Data Privacy Policy

This Data Privacy Policy was last updated and revised on 16 August 2024.

Section 1: Data Privacy Principles

Transparency: We will be clear and transparent as to how we collect and use data, including providing data subjects with a statement of how we may use their data where required.

Fair and lawful usage: We will only collect, process and store data lawfully and where we have a legitimate reason to do so.

Limited purposes: We will collect and process data for specified and lawful purposes, and will not use it for further, incompatible purposes without first taking all steps necessary under applicable data privacy laws and regulations. This means we may also collect, use and disclose data without your consent where we are allowed to do so under an exception provided by such laws and regulations.

Data minimisation and adequacy: We will ensure our collection, retention and processing of data is proportionate. We will strike an appropriate balance to ensure that we process sufficient data to carry on our business and achieve any specified lawful purpose, while making sure that we do not collect, retain or process excessive amounts of data.

Data quality and accuracy: We will maintain appropriate standards of data quality and integrity, and we will implement policies in respect of data accuracy, including taking steps to avoid becoming out of date where appropriate.

Data security and retention: We will ensure that appropriate processes are put in place so only our colleagues with a business requirement to access such data are authorised and able to do so. If there is a data breach involving your personal data, we will notify you without undue delay where we are required to do so under Section 26D(2) of the Personal Data Protection Act. We will retain data securely, implement appropriate data retention policies, and we will dispose of data securely once it is no longer required.

Training and awareness: We will ensure that our colleagues with access to data are trained appropriately on their obligations regarding those data.

Data subject rights: We will ensure that data subjects' rights are observed in accordance with applicable data privacy laws and regulations, including any timeline establish thereby.

Third parties: Where we appoint a vendor, we will require them to apply standards equivalent to the Data Privacy Principles. We will only disclose data to governmental or judicial bodies or law enforcement or agencies or our regulators where this is allowed by applicable data privacy laws and regulations, or otherwise required by applicable laws and regulations.

Data transfers: Where we voluntarily transfer data to third party or to another jurisdiction, we will ensure that the data transfer is lawful and that the recipient is required to apply the same, or equivalent, standards as the Data Privacy Principles.

Section 2: Data Privacy Notice

Your data (including personal data) is important to us. Read this notice to find out how we collect, store, use and share your data.

1. How do we collect and store your data?

We collect your data:

when you interact with us
when you visit our websites or use our services
from other people and companies.

We need to collect your data for the purposes set out in this notice. If you do not provide us with your data, we may be unable to provide services to you. We store your data in physical or electronic form on our systems, our service providers’ systems (including third-party cloud providers) locally or overseas. We comply with the laws of Singapore.

2. What we use your data for?

We use your data:

to provide services to you
to market services to you if you have given us your consent to do so
to comply with laws, regulations and requirements, including our internal policies
to improve our services and marketing for the other purposes set out in sub-section A.

3. Who we share your data with?

We may share your data:

with other companies and third parties who help us to provide services to you
with third parties who you consent to us sharing your data with
with local or overseas law enforcement agencies, industry bodies, regulators or authorities
with the other third parties set out in sub-section C.

We may share your data locally or overseas.

4. How can you withdraw your consent, or access and correct your personal data?

If you:

would like to withdraw your consent to any use of your personal data as set out in this Privacy Policy; or
would like to obtain access and make corrections to your personal data records;

You may email us at hello@ipreciate.co. We will try to comply with your request as soon as reasonably practicable.

Sub-Section A: Data Use

Your data may be used to:

assess you for services and enable us to provide them
manage our business and to comply with our internal policies
design and improve our services and marketing
as described in sub-section D, provide you with marketing information
comply with compulsory requirements such as legal, tax, regulatory, sanctions or market requirements in Singapore and overseas
comply with requests made by different bodies or authorities such as legal, regulatory, law enforcement,
government and tax authorities in Singapore and overseas
allow any company that we transfer our business or assets to, to evaluate our business and use your data after any transfer
any other uses for which you have given consent
any purpose relating to any of the purposes above.

Your Rights

You can request access to your data, correct data that we hold about you or withdraw consent to use of your data. If you withdraw consent, we may be unable to continue providing our services to you.

Sub-Section B: Data Collection And Storage

We may collect:

data that you give to us such as your contact and identification details
your geographic data and location data based on your mobile or other electronic device.

If you don’t give us data or if you withdraw your consent to any use of your data then we may be
unable to provide our services. We may also collect data about you from third parties such as:

people who act for you or who you give consent to transfer data to us
publicly available sources and agencies that collect data which they summarise and use to create statistics
people who you deal with through our services.

We may also generate information about you:

based on the analysis of your interactions with us
through the use of cookies and similar technology when you access our website. See our cookies policy below.

Storing Your Data Overseas

We may transfer and store your data overseas, including places that do not have the same level of protection for personal data.

Protecting Your Stored Data

While we store it, your data is protected by physical, electronic and procedural safeguards and governed by the laws of Singapore (including the Personal Data Protection Act). We, along with our third-party service providers, that receive your data are required to comply with strict measures to protect your data. Our service providers may be required by law (which may include court orders, requests from governmental or regulatory authorities, police investigations and criminal prosecutions) to disclose your data to other third parties.

Providing Data About Others

If you provide data to us about another person, you must make sure that you have obtained written consent from such person and that you have retained proof of these consents. You must provide us with such proof if we request for it.

Sub-Section C: Data Sharing

We share your data with:

third parties who provide services to us and other third parties we work with
any bodies or partnerships between law enforcement and the financial sector or authorities, such as legal, regulatory, law enforcement, government and tax authorities in Singapore or overseas or anyone acting for them
any third party to whom we may transfer our business or assets to
partners and providers of reward, cobranding or loyalty programs, charities or non-profit organisation
social media advertising partners (who can check if you hold an account with them for marketing purposes and the partner may then use your data to send our adverts to you and advertise to people who have a similar profile to you)
any other third parties whom you have consented to us sharing your data with.

We may share your anonymised data with other parties not listed above. If we do this you would not be identifiable from this data.

Sub-Section D: Direct Marketing

This is when we use your personal data to send you details about products, services and offers provided by us or our co-branding partners, rewards, loyalty privileges or charities. This includes providing you with personalised marketing (including by aggregating your data with data of others or through social media advertising partners). We will only do this where you have consented (including by you giving us an indication of no objection where this is permitted by law). We may use your contact details and data such as your demographic information, the products and services that you are interested in, location data, social media data, analytics and information from third parties when we market to you. You can tell us any time if do not want to receive marketing from us by clicking our “unsubscribe” links in our emails or by contacting us (it may take a short time to update our records to reflect any change). We will need to get your separate consent to share your data with third parties for them to market their products and services to you.

Section 3: Website Policy

Cookies: We will assess your usage and activities on our website to collect and use information (i) to find out more about users of our website, including user demographics and behaviour and usage patterns, (ii) for more accurate reporting, and (iii) to provide you with personalised marketing based on your individual interests, if you have given us your consent to do so.

Third Party Sites: Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of such websites.

This Data Privacy Policy will apply for as long as we store your data. We will review this Data Privacy Policy from time to time and may make changes.