or other information applicable to us, including that published by the MAS, the requirements of the relevant Applicable Laws shall prevail over this Agreement.
   2. Without prejudice to the foregoing, no breach or contravention of any Applicable Laws shall discharge or release you from any of its obligations under this Agreement to us unless prohibited under Applicable Laws. 
   3. The availability of any Services or any terms and conditions applicable thereto (including pursuant to this Agreement) may be varied by us without notice to you for compliance (voluntary or otherwise) with the Applicable Laws. 
   4. You understand that your tax affairs are your own responsibility. We do not provide any tax or legal advice to you and while we may rely on external tax or legal advice, we accept no responsibility for such advice, to the extent permitted by Applicable Laws. We do not accept any responsibility in respect of any taxation or legal consequences you may incur in relation to the use of the Platform, Services, Transactions or otherwise in connection with the Agreement. 
   5. You confirm that to the best of your knowledge, you have not committed or been convicted of offences under any applicable tax law or regulation of: (a) a jurisdiction to which you are subject, or (b) Singapore.                                                                                                                                            
   6. To the extent you or any of your Assets are subject to any foreign exchange regulations in any jurisdiction, you hereby represent and warrant to us that all funds deposited or to be deposited into your Account have been at all times legitimately acquired, are not the benefits or proceeds or any criminal conduct and held by you offshore or otherwise in accordance with the relevant foreign exchange regulations (including, without limitation, any requirements relating to repatriation or outward remittances).
3. Identification
   1. As you will be aware, governments have enacted legislation designed to prevent the use of the financial system for the purposes of shielding proceeds of crime, including terrorism. Generally, under these anti-money laundering laws and regulations, we are required to identify, verify and record information for individuals and entities prior to the opening of an account. You acknowledge that we are obliged to carry out “Know Your Client” procedures in accordance with our policies and Applicable Laws.
   2. Accordingly, before we can open an Account for you, provide you with our Services or enter into any Transaction for your Account, you must submit to us (through our website or such other method as we may notify you) all the documents, evidence, and information as we may require to carry out such “Know Your Client” procedures. You undertake to inform us promptly of any change in the information provided.
   3. In addition, you agree to provide any information or documents requested by us in relation to any Account, Transaction and Services, including, where desirable or where required for the purposes of complying with any Applicable Law (including pursuant to any order, direction, or request by any applicable court, government or regulatory authority). We may, from time to time, in our discretion, also ask for additional and up-to-date documentation or information about you, including information as to your source of funds. This includes but is not limited to any applicable anti-money laundering requirements, or any applicable tax disclosure or reporting obligations. If all required documentation or information is not provided, we cannot proceed to open your Account, proceed with any Transaction or establish a relationship with you.
   4. Specifically, and without prejudice to the generality of our rights under paragraph 3.3 of this Schedule 2, we may (where applicable) share the information you provide to us to the Inland Revenue Authority of Singapore and/or such other Regulatory Body as may be applicable for the purposes of complying with our obligations under applicable tax disclosure or reporting obligations. Without prejudice to any other representation and/or warranty you have provided, you confirm that you have examined the information and documents you have provided to us and such information and documents are true, correct and complete.
4. Use of our services
   1. After opening an Account with us, you shall be entitled to enjoy the Services through our Platform which we may provide, subject to any addition, modification, suspension or termination of such Services in accordance with this Agreement.
   2. We may monitor all your use of Services so as to detect any improper activity relating thereto. You shall comply in a timely manner with our requests for information, documents and other material requested by us.
   3. You agree to use our Services only for lawful purposes, in accordance with the terms of this Agreement.
   4. We may at our absolute discretion provide alternative means by which you may enjoy the Services outside the Platform, which will be subject to such terms and conditions as we may notify you.
   5. We are not obliged to effect any particular Transaction, or to accept any order or act in accordance with any Instructions (including, but not limited to, in respect of funds transfer), nor need we give any reasons for declining to do so. If we decline an order we will not be liable for any Loss incurred by you if we fail or delay to notify you unless this is as a result of our gross negligence, bad faith, wilful default or fraud.  
   6. To the extent permitted by Applicable Laws, we and our Affiliates, are not liable for any Loss incurred by you or any third party, including loss of your data, investment losses or lost profits, arising our of your usage or inability to use our Services and the Platform unless caused by our wilful misconduct.   
5. Power of attorney
   1. You authorize us to be your attorney (with full rights of substitution) with full authority to be your true and lawful attorney and to in your name do on your behalf all things you could have done for the purposes of:
      1. carrying out any Transactions for your Account, Services or any of your Instructions;
      2. discharging any of our obligations to you under this Agreement; and/or
      3. doing anything which in our opinion is necessary or desirable to preserve our rights under this Agreement.
   2. You undertake and hereby do ratify and confirm, all that we may do pursuant to this power of attorney.
6. Statements and documents
   1. Any statements and any other documents relating to your Account with us will be sent to you through a URL link to the Platform which will be provided to you monthly via electronic means to the electronic mail address indicated by you at account opening or edited subsequently through the “Change of Email procedure” available on the Platform. You agree and acknowledge that such documents will be made available for viewing on the Platform, and therefore, you may download, save or print the documents for your subsequent reference. If you wish to receive your statements and other documents by hard copy, please contact our Customer Support at support@endowus.com.
   2. You agree to verify the correctness of all details contained in each Account statement, or any document sent to you and inform us within 14 days from the date of such document of any discrepancies, omissions, or errors. Upon the expiry of this period, the details in such documents shall be conclusive evidence against you (save for manifest or clerical error) without further proof, except as to any alleged errors so notified, that such details are correct, but subject always to our right to amend or delete from time to time, any details wrongly inserted by us as set out in paragraph 6.3 of this Schedule below. Except as provided in this paragraph, and provided that we are not fraudulent or in wilful default, we shall be free from all claims in respect of any Account or the details of the Transactions or Services contained in such documents.
   3. We have the right, upon giving reasonable notice to you, to reverse any entry, demand refund, and/or debit the Account in respect of any overpayment or wrongful credit in the Account.
   4. Without prejudice to any of the foregoing we may at any time without prior notice to you rectify any clerical errors that may have been made.
   5. For the avoidance of doubt, any document, advice, statement of account, contract note confirmation or other notification relating to a specific Transaction through any Broker or your Assets held with any Custodian shall be sent to you directly by the Intermediary. Any discrepancies relating to such documents should be notified to the relevant Intermediary directly. 
   6. On the statements relating to the Investment Portfolio, if you identify one or more discrepancies which you determine, acting reasonably and in good faith, are material to our respective rights and obligations in respect of one or more outstanding Transactions, you will notify Endowus and the relevant Intermediary in writing as soon as reasonably practicable and we will consult with each other in an attempt to resolve such discrepancies in a timely manner for so long as such discrepancies remain outstanding, using, without limitation, any applicable updated data produced during the period in which such discrepancy remains outstanding. If you do not notify us that the Investment Portfolio contains discrepancies by 4:00pm Singapore time on the fifth Business Day, following the date on which we provided such data to you, you will be deemed to have affirmed such Investment Portfolio data. 
7. Currency conversion
   1. We are entitled to convert any sum received by us (whether for credit into your Account or in payment of any sum due to us) to the currency of the Account or the currency in which payment is to be made, as the case may be, at a rate of exchange determined by us at the relevant time.
   2. We may, at any time at a rate determined by us in our sole and absolute discretion, convert any amount in any Account or standing to your credit to any other currency for the purposes of carrying out your Instructions or exercising our rights under this Agreement. Exchange rate losses and the costs of conversion shall be borne by you.
8. Set-off and lien
   1. For so long as you owe monies or obligations (of any nature and however arising) to us, you may not withdraw your Assets from you Account without our consent. We may at any time withhold any Assets pending full settlement of all such monies or obligations owed by you.
   2. All your Assets in your Account shall be subject to a continuing first fixed charge and general lien for the discharge of all obligations due from you to us. We have the power to sell any Assets, closeout any positions or liquidate the Investment Portfolio in or towards settlement of your obligations to us.
   3. All documents of title and other documents relating to the Assets shall be deposited or transferred by you to us or otherwise placed at our order or at our disposal or under our control.
   4. You warrant and undertake that none of the Assets held in your Account are or shall be subject to any lien or charge in favour of any other person.
   5. Without prejudice to any right of set-off or general lien or other rights to which we may be entitled, we may set-off from any Assets held in your Account (including any of your monies held in a trust account) against and in whole or partial payment of any sum or liability owed by you to us.
   6. You authorise us to do anything in your name which is necessary for us to be able to do any of the foregoing.
   7. Our rights under this Agreement are in addition to any other rights we have at law or under any other agreement, and shall not prejudice any other rights or security that we may have.
9. Individual accounts 
   1. Where you open an Account with us as an individual, your executor or administrator shall be the only person recognised by us in the event of your death. Upon your death, we are entitled to retain any of your Assets held for, and any monies payable to or credit in any Account until such time that a grant of probate or letters of administration are produced by your successor. Upon receiving notice of your death, we may also, in our absolute discretion, take such actions as we in good faith consider necessary or desirable to protect your interests, and those of your estate, in the assets in the Account. In taking such actions we will not be acting as a fiduciary for you or your estate. You and your estate agree to indemnify us and hold us harmless from, and pay us promptly on demand, any and all losses, costs, expenses, damages and liabilities whatsoever (including consequential and special damage) arising directly or indirectly in relation to any such actions taken by us in good faith.
10. Dormant accounts and unclaimed assets
    1. In the event that you have not accessed your Account through the Platform and there has been no activity in your Account (such as a transfer of funds) for a period of 6 years, the Account will be deemed dormant. For the avoidance of doubt, during such period, we will continue to apply and set off any applicable administrative costs to the dormant Account. If we determine in good faith that we are still unable to trace you thereafter, you agree that the Account will be terminated. All Assets then standing to the credit of any Account or otherwise held by us or our Affiliate (as the case may be) together with any property as may from time to time continue to accrue to those monies and property (whether by way of dividends, interest or otherwise) may forthwith be appropriated by us to ourselves to utilise in any manner we so wish for our own benefit. Thereafter you shall have no right whatsoever to claim such monies and property (or any other property as may accrue to it) and you are deemed to have waived and abandoned all your rights to such Assets (and any other property as may accrue to it) in our favour.
11. No waiver
    1. No failure or delay on our part in exercising any power of sale or any other rights or options hereunder and no notice or demand which may be given to or made upon you by us with respect to any power of sale or other right or option hereunder, shall constitute a waiver thereof, or limit or impair our right to take any action or to exercise any power of sale or any other rights or options hereunder without notice or demand, or prejudice our rights as against you in any respect or render us responsible for any loss arising therefrom. A single or partial exercise of a right, power or remedy does not prevent another or further exercise of that or another right, power or remedy. A waiver of a right, power or remedy must be in writing and signed by the party giving the waiver.
    2. We may grant time or other indulgence to you or any other person, without impairing or affecting in any way any of our rights as against you or any such other persons.
12. Electronics records
    1. Our records (including computer and microfilm stored records or any other electronic records stored by us) of all matters relating to you, any Transactions on your Accounts, the Accounts and/or any Services provided to you is conclusive evidence of such matters and is binding against you for all purposes, save for manifest or clerical error, subject to our right to rectify any error or omission therein and our right to adduce other evidence. You hereby agree not to at any time dispute the authenticity or accuracy of any computer output relied upon by us for any purpose whatsoever.
    2. You acknowledge and agree that we shall be entitled to destroy or dispose of all registers, statements and other records and documents relating to the Account, Services or Transactions at any time after the expiration of any period of retention required by Applicable Law. We shall not be liable in any way for such destruction or disposal. Any records we stored of you, Transactions on your Accounts and/or Services provided to you are conclusive and cannot be challenged by you.
13. Affiliates
    1. You acknowledge and agree that we may, in the conduct of our functions, instead of acting ourselves, delegate to or appoint any service provider, agent, sub-agent, contractor, sub-contractor, broker, dealer, custodian, nominee or other third parties, whether in Singapore or otherwise, (and such persons shall each be referred to in this Agreement as an “Affiliate” of ours, where the context permits) to carry out, execute or clear any Transaction, hold, custodise or deal with your Assets, or provide ongoing maintenance and support services for the operation of the Platform or such other Services or business as may be required by us.
    2. You acknowledge and agree that we may delegate to such Affiliates all or any of the power, authority or discretion vested in us and any such delegation may be made upon such terms and conditions and subject to such regulations (including the power to sub-delegate) as we may think fit and, provided always that we shall have exercised reasonable care in the selection of such Affiliate, we shall not be bound to supervise the actions of and shall not in any way or to any extent be responsible for any loss incurred by you for any failure, neglect, default or breach by any such Affiliate.
    3. You agree that our employees, officers, or Affiliates shall not have any authority to bind us to any obligations or liabilities as otherwise expressly provided in this Agreement.
14. Confidential information
    1. Our duty. Save as permitted under this Agreement or any other agreement with you, we shall treat all information relating to you and your Accounts as confidential.
    2. Non-confidential information. You acknowledge that the following information will not be regarded as confidential information and we do not owe you or any other person any duty to keep such information confidential:
       1. information that as at the date of its disclosure is in the public domain (other than through a breach of this Agreement) or which subsequently enters the public domain;
       2. information that was already in our possession before you provided the information to us;
       3. information which we received from a third party who has lawfully acquired such information and is under no confidentiality obligation regarding its disclosure to us; and
       4. any information which is anonymised or encrypted in such a manner where the identities of any person cannot be readily inferred, or which cannot be referable to any particular person.
    3. Exceptions from duty of confidence. You give us permission to disclose information relating to you and your Account as follows:
       1. any of our directors, officers, employees, representatives, agents or delegates;
       2. any of our Affiliates, shareholders or related corporations and any of their successors, assigns or sub-contractors, and their directors, officers, employees, representatives, agents or delegates;
       3. our professional advisers, consultants and auditors;
       4. anyone who takes over or may take over all or part of our rights or obligations under this Agreement or anyone this Agreement (or any part of it) is transferred to or may be transferred to;
       5. any person who we believe in good faith to be your legal advisers or other professionals;
       6. any Regulatory Body in any jurisdiction, in so far as we need to do so to keep to Applicable Laws, or which we in good faith believe that we should keep to;
       7. pursuant to a request by any Regulatory Body (regardless of the reason for such request and whether such request is exercised under a court order or otherwise); and
       8. to such other persons or under such other circumstances as you agree, provided that in the case of disclosures under any of the circumstances in (a) to (c), we shall, where reasonably possible, procure that the recipient is subject to the same duty of confidence.
    4. Survival. The permission you give by agreeing to paragraph 16 of this Schedule will apply even after this Agreement ends or your Account is terminated.
    5. Your duties. Any data, information or message transmitted to you through our System, the Platform or otherwise is confidential and intended for the sole use of the intended recipient. If you are not the intended recipient, you should immediately notify us and delete or destroy such data, information or message, including all copies thereof.
    6. Confidentiality of Other Information. You must keep confidential, all information about the Platform, our System and any information, data, materials or documents provided to you.
15. Recording
    1. You authorise us and any of our Affiliates to record any telephone conversation or any electronic communication conducted between you and us or our personnel, to retain such recordings and use them in such manner as we consider appropriate. The recordings shall be admissible in evidence in legal proceedings and shall have the same probative value as a written original document. You shall not challenge or dispute the admissibility, reliability, accuracy or the authenticity of the contents of such records and you hereby waive any right (if any) to so challenge or dispute. You agree that the recordings made by us shall be conclusive evidence of the contents and shall be binding on you.
16. Suspension and termination of service
    1. Immediate termination by us. We reserve the right to restrict, temporarily or permanently suspend or terminate your Account, or the provision of any Services, at any time and with immediate effect, without incurring liability of any kind to you, if any of the following events occur:-
       1. you have not fully complied with our account opening criteria and/or met our account opening criteria (as we shall set from time to time), including, our “Know Your Client” procedures;
       2. you fail to make any payment to us or any other party when due, whether under this Agreement or otherwise for the Services;
       3. your death or insanity;
       4. any grounds exist for the presentation of a bankruptcy petition against you;
       5. any representation or warranty made by you under this Agreement or through the Platform or for the Services is incomplete, untrue, incorrect or misleading in any material respect;
       6. you have breached the terms of this Agreement;
       7. you are using the Platform or the Services in a manner that may cause us to breach Applicable Laws, have legal liability or disrupt others’ use of the Platform or the Services;
       8. you are using the Platform or the Services for any illegal activities or where we have reasonable suspicion that you may be doing so, or we become aware or suspect that your Account is or will be used for illegal, fraudulent or unauthorized uses;
       9. we become aware or suspect that your Access Methods (i.e. any user identification, passwords and other security credentials assigned to you and required to access and use the Platform) are stolen, lost, damaged or compromised;
       10. we become aware or suspect that the person logged into your Account is not you;
       11. we are required to do so by Applicable Laws or pursuant to a request by any Regulatory Body;
       12. scheduled downtime, recurring downtime or other material IT security issues;
       13. a Force Majeure Event;
       14. you publish, post, transfer, distribute or upload any content or information to the Platform which is false, misleading or inaccurate, contains rude and inappropriate language or which creates the impression that any content is sponsored or endorsed by us;
       15. you modify, adapt or reverse engineer the Platform or any part thereof;
       16. you transmit any viruses, worms, defects, Trojan horses or any other items presenting cybersecurity risk or of a destructive nature, or that may otherwise compromise the security of the Platform;
       17. you create multiple Accounts;
       18. you create Accounts by automated means or under false or fraudulent pretenses; 
       19. the Investments no longer meet the applicable CPF rules, regulations and requirements (including the admission criteria) in order to remain in the CPF Investment Scheme or are no longer offered by CPF Investment for any other reason whatsoever, where applicable; 
       20. your CPF funds or monies are not adequate for investment in the CPF Investment Scheme, where applicable; or 
       21. you are, in our opinion, the subject of any adverse publicity or involved in any litigation that we reasonably believe would be detrimental to our interests.
    2. For the purpose of paragraph 16.1(m) of this Schedule, “Force Majeure Event” means any event beyond our reasonable control (and which does not relate to or arise by reason of our default or negligence) which renders impossible or hinders our performance of this Agreement including our Services, including, without limitation:
       1. war, riot, civil unrest or revolution, sabotage, terrorism, insurrection, acts of civil or military authority, imposition of sanctions, embargo, breaking off of diplomatic relations or similar actions;
       2. terrorist attacks, civil war, civil commotions or riots;
       3. acts of God, epidemic, pandemic, flood, earthquake, typhoon or other natural disasters or adverse weather or environmental condition;
       4. any act of state or other exercise of sovereign, judicial or executive prerogative by any government or public authority, including expropriation, nationalisation or compulsory acquisition or acts claimed to be justified by executive necessity;
       5. fire, explosion or accidental damage;
       6. collapse of building structures or failure of plant machinery, computers or vehicles;
       7. interruption, disruption or failure of utility service, including but not limited to electric power, internet, gas or water; or
       8. any labour disputes, including but not limited to strikes, industrial action or lockouts.
    3. For the avoidance of doubt, we shall not be in breach of this Agreement, nor liable for any failure or delay in the performance of any other obligations under this Agreement arising from or attributable to any of the circumstances giving rise to a right to termination under paragraph 16.1 of this Schedule.
    4. Termination by notice from us. We may at any time and without liability to you terminate this Agreement including our Services. In such cases, we will endeavor to provide you with not less than 14 calendar days’ written notice. However, in certain cases, we may terminate your Account, the Services or this Agreement by providing shorter notice or providing notice with immediate effect. No such termination will affect any Instruction given by you which is properly received by us before the date of such notice.
    5. Termination by notice from you. You may terminate this Agreement or your Account with us at any time by providing us with notice in the manner as we may specify on the Platform. However, no such termination will affect any Instruction given by you which is properly received by us before the receipt of such notice or any action we may take in relation to your Account before the receipt of such notice.
    6. Effect of termination. On termination of the Account or any Services or this Agreement or relationship between you and us:
       1. you will stop using any Services;
       2. all charges, costs and/or expenses due to us or any third parties under this Agreement shall fall due for repayment immediately; and
       3. we may discharge our entire liability with respect to your Account by selling your Assets at your expense and arranging for any credit balance in your Account be transferred to you at the earliest time possible and within fifteen (15) Business Days from the termination of this Agreement, subject to Applicable Laws and unforeseen processing delays by the banks.
17. Indemnity and exclusion of liability
    1. You agree to indemnify on a full indemnity basis, to compensate us, and to hold us and all of our employees, officers, Affiliates or counter-party employed or used by us in connection with the Services (collectively, our “Associates”) harmless from and against any and all Losses, and reimburse on demand, against all Losses which we or our Associates may suffer or incur arising from or in connection with the operation of the Account, Transactions, Services, or any Instructions, whether incurred directly or indirectly (unless they arise solely from our fraud, gross negligence or wilful default).
    2. We and our Associates shall not be responsible for or liable to you for any Loss which may be suffered or incurred by you in any way in relation to any Services provided pursuant to the terms of this Agreement, or Transaction contemplated under these terms, howsoever caused, except for any such Loss which is due to our fraud, gross misconduct or wilful default. In such event, our liability in connection with any Transaction or Service, shall not exceed the market value of such Transaction or Service at the time of the fraud, gross negligence or wilful default and shall not include any direct, indirect, incidental, special and consequential or punitive damages (including losses arising from counterparty risk, investment losses, economic losses or lost profits).
18. Notices
    1. All notices, demands or other communications required or permitted to be given under this Agreement (“Notices”) shall be sent as follows:
       1. in the case of a Notice to you, to the electronic mail address indicated by you at account opening or edited subsequently through the “Change of Email procedure” available on the Platform or by posting a Notice on the Platform; and
       2. in the case of a Notice to us, by email to support@endowus.com
    2. You are deemed to receive the Notice sent by us upon the earlier of:
       1. receipt of the Notice by you on the Platform;
       2. receipt of the Notice by you through your electronic mail address; or
       3. expiration of the calendar month following the posting of the Notice on the Platform or to your electronic mail address.
    3. We are deemed to receive the Notice sent by you on the date upon which it is sent, unless it is sent after 5.00 pm on a Business Day or at any time on a non-Business Day in which case it will be deemed to have been received on the next following Business Day.
    4. You must promptly inform us in writing of any change in your mailing address, fax number and/or email address for communication or any of your relevant particulars available in our records and send us all supporting documents we require. We will need a reasonable time period, not being less than seven (7) Business Days from receipt, to act and effect the change in our records, after which, we may rely on the change.
    5. Applicability of this paragraph. Paragraph 18 of this Schedule relates only to Notices in respect of matters concerning the Platform or Services.
19. Complaints handling and dispute resolution
    1. Any complaint regarding how we handle your personal data may be referred our data protection officer who can be contacted at dataprotection@endowus.com. Any other complaint, dispute or controversy raised by you should in the first instance be referred, in writing to Customer Support at support@endowus.com. We will investigate the complaint and report back to you on the findings and the resolution to the complaint or dispute. If you remain dissatisfied with our findings or the handling of your complaint, dispute or controversy, you may, if appropriate, refer the matter to the Financial Industry Disputes Resolution Centre Ltd (“FIDReC”) at 36 Robinson Road, #15-01, Singapore 068877 or the courts of Singapore. As a financial adviser regulated by MAS, we subscribe to FIDReC. Further information about FIDReC may be obtained from its online website at www.fidrec.com.sg.
    2. Subject to the above paragraph 19.1, any dispute arising out of or in connection with this Agreement and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the courts of Singapore.
20. Miscellaneous
    1. Further Assurance. You shall execute such other documents, do such acts and things and take such further actions as may be reasonably required or desirable to give full effect to the provisions of this Agreement and the transactions hereunder and you shall use your best endeavors to procure that any necessary third party shall execute such documents, do such acts and things and take such further actions as may be reasonably required for giving full effect to the provisions of this Agreement and the transactions hereunder.
    2. Assignment. You shall not have the right to assign any of such rights, undertakings, agreements, duties, liabilities and/ or obligations hereunder, except with our written consent. We may assign or transfer any of our rights hereunder to any party without your consent, but subject to prior notification. For the avoidance of doubt, Endowus shall be permitted to consolidate or amalgamate with, or merge with or into, any other financial institution and any reference in this Agreement to Endowus shall be construed as a reference to the successor entity resulting from such consolidation, amalgamation or merger. Your obligations in respect of any account will not be affected by any takeover, absorption or merger by or of Endowus by, of or with any other financial institution, nor will it be in any way affected by any change in the name or constitution of Endowus or any successor, assignee or transferee.
    3. Amendments and Variation. We shall be entitled to, by posting an updated version of this Agreement at www.endowus.com/legal/terms-and-conditions, to supplement, vary and/or modify the terms of this Agreement at any time and such supplement, variation and/or modification shall take effect from the date the Agreement is posted at www.endowus.com/legal/terms-and-conditions or any other date specified by us. An amendment or supplement made to reflect a change of Applicable Laws may take effect immediately or otherwise as we may specify. You agree that it shall be your responsibility to review this Agreement regularly. If you do not accept any such supplement, variation and/or modification, you shall immediately discontinue operating the Account and/or utilizing the Services provided by us and promptly close your Account and terminate this Agreement. If you continue to operate the Account and/or utilise the Services provided by us after such notice, you are deemed to have agreed to such supplement, deletion, variation and/or modification without reservation.
    4. Entire Agreement. This Agreement and the documents referred to in this Agreement collectively embody the entire terms and conditions agreed upon by you and us as to the subject matter of the same and supersedes and revokes in all respects all other documents, agreements, letters of intent, and undertakings entered into between you and us, whether such be written or oral, with respect to the subject matter hereof. All provisions of this Agreement shall so far as they are capable of being performed or observed continue in full force and effect notwithstanding completion of the matters set out therein except in respect of those matters then already performed and except where expressly stated to the contrary. This Agreement shall be binding on and shall endure for the benefit of each of your and our successors in title or legal personal representatives. 
    5. Survival on Termination. All disclaimers, indemnities and exclusions in this Agreement shall survive the termination of this Agreement.
    6. Severance. If any provision of this Agreement or part thereof is rendered void, illegal or unenforceable by any legislation to which it is subject, it shall be rendered void, illegal or unenforceable to that extent and no further and, for the avoidance of doubt, the rest of this Agreement shall continue in full force and effect and the legality, validity and enforceability of the whole of this Agreement in any other jurisdiction shall not be affected.
    7. No Third Party Rights. Unless stipulated otherwise, a person who is not a party to this Agreement shall have no right under the Contracts (Rights of Third Parties) Act (Cap 53B) of Singapore or under any law, to enforce any provision in this Agreement.
    8. Governing Law. This Agreement shall be governed by, and construed in accordance with, the laws of Singapore.

 



SCHEDULE 3 – RISK DISCLOSURE STATEMENT

 

IMPORTANT - PLEASE READ CAREFULLY

This Risk Disclosure Statement covers risks associated with Transactions that may be carried out through the Platform. The next page covers risks associated with overseas-listed investment products.  

RISKS ASSOCIATED WITH INVESTMENTS AND GENERAL FINANCIAL MARKET RISKS 

You are fully aware of the risk relating to Transactions entered into. In particular, you understand that:

(1) Your Investments are not “capital protected” and therefore, you may lose your capital by entering into the Transactions; and

(2) No Investment can be 100% profitable. As a general guide, you should only invest if you fully understand the Investments and the risks associated with them. 

SUITABILITY OF RECOMMENDATIONS

You agree that any advice provided by us will be based on information from sources believed to be accurate, however no representation or warranty, express or implied is made by us as to the accuracy, completeness or suitability of such advice.

You agree that you are solely responsible for making your own independent investigation and appraisal of any advice, recommendations, view, opinion or information provided by us. You shall fully understand and familiarise yourself with all the terms and conditions of each Investments and the risks involved, and agree that you will only accept our recommended Investment Portfolio Recommendation and Transactions on the basis of your own independent review and determination that the Investment Portfolio Recommendation and/or Investments are suitable and appropriate for you, taking into account your specific objectives, financial situation, investment experience, knowledge and particular needs.

You agree and acknowledge that you have made all necessary enquiries and we have informed you of all material features of and risks involved in respect of the Investments including but not limited to information on:

(a) the nature and objective of the Investments;

(b) the key benefits and risks of the Investments;

(c) details of the providers of the Investments;

(d) your key rights with respect to the Investments;

(e) the intended investment horizon of the Investments;

(f) the ease of converting the Investments to cash;

(g) the expected level of your risk tolerance in respect of the Investments;

(h) the commitment required from you in respect of the Investments;

(i) the pricing of the Investments;

(j) the fees and charges to be borne by you in respect of the Investments;

(k) the frequency of reports to be provided to you in respect of the Investments;

(l) any applicable charges or restrictions on withdrawal, surrender or claim procedures of the Investments;

(m) any applicable warnings, exclusions and disclaimers; and

(n) information in relation to where the prospectus in respect of the Investment (if applicable) may be accessed, or if we consider it appropriate, an abridged version of such prospectus.

ALGORITHMS RISK

We use proprietary algorithms in the portfolio building process including but not limited to portfolio optimization, portfolio rebalancing and portfolio return simulations. Many of the algorithms are based on academic research based primarily on the Nobel Prize-winning Modern Portfolio Theory. The underlying inputs and assumptions are based on external information. We do not guarantee the accuracy or reliability of such information.

You understand the limitations of advice provided by a digital advisor, including the fact that the recommendation may not take into consideration your financial circumstances, existing investment portfolios or the affordability of the investment. We have the right to override the automated algorithm or temporarily halt the digital advisory service in extreme market conditions. 

We also retain the right to make material adjustments to the algorithms in the future as it deems necessary. However, any asset allocation changes to your portfolio will require your prior consent.

FINANCIAL MARKET RISK

Markets tend to move in cycles, with periods of rising prices and periods of declining prices. The market value of portfolio assets may fluctuate and result in economic gains and/or losses.

The Investments transacted in by Endowus may include those listed and transacted on exchanges at market prices. Although it is expected that the market price of such Investments will typically approximate its net asset value, it is possible that there may be periods where the market price may deviate from its net asset value. 

NO TAX, LEGAL OR OTHER ADVICE 

You expressly acknowledge that you have the appetite to assume all economic consequences and risks of the Investments and to the extent necessary, have consulted your own tax, legal and other advisers.

COUNTERPARTY RISK 

You also acknowledge that we may have an interest in the subject of the report or recommendation, and we may be a counterparty to any Investments entered into by you and/or may otherwise benefit from your Investments.

You also acknowledge the losses incurred due to inaccurate or incomplete information of the Investment Product provided by any Affiliates.

COUNTRY RISK 

Where the Investments are listed outside Singapore, such Investments are subject to the laws and regulations of the jurisdiction they are listed and you are aware of the risks involved with investing in such products, including but not limited to differences in regulatory regime and investor protection, differences in legal systems, jurisdiction-specific costs (including tax related costs), exposure to foreign counterparty and correspondent broker risks, and exposure to the political, economic and social developments in the applicable jurisdiction. You acknowledge receipt of the Risk Warning Statement on the next page and understand its contents.

Your payments or receipts under a Transaction will be linked to changes in the particular financial market or markets to which the Transaction is linked, and you will be exposed to price, currency exchange, interest rate or other volatility in that market or markets. You may sustain substantial losses on the Investment if the market conditions move against your positions. It is in your interest to fully understand the impact of market movements, in particular the extent of profit/loss you would be exposed to when there is an upward or downward movement in the relevant rates, and the extent of loss if you have to liquidate a position if market conditions move against you. Your position may be liquidated at a loss, and you will be liable for any resulting deficit in your Account with us.

FOREIGN EXCHANGE RISK

The Assets in your portfolio with us may be denominated in different currencies and may not necessarily be in Singapore Dollar at all times. Portfolio assets are therefore subject to foreign exchange risk. The fluctuations in foreign currency rates have an impact on the profit/loss and the Investment where your portfolio (or any part thereof) or any Transaction is denominated or settled in a different currency from the currency where you carry on your ordinary business or keep your accounts.

 



OVERSEAS-LISTED INVESTMENT PRODUCTS

RISK WARNING An overseas-listed investment product* is subject to the laws and regulations of the jurisdiction it is listed in. Before you trade in an overseas-listed investment product or authorise someone else to trade for you, you should be aware of: The level of investor protection and safeguards that you are afforded in the relevant foreign jurisdiction as the overseas-listed investment product would operate under a different regulatory regime. The differences between the legal systems in the foreign jurisdiction and Singapore that may affect your ability to recover your funds. The tax implications, currency risks, and additional transaction costs that you may have to incur. The counterparty and correspondent broker risks that you are exposed to. The political, economic and social developments that influence the overseas markets you are investing in. These and other risks may affect the value of your investment. You should not invest in the product if you do not understand or are not comfortable with such risks. *An “overseas-listed investment product” in this statement refers to a capital markets product that is listed for quotation or quoted only on overseas securities exchange(s) or overseas futures exchange(s) (collectively referred to as “overseas exchanges”).

 

1. This statement is provided to you in accordance with paragraph 29D of the Notice on the Sale of Investment Products SFA04-N12.
2. This statement does not disclose all the risks and other significant aspects of trading in an overseas-listed investment product. You should undertake such transactions only if you understand and are comfortable with the extent of your exposure to the risks.
3. You should carefully consider whether such trading is suitable for you in light of your experience, objectives, risk appetite, financial resources and other relevant circumstances. In considering whether to trade or to authorise someone else to trade for you, you should be aware of the following:

Differences in Regulatory Regimes

(a) Overseas markets may be subject to different regulations, and may operate differently from approved exchanges in Singapore. For example, there may be different rules providing for the safekeeping of securities and monies held by custodian banks or depositories. This may affect the level of safeguards in place to ensure proper segregation and safekeeping of your investment products or monies held overseas. There is also the risk of your investment products or monies not being protected if the custodian has credit problems or fails. Overseas markets may also have different periods for clearing and settling transactions. These may affect the information available to you regarding transaction prices and the time you have to settle your trade on such overseas markets.

(b) Overseas markets may be subject to rules which may offer different investor protection as compared to Singapore. Before you start to trade, you should be fully aware of the types of redress available to you in Singapore and other relevant jurisdictions, if any.

(c) Overseas-listed investment products may not be subject to the same disclosure standards that apply to investment products listed for quotation or quoted on an approved exchange in Singapore. Where disclosure is made, differences in accounting, auditing and financial reporting standards may also affect the quality and comparability of information provided. It may also be more difficult to locate up-to- date information, and the information published may only be available in a foreign language.

Differences in legal systems

(d) In some countries, legal concepts which are practiced in mature legal systems may not be in place or may have yet to be tested in courts. This would make it more difficult to predict with a degree of certainty the outcome of judicial proceedings or even the quantum of damages which may be awarded following a successful claim.

(e) The Monetary Authority of Singapore will be unable to compel the enforcement of the rules of the regulatory authorities or markets in other jurisdictions where your transactions will be effected.

(f) The laws of some jurisdictions may prohibit or restrict the repatriation of funds from such jurisdictions including capital, divestment proceeds, profits, dividends and interest arising from investment in such countries. Therefore, there is no guarantee that the funds you have invested and the funds arising from your investment will be capable of being remitted.

(g) Some jurisdictions may also restrict the amount or type of investment products that foreign investors may trade. This can affect the liquidity and prices of the overseas-listed investment products that you invest in.

Different costs involved

(h) There may be tax implications of investing in an overseas-listed investment product. For example, sale proceeds or the receipt of any dividends and other income may be subject to tax levies, duties or charges in the foreign country, in Singapore, or in both countries.

(i) Your investment return on foreign currency-denominated investment products will be affected by exchange rate fluctuations where there is a need to convert from the currency of denomination of the investment products to another currency, or may be affected by exchange controls.

(j) You may have to pay additional costs such as fees and broker’s commissions for transactions in overseas exchanges. In some jurisdictions, you may also have to pay a premium to trade certain listed investment products. Therefore, before you begin to trade, you should obtain a clear explanation of all commissions, fees and other charges for which you will be liable. These charges will affect your net profit (if any) or increase your loss.

Counterparty and correspondent broker risks

(k) Transactions on overseas exchanges or overseas markets are generally effected by your Singapore broker through the use of foreign brokers who have trading and/or clearing rights on those exchanges. All transactions that are executed upon your instructions with such counterparties and correspondent brokers are dependent on their respective due performance of their obligations. The insolvency or default of such counterparties and correspondent brokers may lead to positions being liquidated or closed out without your consent and/or may result in difficulties in recovering your monies and assets held overseas.

Political, Economic and Social Developments

(l) Overseas markets are influenced by the political, economic and social developments in the foreign jurisdiction, which may be uncertain and may increase the risk of investing in overseas-listed investment products.



SCHEDULE 4 – PRIVACY POLICY

1. Introduction and application
2. Personal data that we collect
3. Sources of information
4. Purpose of collecting, using and disclosing your personal data
5. Disclosure and sharing of your personal data
6. Transfer of your personal data outside Singapore
7. Retaining your personal data
8. Rights of access and rectification
9. Use of cookies and related technologies
10. Third party sites
11. Complaints
12. Changes
13. Contacting us
    



1. Introduction and application
   1. This policy ("Privacy Policy") describes how Endow.us Pte. Ltd. (Company No. 201708816N) ("Endowus") manages Personal Data which is in our possession or under our control. "Personal Data", is defined in the Personal Data Protection Act (No. 26 of 2012) of Singapore ("PDPA"), and currently refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.
   2. By using our services pursuant to your agreement(s) with us ("Services"), operating any account maintained with us, accessing the online platform operated by us (which is accessible through our website at www.endowus.com or through our mobile application) ("Platform"), websites or mobile applications, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.
   3. Capitalised terms not otherwise defined in this Privacy Policy shall have the meaning as ascribed in the Terms and Conditions, its Schedules and application form(s) submitted by you (including any terms and conditions or disclaimers thereto) (the "Agreement") between you and us. 
   4. The terms in this Privacy Policy shall supplement and add to the terms and conditions as set out in the Agreement. In the event of conflict or inconsistency between any provisions in this Privacy Policy and the Agreement, the terms of this Privacy Policy shall prevail in respect of the matters contained herein to the extent of such conflict and inconsistency. Save for the foregoing, this Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have to collect, use, process or disclose your Personal Data.  
   5. The words "we", "us", "our" or any of their derivatives refer to Endowus and its successors and any novatee, assignee, transferee or purchaser of Endowus' rights and/or obligations hereunder and any reference to Endowus includes a reference to such successor, novatee, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
   6. This Privacy Policy shall be governed by, and construed in accordance with, the laws of Singapore. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the courts of Singapore.
2. Personal data that we collect
   1. We collect, use, disclose, transfer and otherwise process Personal Data about you or individuals who are connected or associated with you including but not limited to your legal representatives ("Associated Persons") in accordance with this Privacy Policy.
   2. The Personal Data that we collect or may collect include:
      1. personal contact data including name, telephone number, email address, residential address and correspondence address;
      2. specimen signature(s);
      3. occupation, education, employment status and income levels, including whether you have any professional qualifications relating to finance;
      4. identification card or passport number, nationality, date of birth, place of birth and other information for the verification of identity;
      5. financial and banking information (e.g. information on source and amount of regular income, your financial situation, net assets, income, expenses, cash flow, financial commitments, credit history, bank account and banking transactions);
      6. images, voice recordings of our conversations with you and/or your biometric information;
      7. tax and insurance information;
      8. information about your financial or investment objectives, risk profile and risk tolerance, investments, investment objectives, knowledge and experience and/or business interests and assets, including current investment portfolio, including any life policies, your current securities trading account, whether the amount to be invested with is a substantial portion of your assets and prior investment experience in relation to specific investment products;
      9. personal opinions made known to us (e.g. your feedback or responses to any surveys);
      10. browsing history, patterns or other unique information;
      11. your internet protocol address and information associated with such address;
      12. any other personal data reasonably required in order for us to provide the Services requested by you; and
      13. any other personal data permitted by or required to comply with any applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time ("Applicable Laws") and our internal control and compliance policies.
3. Sources of information
   1. The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
      1. information provided or submitted by you through among others, your dealings and agreements with us, which includes information provided when registering as a user, providing information regarding any account which you may open with us, providing answers to security questions, completing any confirmations, declarations or forms, or through your utilization of any of our Services, accessing or viewing our Platform;
      2. as applicable, publicly available or publicly accessible information; and
      3. such other written, electronic or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.
   2. As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the below purposes or as required or permitted by any Applicable Laws.
4. Purpose of collecting, using and disclosing your personal data
   1. We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes, the following purposes ("Purposes"):
      1. provision of the Services as requested by you, including instructing any Intermediaries and/or third party services providers in order to provide the Services to you;
      2. carrying out any transactions on your behalf contemplated on the Platform and the Services thereto; 
      3. assessing and processing applications, instructions or requests from you;
      4. communicating with you, including providing you with updates on changes to our Services;
      5. to verify your identity for the purposes of providing the Services to you;
      6. conducting due diligence checks, screenings or credit checks as may be required by any Applicable Laws or our internal policies and procedures;
      7. for the specific purpose for which it was volunteered or provided to us;
      8. to detect and protect us or any third parties against negligence, fraud, theft and other illegal activities;
      9. to understand your needs and preferences;
      10. improving the content, appearance and utility of the Platform;
      11. to manage and develop infrastructure and business operations;
      12. to administer any account which you may open with us;
      13. to process payments;
      14. to comply with our internal policies and procedures;
      15. to respond to queries or feedback;
      16. to address or investigate any complaints, claims or disputes;
      17. as permitted by any Applicable Laws;
      18. to comply with any Applicable Laws or any request from any relevant governmental or regulatory authority;
      19. financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
      20. enforcing obligations owed to us;
      21. seeking professional advice, including legal advice;
      22. any other reasonable purposes in connection with the provision of our Services;
      23. with your consent, providing you with marketing materials in connection with the Services we may provide;
      24. fulfilling any purpose directly related to the above Purposes; 
      25. any other purposes that are appropriate or authorized by any Applicable Laws; or
      26. any other purposes that are specified in the data service agreement between us and service provider.
   2. You shall acquire consent from Associated Persons before providing their Personal Data to us. Where you have provided Personal Data to us relating to any other individual, unless you have specifically instructed us otherwise, we shall assume that you have obtained the relevant consent in order to do so.
   3. You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please contact our data protection officer at dataprotection@endowus.com.
5. Disclosure and sharing of your personal data
   1. Without prejudice to any other provisions in any agreements between us, we may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties including Intermediaries, whether located in Singapore or otherwise, to carry out the Purposes. This includes, disclosing and sharing your Personal Data with the following:
      1. any of our directors, officers, employees, representatives, agents or delegates;
      2. any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates;
      3. our professional advisers, consultants and auditors;
      4. any Intermediaries, service providers, agents, contractors, delegates, suppliers or third parties which we may appoint from time to time to provide us with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
      5. any sub-contractors which any of our Intermediaries, service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
      6. anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you or anyone any agreement we have with you (or any part thereof) is transferred to or may be transferred to;
      7. any person who we believe in good faith to be your legal advisers or other professionals;
      8. any relevant governmental or regulatory authority, in so far as we need to do so to keep to any Applicable Laws, or which we in good faith believe that we should keep to; 
      9. pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under a court order or otherwise);
      10. parties which assist us in carrying out the Purposes laid out above in this Privacy Policy; and
      11. any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any Applicable Laws, provided that in the case of disclosures under any of the circumstances in (5.1.1) to (5.1.4), we shall procure that the recipient is subject to the same duty of confidence.
6. Transfer of your personal data outside Singapore
   1. We may transfer, store, process and/or deal with your Personal Data outside Singapore. When doing so we will take appropriate steps to ensure that the transferred Personal Data is provided with a standard of protection that is at least comparable to the protection under the PDPA. 
7. Retaining your personal data
   1. Your Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other business purposes or to comply with any Applicable Laws.
8. Rights of access and rectification
   1. However, you may also request access to your Personal Data we hold, or request the rectification of any inaccurate Personal Data. If you would like to do so, please contact our data protection officer at dataprotection@endowus.com. 
9. Use of cookies and related technologies
   1. Our Platform, websites and mobile applications ("apps" or an "app") use cookies. A cookie is a small text file placed on your computer, system or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or Services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our apps.
   2. A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behavior of users visiting the website.
   3. You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites or the Platform.
   4. We also use analytics programs similar to Google Analytics for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Certain features may be used and as a result, your information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience.
   5. We and our third-party vendors may use first-party cookies or other first-party identifiers, and third-party cookies or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support or endorse the goals, causes or statements of these websites or mobile applications which display our ads.
   6. Where applicable, using the Google Ad Settings (https://www.google.com/settings/u/0/ads/authenticated), you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences. 
10. Third party sites
    1. Our web sites may contain links to other websites which are not maintained by us. This Privacy Policy only applies to our websites, mobile applications (as applicable), the Platform and/or our Services. When visiting these third party websites, you should read their privacy policies which will apply to your use of the web sites.
11. Complaints
    1. We have established the complaint mechanism. If you think any collection, use, process or disclosure of your Personal Data violates this Privacy Policy or any Applicable Laws, please report to our data protection officer at dataprotection@endowus.com and we will process your complaint and respond to you.
12. Changes
    1. Our Privacy Policy may change from time to time. We will post any Privacy Policy changes on this page, for which you will be notified. If you continue to use our Services, operate any account maintained with us, access our Platform, websites or mobile applications (as applicable), and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such changes without reservation.
13. Contacting us
    1. If you have any questions about any aspects of this Privacy Policy or your Personal Data, please contact our data protection officer at dataprotection@endowus.com. 

DISCLOSURES

Our portfolios are built on collective investment scheme products managed by a number of fund managers. Summarised details of the funds currently included in our recommended portfolios may be found in the Frequently Asked Questions section of our website at https://endowus.com/support. Links to the fund prospectuses and key investor information documents are provided on our platform.

Unit investments in collective investment scheme products are typically held on behalf of you under a nominee company’s name and your rights may only be enforced through the nominee company.