We”, “Us” or “Our” mean
, a private limited company organized under the laws of Singapore with its registered office located at 8 Burn Road #15 ‐ 13 Trivex, Singapore 369977“
Cookies” mean small text files that are placed on your computer or mobile device when you browse websites.
“Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her;
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
“Third Party” means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process Personal Data;
contract and does not create any legal rights, it serves as an expression of
’s commitment to protecting private Personal Data.
3.1 Collection of Information In order to provide you with Our services, we must collect Personal Data about you and obtain your consent in relation to the handling of such Personal Data.Here are some types of Personal Data that we collect but are not limited to:
Identity Data includes first name, maiden name, last name, title, username or similar identifier, tax ID, marital status, date of birth, country of birth, gender, employer details, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g. your passport or driver’s licence).
Contact Data includes billing address, residential address, email address and telephone numbers.
Financial Data includes bank account details.
Transaction Data includes details of your transaction activity such as the amount, date and time for each transaction.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
You will provide need to Us upon request all such information in relation to your financial and business affairs and/or identity, as We may reasonably require.
Where we need to perform the contract we are about to enter into or have entered into with you;
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on Consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw Consent to marketing at any time by contacting us at firstname.lastname@example.org. The withdrawal of Consent shall not affect the lawfulness of processing based on Consent before its withdrawal.
3.3 Consent of Information usage In using the Website, you consent to the collection and use of your Personal Data by Us in the ways described above (which may change from time to time) unless and until you inform us to the contrary. You may submit a request to withdraw your consent at any time by contacting Us at email@example.com. The withdrawal of Consent shall not affect the lawfulness of processing based on consent before its withdrawal. In most instances, it is obligatory for you to provide Us with your Personal Data in order to allow Us to satisfy your request or provide you with the service that you have requested for.
3.4 Information correct You must ensure that all information provided to Us is accurate and up-to-date at all times. Any changes must be advised to Us as soon as practicable.
3.5 Protection of Information We collect and store all information electronically and take reasonable steps to protect such information from unauthorized access, misuse, loss or destruction. We shall in no way be liable to you for any loss or damage you may incur as a result of the loss or theft of such information held by Us.
3.6 Retention of Information Any information collected by Us may be kept or destroyed in accordance with relevant data protection legislation.
3.7 Sharing of Information We may share your Personal Data with:
(ii)Law enforcement, government officials, or other third parties when We are required to provide your Personal Data by law, subpoena or court order.
(iii)Other third parties with your consent or direction to do so.
3.8 Non-Personal Data We also collect Non-Personal Data about you and obtain your consent in relation to the handling of such Personal Data. Here are the some types of Non-Personal Data that we collect but are not limited to:
Other technologies such as scripts, demographic information, aggregated information
3.10 Marketing We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We have established the following Personal Data control mechanisms:
(i) Promotional offers from UsWe may use your Identity, Contact, Technical, Profile and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from Us if (i) you have requested information from Us; (ii) use Our Services; or (iii) if you provided Us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
(ii) Third-party marketingWe will get your express opt-in consent before we share your Personal Data with any company outside the Circle group of companies for marketing purposes.(iii) Opting out
You can ask Us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting Us at firstname.lastname@example.org at any time.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to Us as a result of your use of our Service, a product/service experience or other transactions.
3.11 Children’s privacy Unfortunately, if you’re under 21, you can’t use Our website. We do not knowingly solicit or collect information from anyone under 21. If we become aware that a person under the age of 21 has provided Us with Personal Data, we’ll delete it immediately.
Please note that we may process your Personal Data without your knowledge or Consent where this is required or permitted by applicable laws.