PLMP Fintech Pte. Ltd (“PLMP”) are committed to protecting and respecting your privacy.
- 1. General
- This Policy statement provides information on the obligation and policies of PLMP in respect of an individual user’s Personal Data. PLMP undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
- PLMP officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, PLMP. PLMP shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by PLMP shall be done in an appropriate manner and in accordance with the Act and this Policy.
- By interacting with us, submitting information to us, you agree and consent to PLMP as well as to its respective representatives and/or agents (“Representatives”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to PLMP’s authorized service providers and relevant third parties in the manner set forth in this Privacy Statement.
- This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
- For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No.26 of 2012) (the “Act”). “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified – from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of PLMP or that which shall be collected by PLMP in the future.
- 2. Contacting the Data Protection Officer
- Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of PLMP, PLMP shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
- In accordance with the Act, PLMP has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that PLMP receives your complaints and enquiries regarding Personal Data, please send the name via email to any of our Data Protection Officer at firstname.lastname@example.org.
- Should you not wish PLMP to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.
- 3. Statement of Practices
Types of Personal Data Collected:
PLMP may collect from you, through various means, including via our websites, enquiry forms, smart phone applications, marketing events such as exhibitions and any forms used by PLMP from time to time, some or all of the following Personal Data (as and when if required):
- Name (first and surname);
- Date of Birth;
- NRIC Number;
- Passport Number;
- Residential Address;
- Bank Account Number;
- Credit Card Number;
- Phone number (including mobile);
- Email address; and
- Proof of source of funds
Purpose of Collection of Personal Data
- To operate, improve, personalise the Site;
- Communicate with Users regarding Site updates;
- Provision of Services and information related to the Site;
- To send relevant educational content and marketing/advertising information from PLMP or on behalf of PLMP partners;
- Development and research of new services;
- Coordination with third party institutions (Monetary Authority of Singapore, and the like);
- For system administration and to report aggregated statistical information about browsing patterns and actions which do not identify any individual; and
- To administer the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- Advertisers: PLMP do not control the practices of the advertisers on their sites. When you click on links and/or ad banners that take you away from our Sites to third-party websites, you will be subject to that party’s privacy policies.
- Information related to the status of use: PLMP will collect information related to the devices you use for accessing the Site as well as information from such devices. This includes IP address, type of browser and device, web pages that you visited prior to accessing PLMP 's site, and personal identification information related to the devices being used. Furthermore, there may be cases where the devices being used (depending on the setting) may transmit position information to the Site.
Disclosure of Personal Data:
PLMP may disclose your Personal Data to the following third parties:
- Relevant authorities;
- Regulators and law enforcement officials;
- Third Party service providers and consultants;
- Credit, debit and charge card companies, banks and other entities processing payment;
- Potential buyers or investors of PLMP;
- Any online/offline data storage facility provider working with PLMP; and
- Any agent of subcontractor acting on PLMP’s behalf for the provision of PLMP’s servicers
PLMP may in certain cases share personal information with others as described below.
- Advertisers: When you are exposed to an advertisement through the Services, PLMP may provide your personal information (such as name, specialty, and country of residence) and information about your engagement with the Services (e.g., whether you viewed, interacted with or requested information about promotional content) to advertisers and their agents or potential advertisers and their agents. Additionally, when you become a registered user of the Services, we may provide your personal information to potential advertisers and their agents.
We will NEVER provide these Advertisers with your personal contact information such as email, phone number or mailing address without your consent.
- PLMP Survey: Generally, these surveys provide specific feedback using aggregated, de-identified data to third parties used to analyze trends and statistics for marketing, research, and development purposes, and neither your identity nor your specific feedback is shared with third parties. However, under the following circumstances, your identity may be shared with third parties and/or associated with specific feedback: (i) when we have your permission, (ii) when we match user information with such third party’s data, and (iii) when we believe in good faith that the law requires it. In all circumstances, the privacy of our User is protected, and if such sharing is permitted or required, your answers and identity will remain confidential.
3.1 Possibility of disclosure of information
- To the extent that PLMP is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend PLMP legal rights;
- To the purchaser (or prospective purchaser) of any business or asset which PLMP is (or is contemplating) selling;
- To any person and/or entity for the purpose of processing such information on PLMP behalf;
- To any third party that purchases PLMP;
- To prevent and/or protect a person from death or serious bodily injury;
- With your consent; and
- For the purposes of disaster recovery
Optional Provision of Personal Data:
3.2 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve PLMP services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent PLMP from providing the service to you.
- 4. Transfer of Personal Data Overseas
Your Personal data may be processed by PLMP, its affiliates, agents and third parties providing services to PLMP, in jurisdictions outside of Singapore. In this event, PLMP will comply with the terms of the Act and will, with all reasonable endeavours, ensure that such affiliates, agents and third parties do the same.
- 5. Accuracy of Personal Data
Where possible, PLMP will validate data provided using generally accepted practices and guidelines. In some instances, PLMP is able to validate the data provided against pre-existing data held by PLMP. In some cases, PLMP is required to see original documentation before we may use the Personal Data. To assist in ensuring the accuracy of your Personal Data in the possession of PLMP, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
- 6. Protection of Personal Data
PLMP uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside of PLMP, other to you or as described in this Policy. However, PLMP cannot ensure or warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any PLMP’s physical, technical, or managerial safeguards.
- 7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
- Check whether PLMP holds any Personal Data relating to you and, if so, obtain copies of such data; and
- require PLMP to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 PLMP reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to PLMP or if you wish to check on the manner in which PLMP uses and processes your Personal Data, PLMP’s security procedures mean that PLMP may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC or Passport of FIN number. You must therefore keep this information safe as you will be responsible for any action which PLMP takes in response to a request from someone using your details.
- Storage and Retention of Personal Data
However, in the foregoing case, please take note of the following points:
(1) it may take some time to delete the information of User from the PLMP server and its backup storage;
(2) PLMP may in certain cases retain the information of User due to legal obligations, for dispute resolution, or upon enforcement of the written consent regarding PLMP; and
(3) PLMP may anonymize personal information and permanently retain the same for the purpose of research, and the like.
- Do Not Call Registry (the “DNC”)
- Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by PLMP. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. PLMP does not share your Personal data with third party websites. PLMP is not responsible for the privacy and conduct practices of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
12.2 PLMP will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to PLMP website.