Unless the context otherwise requires, words in the singular shall include the plural version and in the plural shall include the singular version.
Any words following the terms “including”, “include”, “in particular”, “for example”, or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase, or term preceding those terms.
4. COLLECTION OF PERSONAL DATA
We may collect your personal data when you create an account with us or otherwise provide us with your personal data to us through your access to and use of the Website, the Application and the Services. Personal data that we may collect includes but is not limited to:
(i) your personal particulars such as your name, date of birth, telephone numbers, home and email address and any other contact information;
(ii) your financial information such as your bank account, credit card details, expenses, bank details and any other billing information;
(iii) blockchain information such as your blockchain address and public keys;
(iv) any other form of personal data relevant to the Website, the Application and the Services including the username and password of the account created by you.
We may at other times acquire personal data from other sources such as offline records, publicly available information, or from third parties, in order to provide you with the Services.
You must only submit to us information which is accurate and not misleading. We reserve the right to request for further documentation in order to verify information provided by you.
5. COLLECTION OF COMPUTER DATA
When you access the Website and the Application, we will automatically collect your computer data, which may include browser type, IP address, language, operating system, location of your device, the state or country from which you accessed the Website and the Application, the pages you view, length of time spent on pages, communications with other users through the Website if applicable, the Services you use and the manner in which you use such Services (e.g., the content you access, view, click on, search for, post, follow, share, upload, or tag), the date and time of your visit, the websites you visited immediately before and after visiting the Website and the Application, error logs, and other hardware and software information, as well as other geographic and demographic information.
To the extent that such information is maintained in a manner that identifies your name or contact information, it will be treated as personal data; otherwise, such information will be treated as non-personal data.
We may work with advertising partners who help us to make our website more interesting for you. For this purpose, cookies from partner companies are also stored on your hard disk (third-party cookies) when you visit our website. If we work with the aforementioned advertising partners, you will be informed individually and separately about the use of such cookies and the extent of the information collected in each case within the following paragraphs.
Most web browsers automatically accept cookies, but you may set your browser to block cookies (consult the instructions for your particular browser on how to do this). Please note that if you decide to block cookies, this may interfere with your ability to use certain functionalities of the Website, the Application and/or the Services.
Please note that you can set your browser in such a way that you are informed about the setting of cookies and can decide individually about their acceptance or exclude the acceptance of cookies for certain cases or generally. Each browser differs in the way it manages the cookie settings. This is described in the help menu of each browser, which explains how you can change your cookie settings. You will find these for the respective browsers under the following links:
Internet Explorer: http://windows.microsoft.com/en-EN/windows-vista/Block-or-allow-cookies
Please note that the functionality of our website may be limited if cookies are not accepted.
6. USE OF PERSONAL DATA
Through the use of the Website, the Application and the Services or when you submit personal data to us, we may use your personal data to operate, maintain, develop and provide to you the features and functionality of our facilities, products or Services. The purpose for which we collect your personal data includes but not limited to:
(i) identifying, analysing and evaluating the areas in which the Website, the Application and the Services can be improved;
(ii) improving your access and use of the Website, the Application and the Services;
(iii) offering you updates and information relating to our products or Services; responding to any queries or requests you may have;
(iv) verifying your identity for the purposes of providing our products or Services;
(v) conducting due diligence checks in accordance with legal and regulatory obligations in Singapore; and/or
(vi) resolving any disputes or problems which may arise in relation to use of the Website, the Application and the Services.
We have implemented reasonable security arrangements including physical, administrative, technical, and electronic security measures to protect against the loss, misuse, and alteration of your personal information. Despite our best efforts, however, no security measures are perfect or impenetrable. In the event where you believe your privacy has been breached, please contact us immediately.
It is your responsibility to protect any passwords you require to access your account, the Website, the Application and the Services. Please use unique numbers, letters and special characters, and do not share your password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password.
You undertake to treat your password and other confidential information in relation to the use of the Website, the Application and the Services confidentially, and we disclaim any liability arising from your failure to do so.
8. DISCLOSURE OF PERSONAL DATA
Your personal data will never be sold, traded, or otherwise transferred to any third party. However, your personal data may, from time to time, be shared with but not limited to:
(i) our personnel who will use the data to carry out the purposes set out above; and/or
(ii) financial institutions and payment operators.
Personal data we collect from you will also be used, or shared with third parties that assist in operating and facilitating use of the Website, the Application and the Services (including related companies and third party service providers), for some or all of the following purposes:
(i) creating or maintaining any account or profile you may have with us;
(ii) verifying and carrying out financial transactions in relation to any payments or transfers you make;
(iii) carrying out research and analytics on our users’ demographics and behaviour;
(iv) provide you with information we think you may find useful or which you have requested from us;
(v) enhancing user experience;
(vi) determining and verifying your eligibility for certain marketing or transaction events and other features of the Website;
(vii) enforcing our Terms of Service; and
(viii) communicating with you in relation to your account and alerting you to our latest developments.
Disclosure may also be made where we believe in good faith that such disclosure is necessary to:
(i) comply with the law or in response to a subpoena, court order, government request, or other legal process;
(ii) produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
(iii) protect our interests, rights, safety, or property or that of others;
(iv) provide users of the Services with the services they request;
(v) provide you with special offers or promotions from us; or
(vi) operate our systems properly.
Disclosure on information about our visitors, customers, or former customers may also be made with the following types of companies that perform services on our behalf or with whom we have joint marketing agreements:
(i) Non-financial companies such as envelope stuffers, fulfilment service providers, payment processors, data processors, customer/support services, etc.; and
(ii) Financial service providers such as companies engaged in banking, mortgage lending, consumer finance, securities, and insurance.
In sharing your personal data with such parties, we shall endeavour to ensure that the third parties and our affiliates keep your personal information secure from unauthorised access, collection, use, disclosure, or similar risks and retain your personal information only for as long as they need your personal information to achieve the above mentioned purposes.
If any disclosure of your information involves the transfer of your personal information out of Singapore, we will take steps to ensure that the receiving jurisdiction has in place a standard of protection accorded to personal information that is comparable to the protection under or up to Singapore’s data protection legislation.
9. ACCESS TO, WITHDRAWAL OF CONSENT AND UPDATE OF PERSONAL DATA
You have a right to access your personal data which we have collected, subject to the exceptions referred to in Section 21(2) PDPA, but we may charge a fee to cover the cost of verifying the application, and locating, retrieving and copying any material requested.
You may communicate your objection to our continual use and/or disclosure of your personal data for any of the purposes at any time.
You may update any of your personal data we possess by means of updating and accessing your account details, and if not, by contacting us.
10. OUR SECURITY POLICY
We require all users to exercise a duty of care in relation to the operation and use of our and/or their information systems.
If you are using our Website, Application and/or our Services as a member of staff or contractor, then with the exception of information published for public consumption, all such users’ information systems must be formally authorised by written appointment by us.
Authorised users will pay due care and attention to protect our information in their personal possession. Confidential, personal or private information must not be copied or transported without consideration of:
(i) Permission of the information owner;
(ii) The risks associated with loss or falling into the wrong hands;
(iii) How the information will be secured during transport and at its destination; and
(iv) Acceptable use of information systems use of our information systems by authorised users (such use to be lawful, honest and decent and shall have regard to the rights and sensitivities of other people).
We shall be responsible ensuring our information systems meet the following standards:
(i) Systems are adequately protected from unauthorised access;
(ii) Systems are secured against theft and damage to a level that is cost-effective;
(iii) Adequate steps are taken to ensure the availability of the information system, commensurate with its importance (Business Continuity);
(iv) Electronic data can be recovered in the event of loss of the primary source. I.e. failure or loss of a computer system. It is incumbent on all system owners to backup data and to be able to restore data to a level commensurate with its importance (Disaster Recovery);
(v) Data is maintained with a high degree of accuracy;
(vi) Systems are used for their intended purpose and that procedures are in place to rectify discovered or notified misuse;
(vii) Any electronic access logs are only retained for a justifiable period to ensure compliance with the data protection, investigatory powers and freedom of information acts; and
(viii) Any third parties entrusted with our data understand their responsibilities with respect to maintaining its security.