This Privacy Policy describes how LC Adroit Vantage Pte. Ltd. ("Keenai", "we", "us") collects, uses, discloses, and safeguards your personal data when you use the Keenai platform, websites, and mobile applications. It applies to prospective and existing users, visitors to our websites, and authorised representatives of corporate clients.
This policy is issued in accordance with the Singapore Personal Data Protection Act 2012 ("PDPA") and is supplemented by privacy notices published by our licensed partners, including Lighthouse Canton Pte Ltd ("LCPL") and BNY Pershing, which govern personal data processed under regulated service relationships.
Identity and personal data
Full legal name, date of birth, nationality, residency
Government-issued identity documents (passport, national ID)
Residential and correspondence addresses
Email addresses, phone numbers
Photograph or video image (where required for KYC identity verification)
Financial and eligibility data
Accredited Investor declarations and supporting evidence (pay slips, bank statements, holdings statements, valuation certificates)
Source of wealth, source of funds, employment status, occupation
Tax residency, tax identification numbers, FATCA/CRS declarations, Form W-8BEN
Bank account details including account number, sort code, and IBAN
Details of debit or credit cards registered with us (card number, expiry date, CVC)
Income and financial obligations where relevant to product eligibility
Platform usage data
Device identifiers, IP address, browser type, operating system
Access logs, session timestamps, feature usage, click and scroll telemetry
Account activity: logins, fund transfers, subscription, redemption, trading activity
Page response times, download errors, length of visits, and browsing methods
Mobile network information, mobile operating system, and mobile browser type
Location data
If you enable location services in the Keenai app, we collect GPS location data to provide location-relevant services and protect against fraud
Communications
Messages and attachments sent via the in-app messenger
Call recordings (where legally permitted and disclosed at point of call)
Email correspondence with client services, investment team, and compliance
Data from third parties
Credit reference agencies, financial institutions, official registers, and databases
Fraud prevention agencies and onboarding verification partners
Publicly available sources including media, online registers, and directories (for enhanced due diligence and KYC purposes)
Social media platforms where publicly available information is used for sanctions screening or anti-money laundering obligations
We process your personal data on the following legal bases under the PDPA: contractual necessity, legal obligation, legitimate interests, substantial public interest, and consent.
Providing our services
Verifying your identity and Accredited Investor status (KYC/AML/CFT obligations)
Deciding whether to approve your application for products or services
Facilitating introductions to licensed partners including LCPL and BNY Pershing
Providing platform features: portfolio aggregation, performance reporting, document vault
Processing account funding instructions, trade confirmations, and corporate actions
Maintaining audit trails, regulatory recordkeeping, and compliance monitoring
Providing client service, responding to queries, resolving complaints
Recovering debt and exercising other rights under any agreement with you
Security and fraud prevention
Preventing fraud, money laundering, financing of terrorism, and market abuse
Conducting enhanced due diligence and sanctions screening
Protecting the security of accounts and platform infrastructure
Marketing and personalisation
Personalising your in-app experience and marketing messages about our products and services
Providing information about partners' promotions or offers where you have agreed to receive these
Measuring the effectiveness of our marketing and advertising campaigns
Providing relevant advertising to you based on your use of the platform (where you have consented)
Sharing data with advertising partners and social media platforms to deliver relevant ads (where you have consented)
Platform operations
Troubleshooting, data analysis, testing, research, and statistical purposes
Ensuring content is presented effectively for your device
Improving the platform via aggregate, non-identifying analytics
Keeping our website and app safe and secure
Legal and regulatory compliance
Complying with legal, tax, regulatory, and court-order obligations
Reporting to and cooperating with the Monetary Authority of Singapore, PDPC, and other regulatory or law enforcement bodies when legally required
We may use technology to evaluate your personal circumstances and other factors to predict risks or outcomes. This is used for the efficient running of our services and to ensure decisions are fair, consistent, and based on accurate information. Where we make an automated decision that significantly affects you, you have the right to request that it is manually reviewed by a person. Contact us at privacy@keenaiglobal.com to exercise this right.
We share your personal data with licensed partners and service providers strictly on a need-to-know basis, under binding confidentiality and data-protection terms.
Partner / provider type | Purpose |
|---|---|
Lighthouse Canton Pte. Ltd. (LCPL) | Regulated investment advisory, suitability assessment, and portfolio management services |
BNY Pershing (subsidiary of BNY Mellon) | Brokerage, custody, and settlement |
KYC, identity verification, and sanctions-screening providers | Onboarding verification and ongoing compliance monitoring |
Cloud infrastructure, hosting, and security providers | ISO 27017/27018-certified environments for data hosting and platform operations |
IT, payment, and delivery service providers | Supporting the running of our services and processing transactions |
Banking and financial services analytics partners | Credit referencing, lending assessment, and international payment processing |
Customer analytics providers and web developers | To help us improve our website and app and understand platform usage |
Customer satisfaction and survey providers | To help us understand how we are performing and improve our services |
Communications service providers | Delivering push notifications and in-app messages |
Advertising partners and social media platforms | Delivering relevant advertising and measuring campaign effectiveness (where you have consented to targeting) |
Credit reference agencies | Managing fraud and credit risk |
Professional advisors (auditors, legal counsel, tax advisors) | Under privilege and confidentiality obligations |
Regulators, courts, tax authorities, and law enforcement | When legally compelled |
We do not sell your personal data.
Keenai operates out of Singapore, and your personal data is collected, stored, and processed within Singapore. We do not transfer your personal data outside Singapore. We will ensure any recipient provides a standard of protection at least comparable to the PDPA, through contractual safeguards, data-transfer agreements, or reliance on the recipient's own adequate legal regime, and we'll update this policy accordingly.
You have the following rights in respect of the personal data we hold about you:
Right | What it means |
|---|---|
Access | Request a copy of the personal data we hold about you |
Correction | Ask us to correct inaccurate or incomplete personal data |
Withdrawal of consent | Withdraw consent previously given for processing. Note: withdrawal may affect our ability to continue providing services |
Data portability | Where technically feasible, receive your data in a machine-readable format |
Opt out of marketing | Ask us to stop sending you marketing communications at any time via the app notification settings or by contacting us |
Automated decision review | Request that any automated decision significantly affecting you is reviewed by a person |
Account deletion | Request deletion of your Keenai account and associated personal data (subject to legal retention obligations) |
Lodge a complaint | Complain directly to us, or to the Personal Data Protection Commission (PDPC) of Singapore at pdpc.gov.sg |
Requests should be addressed to our Data Protection Officer at privacy@keenaiglobal.com. We respond to verified requests within 30 days.
You may request deletion of your Keenai account and associated personal data by contacting privacy@keenaiglobal.com or through the account settings in the Keenai app. We will action verified deletion requests within 30 days, subject to our legal obligations to retain certain records under Singapore law, LCPL's regulated obligations, and anti-money laundering requirements (minimum five years from the end of the client relationship). Data required for legal compliance will be retained for the mandatory period before deletion.
If you sign up to our services and where national laws allow, we may contact you by post, push notification, email, and in-app message with information about our products and services. We will always make it clear how to stop receiving these communications.
We use your personal data in personalised marketing messages about our products and services so they are more relevant and interesting to you. This may include analysing how you use our products, services, and your transactions.
We may use your data for direct marketing purposes, including profiling, to make our marketing more relevant. You can object to this at any time using the in-app preferences or by contacting us directly.
If you do not want to receive personalised marketing communications, you can opt out through the in-app settings at any time.
We will not pass your details to any organisation outside the LCPL group for their marketing purposes without your explicit consent.
We may update this Privacy Policy from time to time. Material changes will be notified through the platform and by email to registered users at least 14 days before taking effect. The date at the top of this document reflects the most recent revision. We will also update this policy whenever we add new SDKs, change data collection practices, or in response to changes in applicable law or app store requirements.
For any questions, requests, or concerns about this policy or how we handle your personal data, please contact us.
