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Privacy Policy

Updated as of 21 March 2022

 

Your personal data is important to us

Your personal data is important to CardsPal (“CardsPal”, “us”, “our” and/or “we”), and it is our policy to respect and protect your personal data. This privacy policy (“Policy”) outlines how we collect, use, store, process, manage and protect the personal data you may have provided to us that may be through our CardsPal’s website (“Site”), through any engagements with us, the use of our mobile application (“App”) and/or the CardsPal for Business merchant platform (“Platform”).

For the purposes of this Policy, “personal data” shall mean data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access.

 

Introduction

Please read this Policy carefully. By registering an account with us, accessing or using our Site, App and/or our Platform, you acknowledge that you have read and agree to this privacy policy to us collecting, using, storing, processing, and/or disclosing your personal data in accordance with this Policy.

We commit ourselves to a high standard for data protection. Should you not agree or consent to the processing of any of your personal data as described in this Policy, please do not register an account, access, use our App, Site and/or our Platform, or use any of our services.

This Policy should also be read in conjunction with our Terms of Use and any other privacy notices, consent clauses or contractual provisions that may apply in respect of the collection, use, storage, disclosure and/or processing of your personal data (i) during the provision of our services, your usage of our Site, App and/or Platform, or (ii) when you participate in any promotions, discounts or contests that we may run. It is not intended for this Policy to override such notices or clauses unless we expressly state otherwise.

 

How we may have come to receive your personal data

The following are some instances where we may have come to receive or collect your personal data:

– when you browse our Site, App and/or Platform, which includes through any cookies that we may have deployed in our site;

– when you enter into any agreements with us;

– when you register and open a user and/or a merchant account with us, and use any of our services;

– when you have any engagements, such as face-to-face meetings or physical interactions with any of our account or sales representatives;

– when a transaction is made for the purchase of any deals;

– when you use any of the features or play any of the games made available to you on the App;

– when you subscribe to any of our marketing collaterals or newsletters;

– when you engage with any of our customer service agents or representatives;

– when you participate or interact with us in any of our competitions, campaigns or promotions regardless of whether they are through the App or any other form of social media channels;

– when you write to us to make any complaints;

– when you submit your data, resume or CV in response to any job advertisements through our Site, external recruitment agencies or such other third-party job portals; and

– when you complete any surveys or provide any feedback.

If we ever receive your personal data from any third party or affiliates, we will only collect, store and use your personal data that is necessary for the purpose for which those third parties or affiliates are engaged, and to which was made known to you.

 

Cookies

We, our service providers, agents, partners and/or affiliates, may use “cookies” to allow us to collect certain information about your use of and access to our services and Site. “Cookies” are small text files placed into your computer by certain websites or files you open. They allow us to, amongst others, recognise a particular device or record information on how and when our services or Site are used or visited.

While these cookies may not necessarily collect information that directly identifies you as an individual, some cookies may contain information that could be treated as personal data. The data collected through the cookies will help us to conduct data analysis, keep track of the deals you purchased, to deliver content specific to your interests, or enable third-party advertising partners to send advertisements on sites you visit.

To help you better understand, we use the following cookies:

– essential: these are necessary cookies to help our website function properly and make a website accessible such as page navigation and access to secure areas of the website.

– analytics: these cookies help us understand how you interact with the Site, and the information here will help us improve our services and Site.

– advertising: these cookies are used to collect information on your visits to our website, the type of content you viewed or interacted with, and the data collected will enable our third-party providers and us to display advertisements relevant to your interests and browsing patterns.

We may also work with third parties who may place third-party cookies on the Site. These third parties include our partners and service providers, such as advertisers, search engine or analytics platforms that enable us to improve and personalise your experiences on the Site and deliver relevant content to you.

You can manage and delete cookies through your browser or device settings. You may refer to the links below for each browser’s guide on deactivating or deleting the cookies. However, please do note that changing and deleting certain cookies may affect the functionality of our Site and/or our services.

Chrome

Firefox

Microsoft Edge

Internet Explorer

Safari

 

Personal data we collect from you

The personal data we may collect depends on the products or services you use, and they include:

– contact information that facilitates communication with you, such as your name; gender, your mobile number, email address, or business-related information;

– the types of credit and/or debit cards which you may hold;

– technical data that may include device type, location details or data, internet protocol addresses, operating systems and platform, carrier details and cookies;

– profile related data, such as username, birth month, password, preferences, interests or feedback;

– usage data, such as how often and how long you use the App, search histories, past orders, and any other content that you interacted with while using the App or Platform;

– payment and transaction information, such as payment details, bank statements and/or bank account details (where such information may also be collected directly by our affiliates and/or third-party payment service providers for due diligence or KYC purposes);

– information or documents (such as passports, IDs etc.) which we or our third-party service providers may require for authentication purposes;

– marketing and communications data, such as preferences in receiving marketing messages or content from us and/or third parties;

– professional and employment-related data, such as education and employment history; and

– such other information you voluntarily disclose to us depending on the products, services, and/or promotions you use or subscribe with us.

The personal data you submit to us must be accurate and not misleading. You agree to correct any inaccuracies and keep your information updated by informing us of any changes. We reserve the right to request documentation to verify these changes.

 

How we use your personal data

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 and regulations. We will not sell, rent or give away any of your personal data to third parties for commercial purposes without your consent.

We may use, store and/or process your personal data for one or more of the following purposes:

– authenticating your credentials, verification, due diligence and/or KYC/KYB purposes;

– providing you with access to the App and the Site;

– managing, operating, providing and/or administering your use of our App, Services and/or our Platform, as well as maintaining your account and your relationship with us;

– to notify you of any service or Platform issues;

– to help facilitate any customer service, or respond or deal with any queries, complaints and/or feedback which you may have;

– providing you with products and services as subscribed to or requested by you;

– processing your applications for products and services, effecting payments from and to you, processing transactions and completing instructions or requests;

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

– to enforce our Terms of Use and CardsPal for Business Merchant Terms and Conditions, including any terms relating to our services and/or any other agreements you may have with us;

– to carry out investigations in the event of any actual or suspected breach or violations with our terms;

– to contact you or communicate with you through call, text, messaging, email or any such other means of communication;

– market research and surveys (including data analytics, product development and/or profiling) to improve our products and services;

– to send you mobile notifications of our promotions, discounts, Deals and/or exciting merchants near your location;

– marketing and advertising purposes, promotional events, competitions and lucky draws, and sending you any marketing or promotional information which we think you may find helpful or requested from us;

– for security and compliance, which include fraud prevention and detection;

– for evaluation of job applications and administer employment-related activities; and

– complying with and monitoring compliance with applicable laws and regulations, voluntary codes, internal policies (including our affiliates), contractual obligations (including between us and our affiliates) and other requirements.

 

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

– third parties and/or our affiliates anywhere in the world, including any officer, employee, agent or director of any affiliate for any of the purposes mentioned above;

– our joint venture partners, business alliance partners or other investors;

– our professional advisers and service providers to provide administrative, financial, legal, accounting, information technology, research or other services;

– a merchant or a member of a card association where the disclosure is in connection with the use of a card;

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

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

– third parties in connection with the purpose of any proposed investment, merger or acquisition or joint venture;

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

– anyone we consider necessary to provide services in connection with a product or service.

We may also transfer or permit the transfer of your personal data outside of your jurisdiction for any purposes set out in the Policy, but we will not share or permit such transfer unless such transfer complies with applicable data protection laws.

 

Access and Correction

You will have the right to request any information on the personal data you have with us. If you have an account with us, you can access and/or correct the personal data we have in our possession through the accounting settings in the App or Platform (as the case may be). If you do not have an account with us, you will have to submit a written request to us at privacy@cardspal.com, and we will arrange for the access or correction of your personal data subject to the verification of your identity.  We may charge you a reasonable administrative fee to process your requests. In compliance with any applicable privacy laws, we may also have a right to refuse to correct any of your personal data.

 

Withdrawal of Consent

You may choose to withdraw your consent for the use, processing, storage and/or disclosure of your personal data by sending an email request to us at privacy@cardspal.com.

Some of your personal data may be essential for us to continue to provide you with services or usage to the App and/or Platform. You may wish to note that if you decide to withdraw your consent to any of the above, there is a possibility that we may not be able to continue to provide you with our services or proceed to perform any part of a contract or agreement which we may have with you. In this regard, we shall not be liable to you for failing to perform any of our obligations.

 

Security

As mentioned above, your personal data may be transferred to, or stored at, a location outside of your country of residence, which may not have data protection laws. The security of your personal data is important to us. We have technical and organisational security measures in place to safeguard your personal data. When using external service providers, we will use reasonable endeavours to ensure they adhere to applicable security standards. We may do this through contractual provisions, including any required by a privacy regulator, ensuring a service provider has appropriate security and/or data protection certifications, and/or oversight of the service provider. Regardless of where personal data is transferred, we will ensure that personal data is kept securely.

However, while we strive to protect the security of your information, you will appreciate that it is not for us to perfectly secure your personal data from cyberattacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal data arising from such risks.

 

Retention

We retain your personal data in line with our legal and regulatory obligations and for business and operational purposes. In most cases, this will be for seven 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.

 

Your rights

We will not send you marketing material if you have specifically asked us not to do so. You have the right to opt-out of receiving marketing material at any time. You may choose to unsubscribe from receiving marketing materials at your email address at any time through the unsubscribe button in any email you receive from us. If you wish to opt-out of receiving marketing materials via means other than email, please get in touch with us at privacy@cardspal.com.

However, you may wish to note that it may take up to 30 calendar days for your withdrawal of consent to receive marketing materials to be reflected in our systems. Therefore, you may still receive marketing materials during this period. We will continue to use and process your personal data in accordance with this Policy.

 

Updates to this Policy

We may update this Policy from time to time, and the changes will be reflected on this page and shall take effect from the date they are placed on this site. Material changes may be notified to you. If permissible under local law, your continued usage of the App, Platform or our services shall be deemed to constitute an acceptance of the changes we made.

 

Third-party websites and services

Our app and site may contain links to third party websites or mobile apps (such as payment service providers to facilitate your transactions on our app). You agree and acknowledge that we do not operate or control such third-party websites or mobile apps and that this Policy does not apply to any information you give to these third-party websites or mobile apps.

Third-party websites, apps or service providers may require you to disclose personal information for your use of their services (for example, a payment service provider may require you to disclose personal identification information for verification purposes and payment information to facilitate your use of their payment services).

We encourage you to read the terms and conditions and privacy policy of any third-party website and app that you access before disclosing any information to these third-party websites or apps or using their services.

This Policy does not apply to any linked third-party websites and/or third-party service providers which we do not operate or control. Please refer to the relevant terms and conditions and privacy policies of these third-party websites and/or third-party service providers for further information on how they collect, disclose and use your data.

 

Contacting us

If you have any questions about our Policy, you may contact our Data Protection Officer at privacy@cardspal.com.