This policy covers how SingX and its affiliates including SingX HK Co. Ltd (the “SingX Group”) treats personal information that we collect and receive, including information related to your past use of SingX products and services. Personal information is information about you that is personally identifiable like your name, address, email address, or phone number that is not otherwise publicly available.
This policy does not apply to the practices of companies that SingX does not own or control, or to people that SingX does not employ or manage. Where you are undertaking a remittance transaction, all information which you provide will be shared with the respective licensed remittance operator (“LRO”) in the markets for which you are undertaking a transaction utilising the SingX platform and such LROs shall have an independent right to your personal information.
1. Information Collection and Use
1.1 The purposes for which information may be used by us include:
- ensuring that content from our site is presented in the most effective manner for you and for your computer;
- providing you with alerts, newsletter, education materials or information that you requested or signed up to;
- carrying out our obligations arising from any contracts entered into between you and us and our Licensed Remittance Operators where you are carrying out a remittance transaction;
- allowing you to participate in interactive features of our service, when you choose to do so;
- designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
- complying with laws and regulations applicable to us or any of our affiliates / LROs ;
- legal proceedings, including collecting overdue amounts and seeking professional advices;
- researching, designing and launching services or products including seminars/events/forums;
- promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in clause 1.2 below); or
- purposes directly related or incidental to the above.
1.2 We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
- Data collected directly from you. This may be done through this Site, over the phone, by email, or in person when you meet our staff or representatives. The data collected may include, but is not limited to:
- your contact information, including your (first and last) name, (billing and/or delivery) address, birthdate and email address and your telephone number. We need your e-mail address and telephone number so that we may contact you if we have questions or information for you regarding your order or the service that we are providing or will provide to you;
- other information required to be able to process your order or to provide you with the service, such as information concerning the products you have ordered or the service we are providing to you, the billing and/or delivery address, banking and/or credit card details;
- if you have created an online profile or account, the preferences and interests stored in such profile or account (please see below for further information concerning the profiles); and
- if you have contacted us, the details of this contact and the contact history.
- Data collected by automated means. Various technologies may be used on our website and our mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user's personal data. Examples of such technologies include:
Click-stream data. A visit to our Site results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
- the visitor's IP address
- the date and time of the visit
- the referral URL (the site from which the visitor has come)
- the pages visited on our website
- information about the browser used (browser type and version, operating system, etc).
- Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or our (mobile) applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
- Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. This means that when you visit our website or use any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies.
- the following classes of services, products and subjects may be marketed in direct marketing:
- services and products related to our site and/or our licensed remittance operators and/or third party entities whom SingX has partnered with (including marketing programs we are a part of);
- reward, loyalty or privileges programmes, promotional offers and related services;
- invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
- We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge
2 Disclosure of your information
2.1 We provide the information to our LROs who work with the SingX Group under confidentiality agreements. These companies shall use your personal information to meet their regulatory requirements in their country in order for the SingX Group to process any transactions which you undertake using the SingX platform.
2.2 We will keep the personal data we hold confidential but may provide information to:
- personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;
- our overseas offices, affiliates, business partners and counterparts (if any);
- persons under a duty of confidentiality to us;
- persons to whom we are required to make disclosure under applicable laws and regulations in or outside Singapore or Hong Kong; or
- actual or proposed transferees or participants of our services in or outside Singapore or Hong Kong.
We reserve the right to send you certain communications relating to the SingX Group services, such as service announcements, administrative messages and the SingX Group Newsletter, that are considered part of your SingX Group account.
4. Confidentiality and Security
We limit access to personal information about you to employees who we believe reasonably need to come into contact with that information to provide products or services to you or in order to do their jobs.
No electronic data interchange can be guaranteed to be 100% secure. However, when entering any data information we use the industry standard SSL (Secured Socket Layer) 256-bit encryption.
5. Third party websites
Our website may contain links to other sites ("Linked Sites"). We are not responsible for the privacy policies or practices of such other Linked Sites. We encourage our users to be aware when leaving our website to read the privacy policies or statements of each Linked Site that collects your personal data. You agree to waive any claim against us with respect to the Linked Sites.
6. Data transfers
We may hold your data on servers in such territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any people listed at clause 2 above, who may be located in or outside of Singapore.
7. Your consent and rights
7.1 By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.
7.2 Individuals have the right:
- to check whether we hold personal data about you and to access such data;
- to require us to correct as soon as reasonably practicable any data relating to you which is inaccurate;
- to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and
- to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.
7.3 You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to email@example.com
8. Governing law and jurisdiction
9. Questions and Suggestions
If you have questions or suggestions, please contact us via the “Contact Us” link.