Privacy Policy

1. Who We Are

1.1 NORFH PTE LTD (UEN: 202616626E), operating the Five Cents brand, is the organisation responsible for the personal data collected through Free Will + LPA.

1.2 Our Data Protection Officer is See Seng Yang. You can reach him at hello@norfh.com for any question about this policy or your personal data.

2. What We Collect

2.1 When you sign up, we collect:

• Your full name;
• Your email address and mobile number;
• Your age and residency status;
• Your employment status and occupation;
• Your Will history, recent life events, insurance and property ownership answers, main reason for a Will, and gift choice; and
• Your consent selections.

2.2 We also record technical information such as your IP address and the time of submission for security and record keeping.

3. How We Use It

Five Cents and NORFH PTE LTD are not licensed financial advisers and do not provide financial advice. We are not responsible for any advice, recommendation, product or service provided by the one Adviser assigned to you (a licensed financial adviser representative listed in the T&Cs) and the financial adviser firm they represent.

3.1 We use your data to administer the Campaign and deliver gifts. A licensed financial adviser representative contacts you by phone call, SMS, WhatsApp or email to arrange and conduct your Consultation and prepare your Will and LPA. Five Cents (NORFH PTE LTD) contacts you by email or mobile phone to administer your consultation and deliver your gift.

3.2 If you opt in to the newsletter, we will also send you occasional Five Cents content. You can unsubscribe at any time.

3.3 We do not sell your personal data.

4. Who We Share It With

4.1 Your details are shared with the one Adviser assigned to you (a licensed financial adviser representative listed in the T&Cs) and the financial adviser firm they represent for the purpose of arranging and conducting your Consultation and preparing your Will and LPA. Your details will not be passed to another adviser without your fresh consent.

4.2 We also use service providers for hosting, storage, and communications. They may process your data only on our instructions.

This page uses the Meta (Facebook and Instagram) pixel and Conversions API to measure page visits and successful registrations for our advertising. When you register, we share a Lead event with hashed email, phone and name, together with technical data such as your IP address, browser type and cookie identifiers. No Will history, life events, insurance, property, reason or gift answers are shared with Meta.

The Campaign page uses cookies and similar technologies. Essential cookies are needed for the page to work. You can make a choice through our cookie banner and manage cookies through your browser settings.

4.3 We may disclose data where required by law or regulation.

5. Retention and Security

5.1 We keep the personal data collected through this Campaign, including your contact details and the record of your consent, for 12 months from the date you submit the form. After that, it is securely deleted. If you withdraw your consent earlier, we delete your data sooner, unless the law requires us to keep it. Once your details are passed to the one Adviser assigned to you (a licensed financial adviser representative listed in the T&Cs) and the financial adviser firm they represent, that firm keeps the personal data it needs as a separate organisation, under its own policies and retention obligations.

5.2 We apply reasonable technical and organisational measures to protect your data against loss, misuse, and unauthorised access.

6. Data breaches

If we become aware of a data breach involving your personal data, we will assess it promptly. Where the breach is notifiable under the PDPA, we will notify the Personal Data Protection Commission and, where required, you.

7. Your Rights

7.1 You may request access to, or correction of, the personal data we hold about you.

7.2 You may withdraw consent to further contact at any time by writing to hello@norfh.com. Withdrawing consent may mean we can no longer arrange your Consultation or deliver a gift.

7.3 We will respond within 30 days. If we need more time, we will tell you when we expect to respond. This policy is governed by the Personal Data Protection Act 2012 of Singapore.