Personal data that we collect about you
Personal data means any information in our possession that relates directly or indirectly to an individual to the extent that the individual can be identified from that and from other information in our possession.
Personal data includes, but not limited to, name, address, copies and details of identification documents, contact details, gender, details of bank account, billing address, employment history, credit and references check, marital status, commission or alleged commission of offence, personal financial, social security detail, as well as information and data generated in the ordinary course of the relationship with us which may include signatures, answers to questions intended for security verification, emergency contact numbers and call back contact details.
How we collect your personal data
Purpose of personal data collected
You hereby acknowledge, confirm and consent that we may collect, record, hold, store and/or process your personal data for the following purposes:
1. to establish a relationship between you and us and/or companies related to or affiliated to us, our service providers and business partners;
2. to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Platform;
3. to manage, operate, administer and provide you with as well as to facilitate the provision of our services, including, without limitation, remembering your preferences;
4. to tailor your experience through our services by displaying content according to your interests and preferences, providing a faster method for you to access your account and submit information to us and allowing us to contact you, if necessary;
5. to process applications for products and services;
6. for identification and/or verification;
7. for evaluation and/or due diligence purposes;
8. for carrying out your instructions and the provision of products and services to you, whether provided personally or through telephone or electronic means, including processing of receipts and payments;
9. to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Platform;
10. for data processing purposes;
11. to evaluate and monitor provision of our services;
12. to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
13. to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
14. to allow other users to interact or connect with you on our Platform, including to inform you when another user has sent you a private message or posted a comment for you on our Platform;
15. to understand your needs and offering products and services to meet those needs;
16. for the research and development of products and services for customers use;
17. to allow us, our related and/or affiliated companies, service providers and business partners to promote their products and services;
18. for debt collection purposes;
19. for enforcement of our rights and obligations of other parties to us and/or our affiliates;
20. operating internal controls including determining amounts owed to or by you, payment to or collection of such amounts from you and from any persons providing security for your obligations and enforcing any charge or other security granted by or for you in respect of our products and services;
21. to enable a party to evaluate any actual or proposed assignment, participation, sub-participation and/or novation of our rights and/or obligations;
22. to meet legal and regulatory requirements, which may include disclosure, notification and record retention requirements;
23. to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
24. for any transfer or proposed transfer of any part of our interests, obligations, business and/or operations;
25. to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
26. to perform research, evaluation, administrative and operational tasks (including market or customer survey, due diligence, service improvement and product development, risk management, systems development, credit rating, and training);
27. for such other purposes as permitted by applicable law or with your consent; and
28. for all other purposes incidental and associated with any of the above,
(collectively referred to as “Permitted Purposes”).
This may require, among other things, share statistical and demographic information about our users and their use of the Platform with suppliers of advertisements and programming.
Use and disclosure
Your personal data will not be disclosed by us to any third party without your consent, save for disclosure to:
1. our group of companies (including our parent company, representatives, subsidiaries, affiliates, related and/or associated companies);
2. our trustees, business partners, vendors, suppliers, agents, contractors, service providers, insurance companies, professional advisers, banks and/or financial institutions who provide banking, trust, remittance, administrative, mailing, telecommunications, call centres, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, payment, debt collection, credit reference checks or securities clearing or other services to us;
3. our auditors, business consultants, accountants, lawyers or other professional advisers and/or consultants as we deem necessary and appropriate;
5. to any party who undertakes to keep your personal data confidential only to the extent necessary to fulfil the relevant Permitted Purposes, or to whom we are compelled or required by law to disclose to, including disclosure to courts, tribunals, legal, regulatory, tax and other government authorities; or
6. any actual or proposed assignee or transferee of our rights in respect of all or part of our assets or business.
Security of your personal data
We implement a variety of security measures and strive to ensure the security of your personal data on our systems. Your personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Third party’s personal data
Right to access and correct personal data
You have a right to request access to, request for a copy of and to request a correction of the personal data and to contact us with any inquiries or complaints in respect of your personal data. Subject to our right to rely on any statutory exemptions and/or exceptions to collect, use and disclose your personal data, you have the right at any time to request us to limit the processing and use of your personal data.
Where permitted by the Privacy Laws, we reserve the right to charge a reasonable administrative fee for retrieving your personal data records. If so, we will inform you of the fee before processing your request.
Withdrawal of consent
You may communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data by contacting us using the contact details below, subject to the conditions and/or limitations imposed by applicable laws or regulations.
Please note that if you communicate your withdrawal of your consent to our use, disclosure, storing or processing of your personal data for the purposes and in the manner as stated above or exercise your other rights as available under applicable local laws, we may not be in a position to continue to provide the services to you or perform any contract we have with you, and we will not be liable in the event that we do not continue to provide the services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
We do not sell products to minors (which is to be determined based on the applicable law), nor do we intend to provide any of the services or the use of our Platform to minors. We do not knowingly collect any personal data relating to minors.
We will not be responsible for any unauthorised use of the services on our Platform by yourself, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the services on our Platform and take necessary steps to prevent any misuse of the services on our Platform.
Third party sites
Our Platform may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.
Disclaimer regarding security and third party sites
WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you register a user account at our Platform or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.
In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, our Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party websites (even if offered on or through our Platform) may not be received by us.
We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
Requests or queries
English version shall prevail
Version dated April 2022