With effect from 1 July 2014, this Privacy Notice (“this Notice”) shall form part of our terms and conditions governing your relationship with us as set out in the security and/or legal documents or otherwise entered into between you and us (collectively “the Terms and Conditions”). This Notice shall not affect our rights of collection, use, disclosure, processing and/or transfer of your personal data pursuant to the Terms and Conditions or under the law or any statutory provisions or at common law or equity and nothing herein shall be construed as limiting any of those other rights.
1. Collection and Use of Personal Data
Sing Investments & Finance Limited (“SIFL”) is committed to maintaining the confidentiality and privacy of your personal data. We only collect and use your personal data to provide you better customer service and for business and legal purposes in relation to our financial products and services including but not limited to the following:-
- Developing and providing loans and/or facilities, financial products or services (whether made available by us or through us), including but not limited to:
- executing banking, commercial or other transactions and clearing or reporting on these transactions;
- carrying out research, planning and statistical analysis; or
- analytics for the purposes of developing or improving our financial products, services, security, service quality and advertising strategies;
- assessing and processing applications, instructions or requests from you or our customers;
- communicating with you, including providing you with updates on changes to our financial products, services and loans and/or facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such financial products, services and loans and/or facilities and their terms and conditions;
- managing our infrastructure and business operations and complying with internal policies and procedures;
- responding to queries or feedback;
- addressing or investigating any complaints, claims or disputes;
- verifying your identity for the purposes of providing loans and/or facilities, financial products or services;
- conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
- complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities of Singapore and any other jurisdictions;
- monitoring financial products and services provided by or made available through us;
- complying with obligations and requirements imposed on us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
- creating and maintaining credit and risk related models;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enabling any actual or proposed assignee or transferee, participant or sub-participant of SIFL’s rights or obligations to evaluate any proposed transaction;
- enforcing obligations owed to us;
- seeking professional advice, including legal advice; and/or
- any other purposes reasonably required by SIFL.
We may also use personal data for any of the purposes set out in the Terms and Conditions that govern our relationship with you or our customer. Nothing in this Notice shall vary or supersede the Terms and Conditions that govern our relationship with you or our customer.
2. Withdrawal of Consent
You may at any time withdraw your consent to the collection, use or disclosure of your personal data by giving reasonable notice to us. However, you should take note that if you withdraw your aforesaid consent, we will have to terminate the loans and/or facilities and/or any of our financial products and services granted to you.
3. Handling Of Personal Data
We safeguard your personal data by ensuring that only authorised staff will have access to them. Our authorised staff are required to abide by their contractual obligations to maintain the confidentiality and privacy of your personal data at all times.
4. Disclosure Of Personal Data
We do not sell your personal data to anyone or any third party for marketing initiatives. Your personal data will not be published on our website.
We will only disclose your personal data in limited circumstances such as to the regulatory or law enforcement agencies or in accordance with the applicable laws or to the credit bureau for the purpose of conducting credit checks, to collect or report debts due and owing to us, to enforce and protect our rights, powers and remedies under our security documents and other third parties, whether located in Singapore or any other jurisdictions for any of the purposes set out in this Notice.
We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the Personal Data Protection Act 2012 (“PDPA”)( as amended, revised or re-enacted thereto from time to time) and any other applicable data protection and privacy laws.
The disclosures herein shall be without prejudice and shall not affect our rights of disclosure to any other persons or parties as set out in the Terms and Conditions or pursuant to any laws or any statutory provisions or at common law or equity and nothing herein shall be construed as limiting any of those other rights.
5. Compliance By Third Parties
6. Security Measures in Place to Protect Personal Data
To protect and safeguard the confidentiality of your personal data and to ensure that they are safe, secure and private, we adopt the following systems security and monitoring measures:-
- Firewalls, data loss prevention system, anti-virus protection and intrusion detection systems to detect and prevent any forms of illegitimate activities and/or illegal intrusions of our network systems;
- Regular security reviews of our systems by our Internal and External Auditors;
- Vigilant monitoring to detect any suspicious online activities at our website.
We are committed to monitoring our security system constantly for potential situations that could compromise the security or the privacy of our customers, online users and visitors to our website and to exploring new technology continually to enhance our security system. Nevertheless, we do not warrant the security of your personal data transmitted to us using our website and Internet and online services. This is because you accept the risks that any of your personal data transmitted to or received by us using our website and Internet and online services may still be accessed and/or disclosed by unauthorised third parties.
Your responsibility in safeguarding your personal data
- If you wish to access our website, always directly enter our website address in the browser address bar. Do not access our website via any hyperlink within emails.
- Clear your Browser’s Cache and History after each session-Default files on a computer, sometimes called “cache” files can retain images of personal data or otherwise sent to or received by us at our website, making them a potential target for a system intruder. Therefore, we strongly advise that you clear your browser’s disk cache and history after each visit to our website.
- Do not use a shared computer or an Internet cafe; computer to access our website because such computers may be installed with certain softwares which could capture your personal data or otherwise without your knowledge.
- If you have installed or downloaded any software which claims to speed up your internet connection or other softwares, games, screensavers etc, you should be aware that they may be spyware which has the ability to track your internet sessions and/or gain access to your personal data and Internet browsing history. We recommend that you uninstall such spywares.
- Do not leave your personal computer unattended during your online session or using the Online Contact Form whereby your personal data may be viewed by unauthorised persons.
- Ensure that your personal computer has the latest anti-virus, anti-spyware and firewall software and updates to guard against new viruses. Make sure that your computer’s operating system and browser software are updated with the latest security patches.
- Update us whenever you have changed your contact details in order for us to contact you in a timely manner on any issues or matters relating to your access to our website.
- Contact us should you notice something suspicious or encounter any issues, difficulties or irregularities in accessing our website.
- You should be aware of email frauds via phishing whereby generally you are asked to click a link to a fake website and provide, update or confirm your personal data. To bait you, the fraudsters may falsely inform you of a fake urgent or threatening condition concerning your account. Please note that we will never send you an email requesting for your personal data or information regarding your account with us. You should NOT respond to such fraudulent emails.
- Do not open email attachments from strangers, install software or run programs from unknown sources or origins.
- Delete junk or chain emails.
- Email messages sent to us over the Internet containing your personal data cannot be guaranteed to be completely secure and you assume all risks arising or in connection thereto.
It is important that you do your part to ensure that any personal data provided to us via the Online Contact Form or email or any other channels of communication are done in a safe and secure manner. We will not be liable to you for any losses, damages, expenses, costs (including legal costs) and charges (whether direct or indirect, foreseeable or unforeseeable, special or consequential or economic loss ) incurred or suffered by you arising out of you sending email messages containing your personal data to us over the Internet or for any error, fraud, forgery, system failure or anything beyond our control or in connection with your failure to adhere to the terms and conditions herein and the terms and conditions of access to our website under our Notice “Disclaimer of Liability” and/or your failure to follow the above recommended security measures.
7. Access to Personal Data
Under the PDPA as amended, revised or re-enacted thereto from time to time, you have the right of access to your personal data which are in our possession or under our control or information which may have been used or disclosed by us within a year before the date of your request. Your request to us for access must be made in writing and subject to payment of such fees as may be prescribed by us from time to time. The prescribed fee amount depends on the nature and complexity of your access request.
8. Correction of Personal Data
Keeping your personal data accurate and updated is very important to us. You can help us keep accurate records by informing us of any changes, errors or omissions in your personal data. If you have any reasons to believe that your records with us are inaccurate, incorrect, incomplete or not updated, please write to us. We will promptly update your records accordingly within seven (7) working days from the date of receipt of your request.
9. Retention of Personal Data
Your personal data will be retained by us for as long as the original purposes or the legal or business purposes for which your personal data were collected continues. Should retention is no longer necessary, your personal data will be deleted, destroyed or de-identified from you unless retention of the same is required to satisfy legal or regulatory requirements or to protect our interests or in accordance with our policies.
10. Third Party Websites
11. Customer Service and Enquiries
If you have any queries, concerns or complaints relating to the collection, use or disclosure of your personal data, you may call any of our Customer Service Officers at Tel: 63050398/ 64387060 during office hours from 9.00 am to 6.00 pm from Mondays to Fridays.
Please note that calls to our Customer Service Officers may be monitored or recorded.
Alternatively, you may write to us or send your email to our Data Protection Officer at firstname.lastname@example.org.
We are committed to providing you with good customer service and hence we will attend to your queries, concerns or complaints as expeditiously as possible.
13. Governing Law and Submission to Jurisdiction
Our data protection policy and practices shall be governed by and be construed in accordance with the laws of Singapore and in the event of any dispute or grievance, you agree to irrevocably submit to the exclusive jurisdiction of the courts of Singapore.
- “personal data” shall have the same meanings ascribed to them under the Singapore Personal Data Protection Act 2012 as amended, revised or re-enacted thereto from time to time. Personal data is data that can be used to identify a natural person. Some examples of personal data that we may collect are:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
- Specimen signature(s);
- financial details (e.g. income, expenses, and/or credit history);
- images (including photographs and video recordings) and voice recordings of our conversations with you;
- employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- tax and insurance information;
- banking information (e.g. account numbers and banking transactions); and/or
- personal opinions made known to us (e.g. feedback or responses to surveys);
- Any reference to the word “We”, “us” or “our” and words of similar import herein shall mean Sing Investments & Finance Limited and its successor or assign.
- Words importing the singular number include the plural number and vice versa. Words importing the masculine genders shall include the feminine and neuter gender and vice versa;
- Clauses and other similar headings are for ease of reference and shall not affect the interpretation of any terms herein; and
- Reference to any statute, statutory provision or subsidiary legislation includes a reference to that statute, statutory provision or subsidiary legislation as may be amended, varied, revised, substituted or re-enacted from time to time.