Equity Solution Terms and Privacy Statement II
The purpose of this document (“Data Protection Policy“) is to inform you of how Equity Solution Pte Ltd (the “Company”), which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (the “PDPA“). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use, and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any services offered by us, you agree and consent to the Company as well as its representatives and/or agents (the “Representatives“) (the Company and Representatives collectively referred to herein as, “us”, “we” or “our”) collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to the Company’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to the Company in respect of your Personal Data, and your consents herein are additional to any rights which the Company may have at law to collect, use, or disclose your Personal Data.
We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time.
1.1As used in this Data Protection Policy,
“Customer” means an individual who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of services by us; and
“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 to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2Examples of such Personal Data you may provide to us includes:
(a)your personal information (e.g. your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, date of birth, number of dependents, marital status, nationality etc.);
(b)information about your property or prospective property, your financial and loan information (e.g. your income, assets, liabilities, credit rating etc.);
(c)transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.
1.3Other terms used in this Data Protection Policy shall have the meanings given to them in the PDPA (where the context so permits).
2.COLLECTION OF PERSONAL DATA
2.1Generally, we do not collect your Personal Data unless it is provided to us voluntarily by you directly on our website or otherwise provided to us through other channels e.g. phone, email, WhatsApp and other messaging and information sharing services. We may also collect and store Personal Data that is provided to us about other related individuals (e.g. co-borrowers, family members, dependents), including their full name, their NRIC/passport number, soft copies of their NRIC/passport, residential address, phone number, financial information or other personal data.
2.2We may also periodically obtain Personal Data about you from business partners and other third parties, including but not limited to banks, financial institutions, and other service providers and websites. Examples of such Personal Data includes, but is not limited to, contact details, purchase details such as information about your property and additional demographic information, and credit reports.
2.3We 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).
2.4Generally, we collect Personal Data in the following ways:
(d) when you submit an application form or other forms relating to any of the goods and services;
(e)when you interact with our employees, for example, via telephone calls, letters, face-to-face meetings, emails or social media;
(f)when you use some of our services, for example, websites including establishing any online accounts with us;
(g)when you purchase or obtain third party services through us;
(h)when you request that we contact you, be included in an email or other mailing list;
(i)when you respond to our promotions, initiatives or to any request for additional Personal Data;
(j)when you are contacted by, and respond to, our marketing representatives and customer service officers;
(k)when we receive references from business partners and third parties (e.g. where you have been referred by them);
(l)when we seek information from third parties about you in connection with services you have applied for; and
(m)when you submit your Personal Data to us for any other reasons, including when you express your interest in any of our goods and services.
2.5If you provide us with any Personal Data relating to a third party (for example, information of your spouse, children, parents, or a Connected Person), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with his/her Personal Data for the respective purposes.
2.6When you browse our website and platforms, you generally do so anonymously but please see the section below on cookies. We do not, at our website and platforms, automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials.
2.7You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with goods and services you have requested. You agree to inform the Company immediately of any change of facts or circumstances which may render any information or Personal Data previously provided inaccurate, untrue, or incorrect and provide any information or documentation as the Company may reasonably require for the purposes of verifying the accuracy of the updated information or Personal Data
3.PURPOSES FOR COLLECTION OF PERSONAL DATA
We may collect and use your Personal Data for any or all of the following purposes:
(n)verifying your identity for the purpose of providing services in which you have expressed interest, purchased, or signed up for;
(o)performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(p)responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(q)managing our administrative and business operations and complying with internal policies and procedures;
(r)monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;
(s)communicating with you about products or services that you have expressed interest in, or may be of interest to you, either offered by the Company or other third parties that we liaise with, including but not limited to banks, insurance companies, and other financial institutions.
(t)complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(u)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; and
(v)any other purposes for which you have provided the information; and
(w)any other incidental business purposes related to or in connection with the above.
3.2The purposes listed in the above clauses may continue to apply even in situations where your relationship 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).
4.DISCLOSURE OF PERSONAL DATA
4.1We will undertake reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of the applicable law, your Personal Data may be disclosed:
(a)where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
(b)to third-party service providers, agents, and other organisations we have engaged to perform any of the functions listed in Clause 2.4 above; or for any purpose allowed under any applicable law or regulation.
4.2We may disclose your Personal Data to the following parties: –
(a)our related corporations and employees to provide content, goods and services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Services and to activate, deactivate, install, maintain and operate our systems and/or Services;
(x)companies providing services relating to insurance and consultancy to us;
(y)agents, contractors, or third-party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or any other services;
(z)vendors or third-party service providers in connection with marketing promotions and services offered by us;
(a)other telecommunications, content, or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
(b)any business partner, investor, assignee, or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale) involving the Company;
(c)collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
(d)banks and other financial institutions;
(e)our professional advisers such as auditors and lawyers;
(f)relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(g)any other party to whom you authorise us to disclose your Personal Data to.
4.3We wish to highlight that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our websites and online services; any transmission is at your own risk. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
5.USE OF SESSION VARIABLES, COOKIES, AND RELATED TECHNOLOGIES
5.1Cookies are small text files stored in your computing or other electronic devices when you visit our website and platforms for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
5.2Our websites and platforms use Session Variables, cookies, and other related technologies to distinguish you from other users of our website by storing generally non-personally identifiable information (e.g., session information such as the number of times you visit our website, and the location from which you are accessing the website). Do note that all session variables will be deleted from our server upon you exiting our websites.
5.3We may employ Session Variables, cookies, and other technologies, which stores generally non-personally identifiable information, as follows:
(a)tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
(h)making our websites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites and platforms;
(i)to better tailor our goods and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
(j)using such information to understand how people use our websites and platforms, and to help us improve their structure and contents;
(k)using cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms; and/or
(l)personalising the website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
5.4Any other information is anonymised and/or aggregated to produce statistical reports that enable us to evaluate the use of our website; and to make improvements to and increase efficiency when you browse our website.
5.5Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites and platforms to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
6.STORAGE OF PERSONAL DATA
6.1The Personal Data that we collect form 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 for one of our service providers.
6.2By submitting your Personal Data, you agree to this transfer, storing and processing. We will take the appropriate steps to ensure that your data is treated securely and in accordance with this Data Protection Policy.
7.ACCESS TO AND CORRECTION OF PERSONAL DATA
7.1If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data; or (b) correction 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.
7.2Please not that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
7.3We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) 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).
8.1We will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks. Information such as credit / debit card details are encrypted and transmitted in a secure manner.
8.2However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware, or adware). You should be aware of the risks associated with using websites and take any necessary precautions.
8.3While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or electronic communication or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms.
9.RETENTION OF PERSONAL DATA
9.1We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
9.2We 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.
10.THIRD PARTY SITES
11.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 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.
11.2Upon 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 thirty (30) business days of receiving it.
11.3Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to thirty (30) working days for your withdrawal to be reflected in our systems. In the meantime, you may still receive marketing or promotional materials/communication from us. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the goods and services that you hold or have subscribed to with us.
11.4Whilst 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 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 11.1 above.
11.5Please note that withdrawing consent does not affect our right to collect, use, and disclose Personal Data were such collection, use and disclosure without consent is permitted or required under applicable laws.
12.DATA PROTECTION OFFICER
(a)have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(m)would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(n)would like to obtain access and make corrections to your Personal Data records,
please write to or contact our Data Protection Officer at:
EQUITY SOLUTION PTE. LTD.
16 KALLANG PL #07-03
Attn: Data Protection Officer