PRIVACY POLICY

(version last updated 16/9/2022)

Digizen Pte. Ltd. (“We”) respect your privacy. On this page, we set out our privacy policy in compliance with applicable personal data protection laws, in particular, the Personal Data Protection Act in Singapore (the “PDPA”). By accessing or using our website and/or services, you acknowledge that you have read, understood and accepted this privacy policy and its terms.

A. PERSONAL DATA

We may collect and process the following types of information from you:

1) Contact Information

When you establish any contact with us, e.g., making an enquiry on our website, emailing our representative, or registering for our events, we may collect your name and contact information, including your email address and your contact number, to respond to you. We will also use your contact information to further communicate with you for purposes related to the provision of our services to you as our client (including prospective client).

2) Personal Information

In addition to Contact Information, we collect and process personal data about you, including but not limited to the following:

a) Personal and financial information about you which you provide to us during your onboarding as our client, including but not limited to your national identification number, passport number, age, date of birth, gender, marital status, occupation, nationality, residency, residential address, income, assets, wealth;

b) Personal and financial information about your family members which you provide to us during your onboarding as our client, including but not limited to their national identification number, passport number, age, date of birth, gender, marital status, occupation, nationality, residency, residential address, income, assets, wealth;

c) Internal notes, records and information about you through your interactions with us as our client;

d) Information about you which is available publicly, e.g. online or social media;

e) Information about you obtained from third parties including banks, credit agencies, regulatory bodies, or other client(s) through whom you were referred to us; and

f) Information from cookies when you visit our website.

B. HOW WE USE YOUR PERSONAL DATA

1) General Purposes

Generally, we may use, record, systemize, store, update, modify, retrieve, share, disclose, delete or otherwise process your personal data for the following purposes, using manual or automated means:

a) Provide services, including services agreed under contract, customer, content, product services, technical support and responses to you;

b) Deliver notifications, emails, text messages, alerts and other communications to you about our services and of our third-party partners as agreed by you;

c) Customize and personalize content, customer and product services to you;

d) Send marketing communications and informational newsletters that you have requested, opted-in to or otherwise agreed to receive;

e) Improve the quality of your experience and/or our provision of services to you, including sending surveys to you;

f) Keep your account information updated to ensure accuracy of information;

g) Allow our third-party contractors or service providers to perform functions or services on our behalf;

h) Comply with legal and regulatory requirements and company’s policies and procedures as may be applicable from time to time; and

i) Any other reasonable purposes related to the above.[XS2]

C. WHY WE PROCESS YOUR PERSONAL DATA

Without prejudice to the above, we generally do not collect and process 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;

b) it is necessary for the performance of our services under the contract; or

c) such 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).

D. WHO WE SHARE YOUR PERSONAL DATA WITH

We may share your personal data with our partners and third-party contractors in the course of providing our services. Our partners and third-party service contractors will be responsible for the information in their possession and that information will be subject to any privacy terms or polices that the partner or third party has in place.

We are not responsible for use (or misuse) of your personal data by any of our partners or third-party service providers.

In the event of merger, acquisition, takeover, bankruptcy, liquidation, transfer of the business or assets, we may disclose, share, transfer your information to the prospective acquiror and/or other relevant third-parties. We will make sure that any such transfer is done in a secure way.

E. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will retain your personal data only for as long as necessary for the purposes set out in this policy, i.e. for as long as your account is active, or as needed to provide the services to you. In addition, we will also retain and use your information to the extent necessary to comply with our legal obligations, e.g, for record retention purpose required by local regulations and laws, to resolve disputes, enforce our agreements.

Please note that we may continue to retain log files for internal record, analysis and regulatory purposes even after you close your account.

F. HOW WE KEEP YOUR PERSONAL DATA SAFE AND SECURE

We appropriate organizational safeguards and security measures in place to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

a) The entire system and user information storage is deployed in the highly secured AWS data center;

b) Conduct system security audits on a regular basis;

c) Conduct a series of precautionary measures, such as implementing data access control, to make sure that user data is accessible to authorized persons only. Employees who have access to user data have signed non-disclosure agreements to ensure security of user data;[XS3]

G. ACCESS AND CORRECTION

If 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) a correction request to correct or update any of your personal data which we hold about you;

you may submit your request 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. In general, our response will be within thirty (30) business days. 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).

H. ADDITIONAL INFORMATION

1) Accuracy

We generally rely on personal data provided by you for accuracy. In order to ensure that your personal data is current, complete and accurate, please update us if there are any changes to your personal data by informing our Data Protection Officer via email at the contact details provided below.

2) Transfers of Personal Data Outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

3) Changes to the Policy

We may amend or update this policy from time to time. If we believe that the changes are material, we will let you know by doing one (or more) of the following:

a) Posting the changes on or through the services;

b) Sending you an email or message about the changes; and/or

c) Posting an update in the version notes on our website.

We encourage you to check back regularly and review any updates.

4) Data Protection Officer

You may contact our Data Protection Officer if you have any enquiries or feedback on our data protection policies and procedures, or if you wish to make any request, using the email address: ask@digizen8.com