Privacy Statement

Your privacy is important to us. This Privacy Statement sets out how Shareable Assets Pte.Ltd. (“SA”) comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”).

We also want you to understand the way in which we collect, use, disclose and/or retain your Personal Data.

You agree and consent to SA and our authorised service providers and third parties to collect, use and disclose and/or retain your Personal Data in the manner set forth in this Privacy Statement.

This Privacy Statement supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/or retention of your Personal Data.

From time to time, SA may update or amend this Privacy Statement to ensure that it is consistent with markets development and the regulatory changes. Should any revision(s) be made to this Privacy Statement, updates will be published on our public website (www.shareableasset.com). Any use of the Site after such amendment shall be deemed acceptance of the amended Privacy Statement in its entirety.

This Privacy Statement forms a part of the Site’s Disclaimers, Exclusion of Liability and Terms of Service (collectively, “Conditions”) governing your relationship with us and should be read in conjunction with such Conditions. In the event of any inconsistency between the provisions of this Privacy Statement and the Conditions, the provision of the Conditions shall prevail.

1. Your Personal Data

SA collects information about how to contact you, your interest and relationship with SA, including the products and services which are relevant to you. This Statement applies to any individual’s Personal Data which is in our possession or under our control.

“Personal Data” is data that can be used to identify a natural person. Some examples of Personal Data that we collect are:

• your name, NRIC, passport or other identification number, telephone number, mailing address, email address and any other information relating to you which you have provided SA in your interaction with SA;
• your payment related information, such as your bank account details;
• your employment history, education background, and income levels;
• your specimen signature(s)
• images and voice recordings of our conversation with you;
• information about your use and interaction of the Site and/or services including cookies, Internet Protocol (IP) address, account registration details, computer and connection information, device capability, bandwidth, statistics on page views, frequency of use and traffic to and from the Site;
• information obtained from mobile device with your consent (e.g. device location and information).

2. Collection of Your Personal Data

We may collect your Personal Data in connection with or from you through the following ways:

• when you register with us as a user;
• when you access or use the Site or perform an online transaction;
• communicate with SA or any of its officers, employees or agents whether through written, published or electronic means, the telephone or otherwise;
• when you respond to our request for additional Personal Data;
• when you ask to be included in an email or other mailing list;
• when you submit your Personal Data to us for any other reasons.

3. Purpose For The Collection, Use and Disclosure of Your Personal Data

Generally, SA collects, uses and discloses your Personal Data for the following purposes:

• to provide products and services to you;
• to communicate to you on matters relevant to your relationship with or interest in SA;
• to selectively send you information about our products, services, activities and/or events that may be relevant to you;
• to assess and process applications, enquiries or requests from you or our customers;
• to address or investigate any complaints, claims or disputes;
• to verify your identity;
• to prevent and detect crime, including conducting screenings and due diligence in accordance with applicable laws and regulations and SA internal policies and procedures which include but not limited to those relating to ‘know your client’ and ‘anti-money laundering/ countering financing of terrorism’;
• to enable SA to comply with applicable all applicable rules, laws and regulations, or to assist in law enforcement and investigations by relevant authorities;
• to comply with financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
• to assess and improve the products and services that you use or may use;
• to conduct audits, reviews and analysis of SA’s internal processes, for action planning and managing commercial risks;
• to enable any takeover and acquisition, where SA or any of its assets are involved in any takeover and acquisition.
• to manage our infrastructure and business operations and complying with internal policies and procedures
• to protect and enforce SA’s contractual and legal rights and obligations; and
• any other purposes relating to any of the above.

4. Disclosure of Information

SA may disclose your Personal Data to third parties with your consent for the purpose for which the information was collected or to be used, and any other reasonable ancillary purposes, for legal reasons, or where permitted under the PDPA and other applicable laws, such as in response to law enforcement agencies.

When we disclose your Personal Data to such parties, we will take appropriate steps to ascertain whether, and to require them to ensure that any Personal Data disclosed to them are kept confidential and secure.

If SA transfers your Personal Data to countries outside Singapore, it will be done in accordance with relevant provisions under Singapore laws and regulations. SA will take appropriate steps to ascertain whether, and to ensure that, the recipient of the Personal Data who is located outside Singapore is legally obliged to provide to the Personal Data a comparable standard of protection.

SA does not sell Personal Data to any third party.

5. Marketing Communications

From time to time, SA may use your Personal Data to selectively contact you and/or send you information about SA’s products, services and/or events that may be relevant to you.

You can let us know at any time if you no longer wish to receive marketing materials by informing us through the unsubscribe link contained in email communications or contact us. (Please see the “How To Contact Us” section below).

Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.

6. Cookies

SA may collect certain information from you without you actively providing the information when you navigate the Site. Our websites and mobile applications (“apps” or an “app”) use cookies. A cookie is a small text file placed on your computer or mobile device when you visit a web site or use an app. Cookies collect information about users and their visit to the web site or use of the app, such as their Internet protocol (IP) address, how they arrived at the web site (for example, through a search engine or a link from another web site) and how they navigate within the web site or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our web sites and apps and to compile statistics about activities carried out on our web sites and/or through our apps.

A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our web site but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the web site.

You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your web site visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our web sites.

7. Third-Party Sites

Our Site may contain links to other websites operated by third parties. We are not responsible for the privacy practices of such websites operated by third parties even though it is linked to our Site.

We encourage you to learn about the privacy policies of such third party website(s) by checking the statement of each site and contact its owner or operator if you have any concerns or questions.

8. Retention of Your Personal Data

Your Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.

9. Security Measures

SA has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of Your information.

10. Accuracy of Your Personal Data

We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up-to-date. You may also keep us informed when there are any updates to your Personal Data by contacting us directly.

11. Withdrawal of Consent

If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Privacy Statement, you may contact us. (Please see the “How To Contact Us” section below)

It is important to note that SA uses your personal information to provide you with the products and services you wish to use. SA also complies with various regulatory requirements in doing so, including the requirements for customer due diligence. Withdrawal of consent to any or all collection, use or disclosure by SA of your personal information, depending on the nature of your request, may cause SA to be no longer in a position to continue to provide products and services to you.

12. Access or Correction

You may request access or make corrections to your Personal Data held by SA. SA may charge a fee for processing your request for access. Such fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.

Please contact us (please see the “How To Contact Us” section below) for details on how you may request access or correction to, or exercise your rights with respect to the processing of your Personal Data.

13. Data Portability

You may request and give us your consent to transmit your personal data that is in our organisation’s possession or under our control, to another organisation in a common machine-readable format.

14. How To Contact Us

If you believe that information we hold about you is incorrect, or if you have concerns or further questions about how we are handling your Personal Data, please contact our data protection officer at dpo@shareableasset.com