Privacy

“You” - Customer

“We”, “Our” and “Us” - abrdn Korea Co. Limited

“Customers” - clients, business partners and all parties who have dealings with us

“Personal Information” - same meaning as "personal information" prescribed in the Korea’s Personal Information Protection Act (“PIPA”) which means information relating to a living individual that constitutes any of the following:

(a) Information that identifies a particular individual by his/her full name, resident registration number, image, etc.;

(b) Information which, even if by itself does not identify a particular individual, may be easily combined with other information to identify a particular individual (in this case, whether or not there is ease of combination shall be determined by reasonably considering the time, cost, technology, etc. used to identify the individual such as likelihood that the other information can be procured); and

(c) Information under items (a) or (b) above that is pseudonymised in accordance with the relevant provisions and thereby becomes incapable of identifying a particular individual without the use or combination of information for restoration to the original state (referred to as “pseudonymised information”).

“Sensitive Personal Information” - same meaning as "sensitive information" prescribed in the Korea’s Personal Information Protection Act (“PIPA”) which is defined as personal information concerning an individual’s ideology, faith, labor union membership, political views or membership in a political party, health or medical treatment information, sexual orientation, genetic information, criminal records and biometric data for the purpose of uniquely identifying a natural person and race/ethnic information. Sensitive information can be processed if (a) such processing is required or permitted by a statute, or (b) the consent of the data subject is separately obtained.

General

We (abrdn Korea Co. Limited) take privacy seriously and we will only ever collect and use personal information where it is necessary and lawful to do so. We do not actively collect or use any personal information under the current scope of our business.

This Privacy Notice applies to abrdn Korea Co. Limited and contains important information about what personal information we collect; what we do with that information; who we may share it with and why; and your choices and rights when it comes to the personal information you have given us.

We may need to make changes to our Privacy Notice; so please check our website for updates from time to time. If there are important changes to how we handle any personal information; we may contact you to let you know.

If there is any inconsistency between the English version of our Privacy Policy and the Korean translation, the English version will take precedence.

abrdn Korea Co. Limited is a subsidiary of Aberdeen Group plc; a global business providing a range of savings and investments products and solutions to meet customer and client needs.

Personal information we collect and use

We may collect and use personal information including:

• Information about who you are for identification and security purposes e.g. full name, date of birth, gender, marital status, country of birth, nationality, passport number, expiry date and place of issuance, occupation and employment details including job title, salary and employer’s address.
• Information allowing us to contact you e.g. residential address, telephone number, email address.
• Information connected with your product or service with us e.g. bank account.
• Information that is automatically connected e.g. website cookies.
• Information on persons connected to you, where required to provide the agreed product or service e.g. name, date of birth, nationality, resident registration number of your spouse or beneficial owner.

If you have a distributor / broker / agent, the information we collect and use will most likely have been provided by them on your behalf.

We do not collect or process resident registration numbers.

Why we collect and use your personal information

We take your privacy seriously and we will only ever collect the minimum personal information necessary. These include:

• Where it’s necessary to provide the product or service you have requested e.g. if you wish to invest in one of our funds or products we will require some personal information which may include your name, address, date of birth, and bank account details;
• Where it’s necessary for us to meet our legal or regulatory obligations e.g. to send you Annual Statements, inform you on changes to Terms and Conditions or for the detection and prevention of fraud;
• For our legitimate interests where such interest does not override yours as the data subject e.g. to develop new products and services for our customers; and
• For the performance of a task we require to carry out in the public interest.

You have given us your consent to use your personal information. You are deemed to have provided your consent if you voluntarily provide your personal data to us for an agreed purpose and it’s reasonable to require you to provide such data. Deemed consent also applies when your personal data is disclosed by us to another party in order to fulfil our contractual obligations, or when we have notified you about the collection, use and disclosure of your data and you did not take any action to withdraw your consent.

Subject to the above, we may use your personal information for the following purposes:

• Account opening including information verification and credit checks
• Order Handling
• Unit Allocation
• Regulatory and Compliance Reporting
• Service Request (Amendment, Online trading, Withdraw, Redemption, Closure and Tax Certificate)
• Dividends confirmation
• Marketing and Research including analysis and promotion
• Call Handling (Incoming and outgoing)

You will be required to provide the personal information as required to be processed by or on behalf of us, as described above. If you do not agree to provide such personal information to us in accordance with this Notice, we may not be able to provide you with the product(s) or service(s) requested or comply with any of our contractual obligations owing to Customers.

We will inform you should there be changes to:

• The purpose of collection and use of personal information;
• Particulars of personal information to be collected;
• The fact that you are entitled to deny consent, and disadvantages, if any, resulting from the denial of consent.

You may deny consent at any time by giving reasonable notice via the contact details included under “How to contact us”.

Safeguard of Personal Information

We take personal information and security very seriously and we strive to comply with our obligations at all times. Any personal information which is collected and used by us in any way will have appropriate measures in place to properly manage and protect your personal information. We have implemented the following measures:

• Established an organizational culture to promote and ensure protection of all personal information held by us;
• Designated privacy officers to oversee the proper handling of your personal information;
• Established internal company rules based on Personal Information Protection Laws and guidelines issued by the relevant authority to ensure proper handling of personal information;
• Educated our employees to ensure that they understand the importance of personal information protection and are thoroughly familiar with all relevant rules and guidelines;
• Established a personal information management register and enforcement of appropriate restrictions on access to personal information;
• Implemented appropriate and reasonable security measures [including a secure storage method with restricted access controls] to prevent unauthorized access to, or leakage, destruction or alteration of, personal information. Our security controls are aligned to industry standards and good practice; providing an appropriate control environment that manages risks to the confidentiality, integrity and availability of your personal information.

Disclosure of Personal Information to Third Parties

We may share your personal information with third parties we work with for the purposes outlined in ‘Why we collect and use your information’.

We will only disclose your Personal Information to such third parties where it is lawful to do so and in line with our obligations under data protection laws.

We will share your information with:

• Other parts [subsidiaries, holding companies, related corporations or associates of ours whether present or future] of Aberdeen Group plc who support us in the provision of the product or service you have;
• Companies and partners we have carefully chosen to support us, both inside and outside of Korea;
• Credit reference agencies for the purposes of conducting a credit check and ID verification;
• Your distributor / broker / agent where this is required as part of the product or service you have agreed with us;
• Our regulators including the Financial Services Commission (FSC) and Personal Information Protection Commission.
• Appointed agencies [government agencies, public agencies, agencies] responsible for supervising the provision of services
• Law enforcement agencies e.g. for the prevention and detection of crime, pursuit of legal proceedings
• Other third parties where required to support an organization restructure, amalgamation, merger or sale

By disclosing your personal information to such third parties we shall ensure that those persons treat your Personal Information as confidential and shall not use such information for any purposes other than within the scope specified by us.

We will only instruct a third party to process your personal information on our behalf where we have obtained the necessary assurance that they will properly manage and protect your information to the required standards under applicable laws. Moreover, before we provide and disclose your personal information to such service providers we require, by way of a written contract or similar means, assurance that they will process this data strictly in compliance with our instructions and agreed terms of use including appropriate measures to properly handle personal information. We periodically verify their ongoing compliance with these obligations.

Your rights under law

You have a number of rights under data protection laws which may be exercised in certain circumstances. These are:

• Right of Access to Personal Information. You may request access to your own personal information. However, we may postpone access should there be good cause for not permitting access during a prescribed period. You will be permitted access without delay once the said ground ceases to exist.
• Right to Request for Transmission of Personal Information. You may request for us to transmit your personal information to institutions specialising in managing personal information, or a person who fulfils their duty of safeguards and meets the standards for facilities and technology.
• Right to Correction and Erasure of Personal Information. You may request a correction or erasure of your personal information. However, erasure may not be permitted where the said personal information shall be collected by other statutes or regulations. We will not take measures to recover the personal information in event of erasure.
• Right to Suspend Processing of Personal Information. You may request to suspend the processing of your personal information or withdraw your consent to personal information processing. However, we may deny the request for the following scenarios:
• Where special provisions exist in other statutes, or it is unavoidable to observe obligations under statutes or regulations;
• Where access may cause damage to life, or unjustified infringement of property and other interests of any other person;
• Where it is impracticable to perform a contract such as the provision of services as agreed upon.

If you wish to exercise any of your rights under law, please notify us using our contact details below.

How to make a complaint

We will always strive to collect, use and safeguard your personal information in line with data protection laws. If you do not believe we have handled your information as set out in this Privacy Notice, please let us know immediately and we will do our utmost to make things right.

While we hope that we can resolve any complaints for you, you do have the option complain to your local data protection authority e.g. Personal Information Protection Commission (“PIPC”). This is available to you whether or not you have exhausted our complaints procedure. 

You can contact the Personal Information Protection Commission at the following address:

Personal Information Protection Commission
4th floor, Government Complex Seoul
(03171) 209, Sejong-daero, Jongno-gu,
Seoul, Korea Rep