Privacy Policy.

1. Introduction

1.1 This Privacy Policy outlines how we collect, manage, disclose and share the personal information (including Personal Data) we hold about you, in compliance with Applicable Laws. Personal Data is defined under the Personal Data Protection Act 2012 (PDPA) as “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 the organisation has or is likely to have access”.

1.2 This Privacy Policy applies to personal information that we collect through the Platform and/or our website www.dealcierge.io (the Site).

1.3 By using our Services pursuant to the Agreement, operating any Account maintained with us, accessing the Platform, websites or mobile applications operated by us, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your personal information in accordance with this Privacy Policy.

1.4 If you have any questions or concerns about our use of your Personal Data, then please contact us using the contact details provided at the bottom of this Privacy Policy.

1.5 The Site and/or Platform is not intended for or directed to persons under the age of 18, and we will not knowingly collect information from persons under 18. To provide information to us through registration or in any other manner on the Site and/or Platform, you must be 18 years of age or older.

1.6 Capitalised terms not otherwise defined in this Privacy Policy shall have the meaning as ascribed in the Agreement. The terms in this Privacy Policy shall supplement and add to the terms and conditions as set out in the Agreement. In the event of conflict or inconsistency between any provisions in this Privacy Policy and the Agreement, the terms of this Privacy Policy shall prevail in respect of the matters contained herein to the extent of such conflict and inconsistency. Save for the foregoing, this Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your personal information, and your consent to this Privacy Policy is in addition to any other rights which we may have to collect, use, process or disclose your personal information.

2. What personal information do we collect from you?

2.1 We collect or receive personal information in a few different ways via the Platform and/or Site. Often, you choose what information to provide, but sometimes we require certain information in order for you to use, and for us to provide you with, the Platform and/or Site and the experiences you reserve or access through the Platform and/or Site.

2.2 The Personal Data that we collect or may collect from you includes:

2.2.1 personal contact information including your name, email address, mailing address, telephone number;

2.2.2 identification number, nationality, gender, date of birth;

2.2.3 financial information including but not limited to bank balance information, investment portfolio, property information, information relating to your financial services providers (e.g. bank account information,), preferences and objectives (e.g. investment objectives and goals);

2.2.4 any other Personal Data reasonably required in order for us to provide the Services requested by you;

2.2.5 any other Personal Data permitted by or required to comply with any Applicable Laws and our internal control and compliance policies; and

2.2.6 other information which you voluntarily disclose to us.

3. How do we collect your personal information?

3.1 To create an Account, you need to provide information such as your name, email address, and a password. Unless you choose to opt out, you will be enrolled in our mailing list after your Account is created.

3.2 To complete your profile, you may be required to provide other information, such as a photo/live picture, birthdate and a national identity card or passport. This is to comply with local compliance requirements relating to customer identification.

3.3 Personal information will also be collected automatically through your use of the Platform and/or Site. We log usage data when you visit or otherwise use our Site, such as when you perform a search, browse, contact or communicate with a user or counterparty on the Platform and/or Site. Specifically, the information we collect may automatically include information such as internet protocol address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Site and/or Platform, including the pages accessed and links clicked. The information we collect automatically enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. This enables us to improve the quality and relevance of our Site to our visitors.

3.4 We may also use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across the Site and/or Platform, including when you use different devices

3.5 From time to time, we may receive personal information about you from third party sources to assist us in providing, evaluating and improving our Site and offerings, but only where these third parties have been authorised by you, represented that you gave your consent or are otherwise legally permitted or required to disclose your personal information to us.

4. How do we use your personal information?

4.1 We will only collect, use, and disclose your Personal Data for the purposes you have been notified of and consented to or which are permitted under Applicable Laws.

4.2 We may collect, use or disclose your personal information (including Personal Data) for our business purposes, including the provision and continuing operation of the Platform and/or the Services provided to you. This includes, the following purposes (the Purposes):

4.2.1 performing obligations in the course of or in connection with our provision of products and/or Services requested by you;

4.2.2 providing you with products and Services as subscribed to or requested by you;

4.2.3 carrying out any transactions contemplated on the Platform and the Services thereto;

4.2.4 providing customer service, customer support and technical support, including in relation to product updates;

4.2.5 responding to, handling and processing queries, requests, applications, complaints and feedback from you;

4.2.6 to address or investigate any complaints, claims or disputes;

4.2.7 managing your relationship with us;

4.2.8 communicating with you, including providing you with updates on changes to our Services;

4.2.9 know-your-client checks or processes, verifying your identity or evaluating your eligibility profile before providing products and Services;

4.3 Our service providers may collect metadata (such as ancillary usage data, e.g. IP address) from your use of our Platform and/or Site and/or your use of their services, for providing services and related internal or regulatory compliance uses, such as the provision of service performance statistics. We may also transfer and/or disclose your personal information to our service providers for the purposes of or in relation to the conduct of customer due diligence or know-your-client checks and processes.

4.4 Anonymised data and anonymised aggregated data (anonymised data aggregated with anonymised data from other service provider users) may be used for providing, maintaining and supporting the service provider services, compiling statistical reports, and performance tracking.

4.5 The Purposes listed above 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).

4.6 Depending on the purpose of processing your personal information, personal information may be disclosed to:

4.6.1 our affiliates anywhere in the world, including any officer, employee, agent or director of any affiliate;

4.6.2 our joint venture partners, business alliance partners or other investors or potential investors (in connection with the actual or potential merger, sale, acquisition or investment) provided we inform the relevant third party it must use your personal information only for the Purposes disclosed in this Privacy Policy;

4.6.3 our professional advisers and third party service providers in order to provide administrative, financial, legal, accounting, information technology, authentication, research or other services;

4.6.4 anyone authorised by you, as specified by you or in any contract with you;

4.6.5 any person, (including any regulatory or government organisation, court, judicial body, agency, department or regulatory (including self-regulatory), financial, taxing or other authority or organisation), in any jurisdiction, insofar as we need to do so to comply with relevant laws and regulations or any order, directive or request which we are required to comply with, or which we in good faith believe that we should comply with;

4.6.6 any person to whom disclosure is required or permitted under applicable laws and regulations;

4.6.7 anyone we consider necessary to facilitate requests for services or applications for products with our affiliates; and

4.6.8 anyone we consider necessary in order to provide services in connection with a product or Service.

5. Transfer of personal data outside Singapore

5.1 We may transfer, store, process and/or deal with your Personal Data outside Singapore. When doing so we will take appropriate steps to ensure that the transferred Personal Data is provided with a standard of protection that is at least comparable to the protection under the PDPA.

6. Data security

6.1 We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. When using external service providers, we require that they adhere to security standards mandated by us.

6.2 We monitor our systems for possible vulnerabilities and attacks. However, you should be aware, that no method of transmission over the Internet or method of electronic storage is completely secure. We cannot guarantee 100% security of any information that you send us. Accordingly, you will not hold us liable for any unauthorised access, collection, use, disclosure, copying, modification, disposal, loss or destruction of your personal information arising from such risks.

7. Third party sites

7.1 Our Platform and/or Site may contain links to other websites, including social sharing features and other related tools, which are not operated or maintained by us. Please be aware that Dealcierge does not control these linked websites and this Privacy Policy only applies to our websites, mobile applications (as applicable), the Site, Platform and/or our Services. When visiting these third party websites, you should read their privacy policies which will apply to your use of their websites.

8. Data retention

8.1 We retain your Personal Data in line with our legal and regulatory obligations and for business and operational purposes. In the majority of cases this will be for six (6) years from the end of your relationship with us. We will cease to retain your Personal Data when we no longer require such Personal Data for the purposes we originally notified you of or for any business or legal needs.

9. Your rights

9.1 If you wish to access, correct or update your Personal Data; request the Personal Data you have given to us in a machine readable format; or to make a request to withdraw your consent previously given, you can do so by contacting the Data Protection Officer (details below).

9.2 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.

9.3 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) Business Days after receiving your request, we will inform you in writing within thirty (30) Business 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).

9.4 You also have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us. Please 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 30 Business Days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Additionally, opting out of marketing communications does not mean that we cannot continue using and disclosing your Personal Data for other purposes set out in this Privacy Policy.

9.5 In general, whilst 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 our products or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under Applicable Laws.

10. Updates to this Privacy Policy

10.1 We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. If you continue to use our Services, operate any Account, access our Platform, Site, websites or mobile applications (as applicable), and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such changes without reservation.

11. Contacting us

11.1 You may contact our Data Protection Officer at Karan.Soni@dealcierge.io if you have any enquiries or feedback on our personal data protection policies and procedures.