1. PERSONAL DATA
1. As used in this Policy:
“Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“Personal Data” in this Policy means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2.Personal Data which we may collect from you include, but is not limited to, your name, NRIC, passport or other identification number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
We may collect, use, and disclose your Personal Data for any or all of the following purposes in connection with the products and services which you have applied, to the extent applicable, for:
a. Processing your application for any of the products or services offered or distributed by us;
b. Performing obligations in the course of or in connection with our provision of the goods and/or services requested or applied by you;
c. Evaluating your credit and eligibility profile (including but not limited to your assets) from time to time;
d. Verifying your identity;
e. Managing your relationship with is, including but not limited to responding to, handling, and processing queries, requests, applications, complaints, and feedback from you, addressing or investigating any complaints, claims, or disputes;
f. Processing payment or credit transactions;
g. Sending you marketing information about our goods or services, including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and reward schemes, and other promotions;
h. Meeting or complying our internal policies and procedures, and with any applicable laws, regulations, codes of practice, guidelines, orders or requests issued by any court, legal or regulatory bodies (both national and international) or to assist in law enforcement and investigations conducted by any governmental and/or
i. Legal purposes (including but not limited to enforcing our legal rights, drafting and reviewing documents, obtaining legal advice and facilitating dispute resolution);
j. Any other purposes for which you have provided the information;
k. Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
l. Transmitting to the our related corporations, including its parent company, subsidiaries, affiliates, and business partners, whether in Singapore or abroad, for the aforementioned purposes; and
m. Any other incidental business purposes related to or in connection with the above (collectively “Hire Purchase and Leasing Purposes”).
The Hire Purchase and Leasing Purposes may continue to apply even in situations where your relation with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
3. USE OF PERSONAL DATA FOR MARKETING PURPOSES
1. In addition to the Hire Purchase and Leasing Purposes:
We may use your Personal Data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible.
Where you apply for or hold a business product which is offered jointly by us and our related corporations, including its parent company, subsidiaries, affiliates, and business partners (“Affiliates”), we may also collect, use, and disclose your Personal Data for the purpose of sharing such Personal Data with our Affiliates for offering, marketing and promoting to you any products, services, offers or events which our Affiliates think may be of interest to you. (collectively, “Marketing Purposes”).
Marketing messages sent for Marketing Purposes may take the form of various modes, including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. However, please be assured that we will only do so if you have, pursuant to our Marketing Consent form, provided your clear and unambiguous consent in writing or other recorded form for us to do so.
5. WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw your consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause [4.1] above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
6. ACCCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) a request for access to a copy of the Personal Data which we hold about you; or (b) a request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within fourteen (14) days after receiving your request, we will inform you in writing within fourteen (14) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
7. PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis
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.
8. ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
9. RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected and until it is no longer necessary for any other legal or business purpose
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes
12. EFFECT OF POLICY AND CHANGES TO POLICY
1. This Policy applies in conjunction with any other Terms and Conditions governing your relationship.
2. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes youracknowledgement and acceptance of such changes.