This Data Protection Policy (“Policy”) outlines how Lendingpot Private Limited and/or its related corporations and/or affiliates (“we”, “us”, or “our”, “Lendingpot”) may collect, use, store, disclose or otherwise process personal data you may provide to us when you access and use Platform and Service. This Policy is an integral part of, and must be read with, our Website Terms of Use and all other policies, procedures and rules published on this Platform, as may be amended from time to time. Unless otherwise stated herein, capitalised words, phrases or terms that appear hereinafter shall have the same meanings as they have been defined or described in the Website Terms of Use as may be updated or amended from time to time.
“You” or “Your" means users or persons who access our Platform.
“Relationship Managers (“RMs”)” means sales representatives of third party financial institutions or banks who are connected with you (if applicable).
The Policy supplements, but does not supersede or replace, any other consent that you may have previously provided to us in relation to your personal data. It also does not affect any rights that we may have under relevant Singapore law, including the Personal Data Protection Act 2012 and its regulations (collectively, the “PDPA”), in connection with the collection, use, and/or disclosure of your personal data.
Personal Data
1. As used in this Policy:
“personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access;
"Platform" means our platform, and any websites, any mobile application operated by us or linked to our platform, or any page thereof; and
"Services" means such service that we may provide on our Platform.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and contact information such as your address, email address and telephone number.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Storage and Use & Disclosure of Personal Data
4. We may collect personal information that can identify you (including but not limited to your name and e-mail address, contact details, residential address, gender, age, date of birth and identity card/passport details) as well as other information that does not identify you (including but not limited to specimen signatures, voice recordings of conversations or occupation). When you provide personal information through the Platform or otherwise provide to us, the information may be sent to servers located in Singapore or such other country or territory as may be permitted by law.
5. We use various technologies to collect information from you and about your activities on our Platform. We automatically collect information from your browser when you visit our Platform. This information may include your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us and the referring website address.
6. We or our third party service providers may use standard Internet technology, such as web beacons and other similar technologies, to track your use on the Platform. We also may include web beacons or similar technology in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the Services we offer to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
7. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) sending marketing information about our goods or services including notifying you of our marketing events and other promotions;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) any other specific purposes for which you have provided the information;
(h) transmitting to any unaffiliated or affiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
(i) any other incidental business purposes related to or in connection with the above.
(j) engaging third party software providers to collect information about the use of our websites, such as pages visited, links clicked and non-sensitive text entered and mouse movements. This will help us understand your needs better and optimize our services.
8. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;
(b) in connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy;
(c) in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us;
(d) when we believe disclosure is appropriate in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to comply with the relevant listing rules of the applicable stock exchange; or to enforce our Website Terms of Use, or other agreements or policies including this Policy; and/or
(e) to third party service providers or agents such as RMs and other organisations we engage to perform any of the functions listed in clause 7 above for us.
9. You agree that we are not responsible for the actions of these third parties with respect to their use and handling of your personal data and that you shall have no recourse whatsoever against us in respect of these third party actions. If you want to learn more about the privacy practices of these third parties, you agree that you will do the necessary to visit the websites of those third parties or perform such further understanding as you may deem necessary. These entities or their servers may be located either inside or outside Singapore. We hereby expressly exclude any liability as to the inappropriate usage of your data by these third party service providers and agents.
10. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Withdrawing Your Consent
11. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to dpo@ifscapital.com.sg.
12. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
13. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.
14. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
Protection of Personal Data
15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
16. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. In the event of a data breach, we will notify the affected individuals as soon as practicable (no later than 72 hours) after establishing that the data breach is likely to result in significant harm or impact to the individuals to whom the information relates.
Accuracy of Personal Data.
17. Where you provide personal data to us, you shall take reasonable effort to ensure that the personal data is accurate and complete before providing the same to us. Lendingpot shall put in place adequate measures to ensure that the personal data in its possession or control remain or is otherwise accurate and complete. In any case, Lendingpot shall take steps to correct any errors in the personal data, as soon as practicable upon your written request.
Retention of Personal Data.
18. Lendingpot shall not retain personal data (or any documents or records containing personal data, electronic or otherwise) for any period of time longer than is necessary for business or legal purposes.
19. Lendingpot shall, upon your written request: (a) return to the you, all personal data; or (b) delete all personal data in its possession, and, after returning or deleting all personal data, provide you with written confirmation that we no longer possess any personal data. Where applicable, Lendingpot shall also instruct all third parties to whom it has disclosed personal data for the purposes of this Policy to return to Lendingpot or delete, such personal data.
Our Use of Cookies
20. By using our website with your browser settings adjusted to accept cookies you consent to our use of cookies and other tools to provide the products and services available on our website.
21. Cookies are small text files that may be placed on your web browser when you visit our website. Cookies allow your browser to remember some specific information which the web server can later retrieve and use. We do not use cookies to store any personal information that could be read or understood by others.
Your Rights in Respect of Your Personal Data
22. Subject to applicable guidelines issued by the Personal Data Protection Commission in Singapore on access and correction obligations (as may be amended from time to time and if applicable), you have the right to access, update or correct the personal data we hold about you or withdraw your consent to the use, collection and disclosure of your personal data. If you have any questions about this Policy, or if you wish to access, update or correct your personal data or withdraw your consent to the use, collection and disclosure of your personal data, please email dpo@ifscapital.com.sg. We have the discretion to charge a small fee for this service. Please note that if you withdraw consent, we may still be permitted to hold, use or disclose some of your information as required or permitted by law.
Effect of Policy and Changes to Policy
23. This Policy is intended to cover collection of information on the Platform from persons in Singapore. If you are using the Platform from outside Singapore, please be aware that your information may be transferred to, stored and processed in Singapore (or such other country or territory as may be permitted) where our servers are located and our central database is operated. The data protection and other laws of Singapore and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our Services, you understand that your information may be transferred to our systems and facilities and those third parties with whom we share it as described in this Policy.
24. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
25. We may from time to time update the Policy without any prior notice to you. We may update the Policy to ensure that the Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of the Policy shall apply. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued access to and use of our Platform and Services constitutes your acknowledgement and acceptance of such changes. If you disagree with any part of the Policy, you must immediately discontinue your access to, or use of, the Platform and our Services.
Last Updated: 24 January 2020
