1.1 This Data Privacy Policy (“Policy”) governs the collection, use, disclosure or processing of personal data submitted to Comsoft Fintech Pte. Ltd. Singapore and CollectSmart Pte Ltd Singapore, including where and when assigned by these companies then such assigned associate or subsidiary company(s) (collectively referred to as "CollectSmart", “Company”, "we", "us", or "our"), in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1.2.1 individuals who access our websites, platforms and/or services.
1.2.2 individuals with whom we have or have had contact, either for business purposes or otherwise, whether on their own account or on behalf of third parties or organisations;
1.2.3 individuals who are employees or prospective employees of the Company;
1.2.4 individuals associated with our partners, third parties, suppliers, vendors or professional advisors; and
1.2.5 individuals who have opted to receive communications from us.
1.3 By interacting with us, submitting information to us, purchasing, leasing, visiting, accessing, or using any of our websites, products, platforms and/or services offered by us, you agree and consent to the collection, use, disclosure and processing of your personal data set forth in this Policy
2.1 Pursuant to the PDPA, personal data refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information which we have, or likely have access to. Examples of commonly collected personal data or information may include, but is not limited to:
2.1.1 personal information such as your name, date of birth, nationality, passport or other identification number(s), credit card information, occupation, employment and medical history or other information; and
2.1.2 contact information such as your phone number(s), billing and/or delivery address(es), email address(es) or other information;
2.1.3 information about your device(s), including where available your IP addresses, device type, operating systems and browser types, or other information
2.2 Generally, but not necessarily, we will collect your personal data where:
2.2.1 it is provided to us voluntarily by you directly or through a third party who we believe, in good faith, as to have been duly authorised by you to disclose your personal data to us (the “Authorised Representative”); or
2.2.2 collection and use of personal data without consent is permitted or required by the PDPA or any other applicable laws.
2.3 With regard to any data or information submitted or provided by you to us, whether your own or of any other party, using any means or through any part of the Website, link(s), product(s), service(s) or app(s) or other mechanisms, must be fully correct, accurate, updated, current, and complete in all aspects, and you should keep it fully correct, accurate, updated, current, and complete at all times and you should have all the moral and legal rights over such data or information and you should retain all such rights. You are prohibited from submitting, updating or providing any data or information where any of this is not fully true.
2.4 We may collect your personal data through various means, including but not limited to the following means, mechanisms, cases or events:
2.4.1 when you submit any form, including but not limited to application and registration forms or other forms relating to any of our products and/or services;
2.4.2 when you enter into any agreement (including but not limited to services agreements, sale purchase agreements, leasing agreements) or provide other documentation or information with respect to your interactions with us, or when you use our products and/or services;
2.4.3 when you speak to any of our employees via telephone calls, face-to-face meetings, social media platforms, letters, or emails;
2.4.4 when you use those portions of our Website or products or services that use our or third party cookies, web beacons or similar technologies or mechanisms or use other web links or third party website links that use these mechan8sms or any mechanisms that collect data or information;
2.4.5 when you use our electronic services, or interact with us via our websites, or use services on our websites and/or access any of our mobile apps which are made available on the App Store and/or the Google Play Store;
2.4.6 when you request that we contact you or request that you be included in an email, other mailing list, promotions or initiatives;
2.4.7 when you respond to any request for additional personal data;
2.4.8 when you are contacted by, and respond to our Company’s officers;
2.4.9 when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
2.4.10 when we receive your personal data from third parties in connection with your relationship with us (e.g., business partners, public agencies, or relevant authorities);
2.4.11 when you submit your personal data to us for any other reasons;
2.4.12 when you access the Website or portions of the Website that use cookies, for or in relation to any of our websites, products, platforms and/or services and other similar technologies that record information about your use of our websites, products, platforms and/or services for various purposes;
2.4.13 when we need your personal data in order to perform our obligations under a contract that we are about to enter into or have entered into with you; and/or
2.4.14 when it is necessary for our legitimate interests or where we need to comply with a legal or regulatory obligation.
3.1 Personal data may or will be collected, stored, used, processed, disclosed or transferred for various purposes such as, but not limited to the following:
3.1.1 to help us verify your identity and any accounts you hold with us;
3.1.2 to facilitate the provision of our business products and/or services;
3.1.3 to fulfil contractual obligations, process and manage quotations, processing orders of the supply of goods and/or services;
3.1.4 to process payment of invoices, bills and/or credit transactions for any purchase, lease or use of our products and/or services;
3.1.5 to process and respond to inquiries, feedback, requests, applications or complaints and provide customer support;
3.1.6 to manage our facilities, properties and business operations and comply with internal policies, reporting requirements and procedures;
3.1.7 to process, monitor and record calls and electronic communications with you for quality assurance, employee training, and/or investigation purposes;
3.1.8 to provide you with alerts, newsletters, promotional materials and any other information relating to our products and/or services that you requested or signed up to;
3.1.9 to comply with applicable laws, regulations, codes of practice, guidelines, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
3.1.10 to execute our system administration and to report aggregate information to our partners and advertisers. This relates to statistical data about our user's browsing actions and patterns, and does not specify any individual;
3.1.11 to enforce or defend our rights, contractual or otherwise, including investigations and participating in potential or actual litigation, arbitration, or other legal processes;
3.1.12 to make efforts towards or to try to ensure that content from our websites, products, platforms and/or services is presented in the most effective manner for you and for your device;
3.1.13 to notify you about changes to our services;
3.1.14 to manage any other administrative and support processes; and/or
3.1.15 any other purposes which are reasonably related to the aforementioned.
3.2 You acknowledge, agree and consent to the processing of your personal data depending on the circumstances at hand, including at times for any such purpose that may not appear as a purpose.
3.3 We may use the collected or extrapolated or analysed data or profiling or information for various purposes / reasons, including but limited to purposes such as, to streamline and improve your experience when you access and/or use our website(s), product(s), service(s) and/or our apps or to improve our business or market reach or to derive benefits for us or our Website(s), product(s) or service(s), that in turn allow us to strive to give better service(s) and/or product(s) to you, and/ or other customers, at reduced overheads and/or price. We may use the data, information or profiling for various purposes such as but not limited to, authentication, identification, profiling, improvement of Website(s), product(s) or service(s), business improvements, improvements in customer base or our business partnerships, targeted marketing or sales, business intelligence generation or other analytics etc. We may use various online forms, online or other direct or indirect information collection mechanisms, type of cookies or beacons or other technologies or data collection mechanisms and analytical or marketing tools or partnerships to improve our business potential or other benefits to us as permitted by law. If you do not agree to the said collection and use of data or cookies, web beacons or other similar technologies or data collecting mechanisms and the use or extrapolation of data, then you may not access any part of the Website, link(s), product(s), service(s) or app(s). You accessing any part of the Website, link(s), product(s), service(s) or app(s) shall mean you consent to the collection, extrapolation, analytics, sharing and use as stated herein.
3.4 We may also use your data, or permit selected third parties to use your data, to provide you with information about websites, products, platforms and services which may be of interest to you and we may contact you about these by email, post or telephone.
3.5 We may provide our business associates, partners or advertisers with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal data that we have collected from you to enable us to comply with our business associates’, partners’ or advertisers' wishes by displaying their advertisements to that target audience.
4.1 We will take reasonable steps to protect your personal data against misuse and unauthorised disclosure and will use, disclose and/or transfer your personal data as permitted under the applicable laws and regulations.
4.2 We may disclose and/or transfer your personal data for the purposes specified in Clause 3 and permitted or required by applicable laws and regulations to the following entities or parties:
4.2.1 our affiliates, business partners, counterparts and other companies within our group (if any);
4.2.2 personnel, agents, advisors, auditor, financial institutions, and service providers in connection with our operations, products and/or services;
4.2.3 any person or entity under a duty to keep the personal data confidential;
4.2.4 any vendor or third party service provider, in connection with marketing promotions and services offered by us;
4.2.5 any third parties to whom the Company is required to transfer data by law or regulatory requirement in or outside Singapore; and/or
4.2.6 any other party to whom you consent for us to disclose your personal data to.
4.3 We will also take reasonable steps to ensure that third parties acknowledge the confidentiality of your personal data and undertake to comply with the PDPA and this Policy.
4.4 The personal data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore, who work for us or one of our suppliers. Such staff may be engaged in functions such as but not limited to, the fulfilment of services and the provision of support services. By submitting your personal data to us, you agree to this transfer, storing or processing or use of your personal data or information. We will take steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Policy.
5.1 We are committed to employing reasonable processes and procedures towards the objective of safeguarding your personal data, specifically to:
5.1.1 ensure that all personal data collected by us shall be stored and/or filed in a manner in which personal data maintains its accuracy, integrity, and confidentiality; and
5.1.2 prevent your personal data from being distorted, altered, damaged or accessed by unauthorised third parties.
5.2 However, while we strive to use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet and/or apps is not entirely secure and for this reason, we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet and/or apps. Accordingly, you shall not hold us liable for any unauthorised disclosure, loss or destruction of your personal data arising from such risks.
5.3 If applicable, you undertake to keep your username and password (including other account details) secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person. You shall inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password, or if you believe that the confidentiality of your username and password has been lost, stolen or compromised in any way, or that actual or possible unauthorised transactions have taken place. Similarly, you shall not hold us liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
6.1 Subject to the PDPA and certain exemptions, you may make an access request for access to a copy of, or a correction request to correct or update your personal data held by us in accordance with Clause 11.
6.2 Please note that if your Personal Data has been provided to us by a third party (e.g., a referrer, or your company), you should contact that organisation or individual to make such access and correction requests to us on your behalf.
6.3 Please note that depending on the nature of request, you may be required to pay an administration or other fee to be determined by us in order for your request to be processed.
6.4 We will strive to respond to your request as soon as reasonably possible and based on the nature and complexity of the request.
6.5 Where appropriate, 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 as to why we are unable to do so (except where we are not required to do so under the PDPA).
7.1 Once consent is provided, withdrawal of consent with respect to data already provided may be difficult or non feasible for already submitted data, For any future use of your personal data, we may, upon reasonable notice being given by you of your withdrawal of any consent given or deemed to have been given, subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time, in respect of our collection, use or disclosure of your subsequent personal data in accordance with Clause 11, we may not be in a position to continue to provide our products and/or services to you or administer or continue any contractual relationship in place. We will inform you of the likely consequences upon your withdrawal of consent.
8.1 It is your (and where applicable, additionally your authorised representative’s) responsibility to provide accurate and updated personal data to us. We require that you (or your authorised representative) to notify us of any changes to your personal data in a timely manner and where provided using mechanisms provided by us. We require that you ensure that the record of your personal data or any data you submit to us or provide to us or any part of the Website or link(s) is accurate, current and complete and is kept accurate, current and complete at all times. We also require that you have full rights to any data or information that you submit, update or provide, whether yours or otherwise, before you submit, provide or update such data or information and that you shall continue to retain such rights in the future.
9.1 We may retain your personal data for as long as it is reasonably necessary to fulfil the purpose for which it was collected, and/or as required or permitted by applicable laws and regulations.
10.1 We may use cookies or beacons or other such technologies or mechanisms for various purposes / reasons, including but limited to purposes such as, to streamline and improve your experience when you access and/or use our website(s), product(s), service(s) and/or our apps or to improve our business or market reach or to derive benefits for us or our Website, that in turn allow us to strive to give better service(s) and/or product(s) to you, and/ or other customers, at reduced overheads and/or price. We may use cookies for various purposes such as but not limited to, authentication, identification, profiling, improvement of Website(s), product(s) or service(s), business improvements, improvements in customer base or our business partnerships, targeted marketing or sales, business intelligence generation or other analytics etc. We may use various types of cookies or beacons including but not limited to authentication cookies, performance cookies, functionality cookies, social media cookies, analytical cookies, targeting cookies, optional cookies, marketing cookies, third party cookies, other cookies or beacons or technologies, These cookies, beacons or technologies may be used to identify you, your location, your preferences and in general for your profiling, when you access our website(s), service(s), product(s) and/or our apps. Cookies collect certain data for, or based on, various purposes. If you do not agree to the use of cookies or web beacons or other similar technologies or data collecting mechanisms, then you may not access the Website, link(s), product(s), service(s) or app(s). You accessing any part of the Website, link(s), product(s), service(s) or app(s) shall mean you consent to the use of cookies.
10.2 Should you wish to disable the cookies, you may do so by changing the settings on your browser. However, please note that you may not be able to access all or parts of our website(s) and/or apps.
11.1 Our website(s) and/or mobile apps may contain links to external website(s) operated by third parties independent of us. We shall not be responsible for, and you agree to not hold us responsible for, the privacy policies or practices or any revisions to such, of third-party sites and their adherence to or lack thereof with respect to the said policies. We encourage you to learn about the privacy policies of such third-party sites by checking the policy of each site you visit. You shall agree to waive any claim against us with respect to such third party sites.
12.1 You may contact our Data Protection Point of Contact Person/Officer (Data Protection Point of Contact ) if you:
12.1.1 have any enquiries, feedback or comments in relation to our personal data protection practices or our Policy;
12.1.2 wish to withdraw your consent to any use and disclosure of your personal data as set out in this Policy; and/or
12.1.3 would like more information on or access and make corrections to your personal data records.
12.2 You may contact our Data Protection Point of Contact through but not limited to any of the following means:
12.2.1 Email: [email protected];
12.2.2 Registered mail: Blk 31, Cantonment Road, Singapore 089747
13.1 You also acknowledge that we, as well as our respective representatives and/or agents, may from time to time amend, modify, or otherwise update this Policy at our discretion, without prior notification, by way of posting a revised version on our website.
13.2 We encourage you to review our Website periodically in order for you to stay updated of any changes. Your continued use of our websites, platforms and/or services constitutes your consent to any such changes, to the extent such consent is not otherwise provided.
14.1 This Policy and the use of our website(s) and/or mobile apps shall be governed by the laws of Singapore. You agree to submit any disputes arising out of or in connection with this Policy to the exclusive jurisdiction of the Singapore courts.