SPTel Pte. Ltd. (“SPTel”) has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer your Personal Data when you visit or use our Site. This Privacy Policy applies to your Personal Data when you visit or use our Site and does not apply to online websites or services that we do not own or control, including websites or services of other SPTel Users.

We may revise this Privacy Statement from time to time to reflect changes to our business, the Site, or applicable laws. The revised Privacy Statement will be effective as of the published effective date.

1. OVERVIEW

• This Privacy Policy is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Site. Please contact us if you have any questions about our privacy practices that are not addressed in this Privacy Policy.

2. PERSONAL DATA WE COLLECT

• We may collect information about you when you visit or use our Site, including the following:
• Registration information

When you register to use our Customer Portal by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the subscription you request. Depending on the subscription that you subscribe for, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Site.

• Transaction and experience information

When you use or access our Site, for example, to subscribe for services that we offer, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.

• Participant information

When you use or access our Site, we collect Personal Data you provide us about the other participants associated with the transaction.

• Information from third-party sources

We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

• Other information we collect

We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

3. RETENTION OF PERSONAL DATA

• We retain Personal Data to fulfil our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.
• If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.

4. PROCESSING OF PERSONAL DATA

• We may process your information for the following reasons:-
• To operate the Site and provide access, including but not limited to:
• Authenticate your access to an Account;
• Communicate with you about your Account, the Site, or SPTel;
• Create an account connection between your Account and a third-party account or platform; and
• Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes.
• Keep your Account and financial information up to date.
• To manage our business needs, such as monitoring, analysing, and improving the Customer Portal and the Site’s performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Site.
• To comply with our obligations and to enforce the terms of our Site, including to comply with all applicable laws and regulations.
• To respond to your requests, for example to contact you about a question you submitted to our customer service team.

5. SHARING OF PERSONAL DATA

• We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.
• We may share your Personal Data or other information for the following reasons:
• With our parent, subsidiaries and Affiliates,:We may share your Personal Data with our parent, subsidiaries and Affiliates, to, among other things, provide the subscription you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of our products and communications.
• With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support.
• With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product or service. These financial institutions may only use this information to market and offer SPTel-related products, unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date.
• With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for our business purposes or as permitted or required by law, including but not limited to:-
• If we need to do so to comply with a law, legal process or regulations;
• Law enforcement, regulators, government officials, or other third parties (in Singapore or elsewhere) in relation to a subpoena, court order, or other legal process or requirement under Singapore law or regulation, or the laws and regulations of other jurisdictions that are applicable to SPTel or one of its subsidiaries or Affiliates; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;
• To protect our property, Site and legal rights;
• To facilitate a purchase or sale of all or part of SPTel business;
• To help assess and manage risk and prevent fraud against us, our Users and fraud involving our Site or use of our Site, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants;
• To credit reporting and collection agencies;
• To companies that we plan to merge with or be acquired by; and
• To support our audit, compliance, and corporate governance functions.
• With public agencies or an organisation in the course of acting on behalf of a public agency in relation to the collection, use or disclosure of the personal data.
• With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform.
• In addition, we may provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit or use our Site. This data will not personally identify you or provide information about your use of the Site. We do not share your Personal Data with third parties for their marketing purposes without your consent.

6. COOKIES

• When you visit our Site or use our Site, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognise you as a User and to customise your online experiences, the services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Site. Certain aspects and features of our Site are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Site may be limited or not possible.

7. PROTECTION OF YOUR PERSONAL DATA

• We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls.
• While we are dedicated to securing our systems and Site, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised.

8. TRANSFERS OF YOUR PERSONAL DATA TO OTHER COUNTRIES

• Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.
• We and our third-party service providers store and process your Personal Data in the Republic of Singapore and elsewhere in the world. We will protect your information as described in this Privacy Statement if your Personal Data is transferred to other countries. By using our Site, you consent to your Personal Data being transferred to other countries, including countries that have different data protection rules than your country. We do not represent that our Site is appropriate or available in any particular jurisdiction.

9. DEFINITIONS

“Account” or “SPTel Account” means a Personal or Business SPTel Account.

“Affiliate” means any entity which, directly or indirectly, controls or is controlled by, or is under common control with SPTel, where control is (i) the direct or indirect ownership of more than fifty percent of the voting rights in such entity, or (ii) a right to appoint the majority of the directors of the entity.

“Device Information” means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device’s IP address; information about your device’s web browser and the internet connection being used to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data (e.g., Touch ID/Fingerprint to verify your identity).

“Geolocation Information” means information that identifies with reasonable specificity your location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask you for permission to share your current location. Some of the Sites and Services require this information to provide a specific product or online Service. If you do not agree to our collection of the geolocation information, our Sites or Services may not function properly when you try to use them.

“Personal Data” has the meaning given to it under the Data Protection Laws.

“SPTel,” “we,” “us” or “our” means SPTel.

“Substantial Change” means a change to the terms of this Agreement that reduces your rights or increases your responsibilities.

“Technical Usage Data” means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.

“User” means any person or entity using the SPTel Services including you.

Effective Aug 1, 2020