Data & Privacy Policy

“Personal Data” refers to personal information such as your name, e-mail address, residential address, phone number, credit card information and other data, whether true or not, that identifies you as an individual.

We are committed to protecting your privacy and complying with the Personal Data Protection Act 2012 of Singapore (“PDPA”). Consequently, we will only collect, record, hold, store, disclose, transfer and use your Personal Data as outlined in this privacy policy (the “Policy”).

All references to “using the Site” includes access to and/or use of Finjaro (collectively, the “Site”) and our services and functions offered in this Site, including subscriptions and add-on purchases to use our Software.

If you have any questions, comments, suggestions or complaints, please contact our Data Protection Officer at the following address: dpo@finjaro.com

Your use of the Site is subject to our Terms of Service. For more details, please refer to our full Terms of Service.

We reserve the right to modify and change the Policy at any time to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. Any changes to this Policy shall be published on the Site. You are deemed to be aware of and bound by any changes to the Policy upon the publication of such changes on the site.

1. How We Collect Your Personal Data

We collect Personal Data when:

You voluntarily provide to us, for example during customer onboarding or when you communicate with us via email, telephone or other channels.

Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the person you may be representing.

The Personal Data we collect may include your name, residential address, email address, contact number, date of birth, and gender, etc.

Where required to do so by law, we may collect, use and disclose Personal Data about you to the relevant authorities or to law enforcement agencies.

Some examples of data which on its own or jointly, can be used to identify a natural person are:

1. personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
2. specimen signature(s);
3. financial details (e.g. assets, income, expenses, liabilities and/or credit history);
4. images and biometrics such as thumbprints, voice and video recordings of you, including our conversations with you for verification or other purposes;
5. employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
6. tax and insurance information;
7. information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
8. banking information (e.g. account numbers);
9. your personal opinions made known to us e.g. through feedback or surveys;
10. information relating to your activities, habits, preferences and interests arising from your use of products and services of Advier's Kit, our partners or vendors; and/or
11. other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.

2. True, Accurate and Up to Date Information

You agree and acknowledge that it is your responsibility to ensure that all information submitted to us by you is true, accurate and not misleading and that such information is kept up to date. Failure on your part to do so may result in our inability to provide you with the Software and services you have requested. We reserve the right to request for documentation to verify the information submitted to us by you.

3. Third Party Personal Data

You agree and acknowledge that where you provide to us Personal Data of a third party, such your client’s data, it is your responsibility to obtain the requisite prior consent from such third party for you to provide his/her Personal Data to us for the relevant purposes and you represent to us that you have duly done so.

4. Storage of your Personal Data

We store your Personal Data in softcopy formats on our cloud servers.

We will only keep your Personal Data for as long as we are either required to by law or as is relevant for the purposes for which it was collected.

5. Use and Disclosure of Personal Data

We do not rent, sell or trade your Personal Data to any third party.

We gather your Personal Data for purposes of providing and improving our services to you via the Site. The collected Personal Data may be used, or shared with third parties (including our related companies, our service providers (such as courier companies), and our suppliers and merchants) as we deem necessary, for some or all of the following purposes:

a. to facilitate your use of the Site, including processing orders you place for our Software through the Site and responding to your queries and requests;

b. to deliver the Software you have purchased through the Site;

c. for customer support purposes;

d. to obtain your feedback regarding our Software;

e. to manage requests and enquiries, respond to your feedback, and resolve complaints;

f. to conduct business analysis including carrying out research on our users’ demographics and behaviour;

g. to compare information, and verify with third parties in order to ensure that the information is accurate;

h. to administer and manage your customer account (if any) and your relationship with us;

i. to carry out financial transactions in relation to payments you make online;

j. restricting physical and online access to confidential data only to authorized personnel;

k. to audit the downloading of data from the Site;

l. to improve the layout and/or content of the pages of the Site and customise them for users of the Site;

m. to verify and identify visitors on the Site;

n. to provide you with information we think you may find useful or which you have requested from us, including information about our Software, provided you have indicated that you have not objected to such contact;

o. in connection with business asset transactions (which may extend to any mergers, acquisitions or asset sales);

p. to carry out financial analysis and calculations in the delivery of the Software;

q. other purposes which are reasonably related to the aforesaid purposes.

6. How we Protect your Personal Data

We have put in place a number of security measures to make sure your data is safe from loss, misuse, or alteration. This includes:

a. maintaining technology products to prevent unauthorised computer access;

b. securely destroying your Personal Data when you wish to withdraw your consent to our continued use or when it is no longer needed for any legal or business purpose as stated in paragraphs 11 and 12 of this Policy;

c. ensuring that sensitive and private data exchange between you and the Site happens over a SSL secured communication channel and that such exchange is encrypted and protected with digital signatures; and

d. ensuring all employees are bound by appropriate confidentiality provisions.

Our management reviews our security system regularly, and upgrades it from time to time to keep your Personal Data safe.

7. Security Disclaimer

We take precautions to ensure that your Personal Data is protected against unauthorised or unintended use, access or disclosure. However, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control. To the extent permitted by law, we shall not be liable in any event for any damages of any kind (including but not limited to special and exemplary damages) or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your Personal Data.

In the event of a data breach, Finjaro will notify the affected customers without undue delay.

8. Accessing Your Personal Data

If you would like to view the Personal Data we have on you or inquire about the ways in which your Personal Data has been or may have been used or disclosed by us within the past year, please contact our Data Protection Officer. We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records. Please also note that under the Personal Data Protection Act 2012 of Singapore (“PDPA”), we are not required to provide you with certain categories of information listed under the Personal Data Protection Act 2012 of Singapore (“PDPA”).

We will respond to your access request as soon as reasonably possible, or within 30 working days from the date we receive your request. If we are unable to do so within 30 working days, we will inform you and give you an estimate of how much longer we require.

If you have a customer account, you may access details of your Personal Data collected by us by logging into your customer account via the Site. Here you may administer your address details, bank details and any marketing information to which you may have subscribed.

Here you can view the details of your past completed orders, outstanding unfulfilled orders and orders which are shortly to be dispatched.

9. Updating Your Personal Data

You may update your Personal Data anytime by accessing your customer account via the Site. If you do not have an account with us, you can update your Personal Data by writing to our Data Protection Officer.

We take steps to share your updates with third parties with whom we have shared your Personal Data as is necessary to continue providing you with our Software or to perform on any contract we have with you.

10. Correction of Personal Data

You may request us to correct an error or omission in relation to personal data about you that is in our possession or under our control by writing to our Data Protection Officer and including in your request your name and identification particulars and such other information that we require to identify you and the relevant Personal Data to be corrected.

We will respond to your correction request as soon as reasonably possible, or within 30 working days from the date we receive your request. If we are unable to do so within 30 working days, we will let you know and give you an estimate of how much longer we require.

11. Withdrawal of Consent

Should you wish to withdraw your consent to our continued use and disclosure of your Personal Data for any of the purposes stated herein, you may do so by writing to our Data Protection Officer, stating the following information:

a. your name and account identification number; and

b. reasons of your withdrawal request.

Please note that if you so withdraw your consent, depending on the nature of your consent withdrawal, we may not be in a position to continue to provide our Software to you or to perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event.

In general, we shall seek to process your request within 30 working days of receiving it.

12. Retention of Personal Data

We will not retain any of your Personal Data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your Personal Data in a secure manner as soon as it is reasonable to assume that the permitted purpose is no longer being served by their retention.

Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited personal data will be deleted right away. If received by telephone, these will not be recorded.

13. Complaints

If you have any complaint(s) arising from our collection, use and/or disclosure of your Personal Data, you may submit your complaint(s) in writing to our Data Protection Officer. Upon receipt of your complaint, we shall respond to acknowledge your complaint within 7 working days. Our management will investigate your complaint thereafter and strive to resolve your complaint within 14 working days. If your complaint is complex and cannot be satisfactorily resolved during this period, we will inform you accordingly and advise on the further steps we will take in our further handling of this matter.

14. Transfer of Personal Data Outside of Singapore

We do not transfer personal data outside of Singapore.

In case transfer is necessary in line with the purposes listed in section 4, we will ensure that the standard of data protection in the recipient country is comparable to that of the Singapore Personal Data Protection Act 2012. If this is not so, we will enter into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.

15. Collection of Browsing Data

We or our authorized service providers may use cookies and other similar technologies for storing information to help provide you with a better, faster, safer and personalized experience when you use the Site. When you visit the Site, our servers will automatically record information that your browser sends whenever you visit a website. This data may include:

a. your computer’s IP address;

b. browser type;

c. webpage you were visiting before you came to our Site; and

d. the pages within the Site which you visit; and

e. the time spent on those pages, items and information searched for on the Site, access times and dates, and other statistics.

This information is collected for analysis and evaluation in order to help us improve our website and the Software we provide.

16. Governing Law

The laws of Singapore govern this Policy. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.

As a customer of Finjaro, you will need to provide us with your information. Such information may be considered to be personal data or personal information protected under the Personal Data Protection Act (No. 26 of 2012) of Singapore. By providing us with your personal data or information, you acknowledge and consent to our collection, use, disclosure and/or processing of your personal data/ information for the purposes set out below:

• client onboarding and facilitating your usage of the Platform and your Account;
• providing the Services to you, including providing notifications and reminders, recommendations, facilitating Transactions, etc.;
• providing you with information, materials and/or documents for information updating, marketing, advertising and/or promotional purposes relating to our Services, whether the services currently exist or are created in the future;
• comply with Applicable Laws, including client onboarding, compliance procedures, enforcement of legal rights, disclosure to law enforcement agencies and authorities for crime prevention and detection;
• administration and/or managing of the relationship between you and Finjaro; and
• any other purposes as reasonably incidental to the above.

This Privacy Policy was last updated on 1 June 2021.