1. Collection, Use and Disclosure of Personal Data
We may collect the following personal data from you:
Your account information. We collect your identification number (NRIC, FIN, or passport), address, date of birth, email address and telephone number, as well as service-related information such as bank and credit card details when you register with us. You may provide us with the telephone numbers in your mobile address book, including those of both users and your other contacts. You confirm that you are authorised to provide us with such numbers;
Device and connection information. We collect device-specific information when you access or use our Platform. This includes information such as the hardware model, operating system information, browser information, IP address, mobile network information including phone number and device identifiers;
Usage and log information. We collect service-related, diagnostic, and performance information when you use our Platform. This includes information about your activity (such as how you use our Platform, how you interact with other users using our, etc), log files, and diagnostic, crash and performance logs and reports;
Your attendance records and usage of our Platform. We collect your attendance records, progress, and completion of our online lessons, seminars, webinars, events, or service offerings.
Your usage of our Platform. To improve our performance and for quality and training purposes, we may retain records of your voice, likeness, and image (e.g., in the form of photographs or video and audio recordings) while you use our Platform;
Voluntarily provided information. We collect voluntarily provided information to us, such as when you register with us or post or share any content on the Platform;
Your messages. When you message us or other users on the Platform, we retain your messages (including your note or recording of a call to us, email, or letter you sent us or other records of contact with us, chats, photos, videos, voice messages and files) on our servers in the ordinary course of providing our services to you. To improve performance and deliver messages more efficiently, such as real-time market data, we may retain such content on our servers for a longer period;
Customer support and feedback. We collect copies of your messages and how to contact you to provide customer support when you contact us with queries or provide feedback to us on your use of our Platform;
Transactional information. If you pay for our services, we may receive information and confirmations, such as payment receipts, including from app stores or other third parties processing your payment;
Information others provide about you. We may receive information that other people provide to us, which may include information about you. For example, when other users you know use our Platform, they may provide your telephone number from their mobile address book (just as you may provide theirs);
Third-Party providers. We work with third-party providers to help us operate, provide, improve, understand, customise, support and market our Platform. These providers may provide us information about you in certain circumstances; and
Third-Party services. We may allow you to use our Platform in connection with third-party services. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
We may collect, use and/or disclose your personal data for the following purposes:
setting up your registered user account and profile on the Platform;
to provide and improve our Platform, including informing you of any change or updates to our Platform;
to organise the data to allow you to view, manage your information, or to help you visualise your data;
for targeted online marketing;
for accounting, billing, and verification purposes;
to contact you regarding any complaints, feedback, queries, requests, claims or disputes;
to facilitate investigations into or to take action regarding any suspicious or illegal activity on the Platform;
for internal review, business improvement, and quality and training purposes;
for internal administrative and management purposes;
where required by any act, statute, law, or regulation, rules, directives, or by the order of a government authority or a court or tribunal of competent jurisdiction;
such other purposes as consented to by you; and
any other purpose reasonably related to the aforesaid.
We may disclose your personal data to our partners, service providers, contractors, select vendors and affiliates whom we have engaged to provide our services, to maintain the Platform or to protect the security or integrity of the Platform and our databases. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information.
We may also share your personal data with our affiliates, subsidiaries and parent companies, industry regulators and other government organisations as required by local law and regulations, financial institutions, research institutions for market analysis purposes, or other third parties in our partner network who we work with to deliver our services. In some cases, the information will be encrypted, anonymised or aggregated, whereby all identifying information has been removed, such that the remaining data does not identify any person.
Please refer to Clause 10 below for details on how you can contact us should you decide to withdraw your consent.
6. Special Information for EU Users (applicable to EU Data Subjects only)
The processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). This section summarises our grounds for processing personal information under the GDPR and the rights of EU users as relates to our handling of personal information.
If you are a user in the EU, you can exercise the following rights with respect to our handling of your personal information:
you have the right to request access to the information that we have about you and how we use that information.
you also have the right to receive a copy of the information that we collect about you.
if we have information about you that you believe is inaccurate, you have the right to request for your information to be corrected.
you also have the right to restrict how we process the information about you. This means we are permitted to store the information but not further process it.
you may also request that we:
provide a detailed explanation regarding the information we have collected about you and how we use that information;
provide a copy of the information that we have collected about you; and
correct any inaccurate information that we have about you by either changing your account details within the app or contacting us at
[email protected].
you have the right to delete your account.
We retain user profile and other information for as long as you maintain your account. We retain transaction, location, usage, and other information for as long as is reasonably necessary for legal or business purposes in connection with regulatory, tax, insurance, or other requirements in the places in which we operate. We take steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.
You may request deletion of your account at any time. We may retain certain information about you as required by law and for legitimate business purposes permitted by law. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above.
We may also retain certain information if necessary, for legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if we shut down a user’s account because of unsafe behaviour or security incidents, we may retain certain information about that account to prevent that user from opening a new account in the future.
You have the right to object to our processing of personal data, including for marketing purposes based on profiling and/or automated decision making. We may continue to process your information notwithstanding the objection to the extent permitted under the GDPR.
You also have the right to request that we transfer the personal data that we have collected to another organization, or directly to you, under certain conditions.
Users in the EU also have the right to file a complaint relating to our handling of your personal information. You may submit your questions, comments, or complaints to our Data Protection Officer. Please contact us at
[email protected].
Users outside the EU may also request access, correction, deletion, or copies of their personal data.
The GDPR requires that companies processing the personal data of EU users do so based on specific legal grounds. As described below, we process the information of EU users based on one or more of the grounds specified under the GDPR:
If the processing is necessary to provide the services and features you request, we must collect and use certain information to provide our services. This includes (a) user profile information that is necessary to establish and maintain your account, including to verify your identity, enable communications with you, orders and accounts and to enable you to make payments, (b) transaction information, which is necessary to generate and maintain in connection with your use of our Platform and (c) usage information, which is necessary to maintain, optimise and enhance our services.
We may process your personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.
We collect and use personal information to the extent necessary for our legitimate interests which include collecting and using information:
to maintain and enhance our user’s safety and security. For example, we may collect background check information (where permitted by law) to prevent unsafe users from providing services through our apps. We also use personal information to prevent the use of our services by users who have engaged in inappropriate or dangerous behaviour, such as by retaining information of banned users to prevent their use of our Platform;
to prevent, detect and combat fraud in connection with the use of our Platform. For example, we use user profile, location, device, and usage information, to identify and prevent circumstances when users attempt to defraud us or other users;
to inform law enforcement officials regarding criminal acts or threats to public safety;
to provide customer support;
to optimise our Platform and develop new services;
for research and analytical purposes. This includes analysing usage trends to improve the user experience and enhance the safety and security of our Platform;
for direct marketing purposes. This includes analysing data to identify trends and tailor marketing messages to user needs; and
to enforce our Terms of Use.
We collect and use personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. We may also process personal information when necessary in regard to the substantial public interest, on the basis of applicable laws.
We are subject to the legal requirements in the jurisdictions in which we operate that require us to collect, process, disclose and retain your personal data. We use your information to comply with such laws to the extent they apply to your use of the Platform.
We may share your information with law enforcement, or requests by third parties pursuant to legal processes.
We may collect and use information based on your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires the collection or use of the information we collected or used based on consent.
We rely on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you.
