Privacy Policy
Welcome to use our Services (as defined below) run by Spectrum One Pte Ltd and its affiliates (individually and collectively, "SpeedCard", "we", "us" or "our"). SpeedCard takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our website, software and mobile application (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.
PERSONAL DATA
- As used in this Policy:
- “Users", “you” or “your” refers to a user (whether registered or not) of the Services individually and collectively.
- “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.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.
- By using the Services, registering for an account with us, visiting our Platform, purchasing or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the Privacy Laws or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the Services requested by you;
- managing, operating, providing and/or administering your use of and/or access to our Services (including, without limitation, remembering your preference), as well as your relationship and user account with us;
- for identification, verification, due diligence, or know your customer purposes;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- maintaining and administering any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
- contacting you or communicating with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services;
- allowing other users to interact, connect with you or see some of your activities on the Platform, including to inform you when another User has sent you an updated card via the Platform or connected with you using the social features on the Platform;
- processing payment or credit transactions;
- conducting research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling);
- for marketing and advertising, and in this regard, sending you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom we may collaborate with) that we (and/or our affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters or marketing materials from us and from our related companies;
- preventing or investigating any actual or suspected violations of our Terms of Services, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- responding to any threatened or actual claims asserted against us or other claim that any content violates the rights of third parties;
- storage, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
- dealing with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves us as a participant or involves only a related corporation or affiliate of SpeedCard as a participant or involves SpeedCard and/or any one or more of SpeedCard's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
- 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;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated 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;
- any other incidental business purposes related to or in connection with the above;
- any other purposes which we notify you of at the time of obtaining your consent.
- We may disclose your personal data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
- 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 a contract with you)
- If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your SpeedCard account to your Social Media Account or use any SpeedCard social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times.
COLLECTION OF OTHER DATA
- Your device sends information which may include data about you that gets logged by a web server when you browse our Platform. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site.
- Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.
- As when you view pages on our website or mobile application, when you watch content and advertising and access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time.
- We or our authorized service providers and advertising partners may from time to time use "cookies" or other features to allow us or third parties to collect or share information in connection with your use of our Services or Platform. These features help us improve our Platform and the Services we offer, help us offer new services and features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that record data about computer or device, how and when the Services or Platform are used or visited, by how many people and other activity within our Platform. We may link cookie information to personal data.
- You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Platform or the Services.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
- In compliance with the applicable Privacy Laws, we may collect, use or disclose your personal data without your consent for the legitimate interests of Spectrum One Pte. Ltd. or another person. In relying on the legitimate interests exception of the Privacy Laws, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
- In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- Fraud detection and prevention;
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis.
The purposes listed in the above clause 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.
WITHDRAWING YOUR CONSENT
- 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 collecting, 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 our Data Protection Officer at the contact details provided below.
- 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. In general, we shall seek to process your request within thirty (30) business days of receiving it.
- 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 in the manner described in clause [16] above.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. In general, our response will be within twenty (20) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Privacy Laws).
PROTECTION OF PERSONAL DATA
- 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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password (OTP)/2 factor authentication (2FA)/multi-factor authentication (MFA) to secure access, and security review and testing performed regularly.
- 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.
ACCURACY OF PERSONAL DATA
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES
- WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Platform and other Users may also post links via the Platform which we have no control over. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our Users. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Platform) may not be received by us.
- We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We may transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Privacy Laws.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, pls use the platform feedback channel.
EFFECT OF POLICY AND CHANGES TO POLICY
- 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.
- We may revise this Policy from time to time without any prior Policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : |
27/03/2022 |
Last Updated : |
27/03/2022 |