Genwealth 8 Privacy Policy

Last Updated: 17 October 2019

Introduction

In this Privacy Policy (the "Policy"):

"Account" means the membership or non-membership account opened by you with us;

"Act" means the Singapore Personal Data Protection Act 2012 as amended, revised or re-enacted from time to time;

"Personal Data" has the meaning given to it in the Act;

"Terms of Service" means the terms of use found on our website, as amended from time to time.

any reference to "you", "your" and words of similar import means any individual who may have provided any Personal Data to us for any purpose and any online users and visitors to our website or software applications that run on smart phones, tablets and other devices which provide dedicated non-browser-based interaction (the “apps”); and

any reference to the “Company”, "we", "us" or " our" and words of similar import means the Genwealth 8 Pte. Ltd., its subsidiaries, affiliates, successors and assigns.

This Policy sets out our policy regarding the collection, use and disclosure of your Personal Data to us when you access and use our website, apps or other services provided by us (the “Services”). Our Policy is to be read together with our Terms of Service. By accessing our Services, you consent to the collection, use and disclosure of your Personal Data to us and agree to be bound by the following terms and conditions of this Policy and our Terms of Service.

You must be at least 18 years of age to use our Services. By using our Services, and by agreeing to these terms and conditions, you warrant and represent that you are at least 18 years of age.

If you do not agree to the terms and conditions of this Policy, please discontinue the use of and refrain from using our Services.

Collection and Use of Personal Data and Other Information

Personal Data

As a general rule, we will only collect and use your Personal Data through, including but not limited, cookies, pixel tags, website and data analytics, and other technologies in accordance with the Act, solely for the purposes notified to you. Such information includes but is not limited to the following:

Account information upon registration of an account to use our services such as your personal particulars for example name, address, date or birth, gender, profession, marital status, nationality.
Contact information that allows us to communicate with you. This information is obtained upon registration for our services on our Services including your name, address, telephone number, e-mail address and other means of communication which you may be contracted online or offline.
Payment information related to your financial relationship with us such as the services we provide to you, your payment information such as credit or debit card details and your payment history.
Product / service usage information such as how you use your device to access our Services.
Third party partner information related to how you engage our third-party partners.
Communications with us by e-mail, electronic messages, social media and other electronic and non-electronic means.
Networks and connections made available to us, depending on the permissions you have granted, from your mobile or desktop devices address book contacts, Facebook friends list and other social media such as Linkedin, Instagram, Pinterest and Twitter.
Device and settings information from or about the computers, mobile devices or other devices where you access our Services depending on the permissions you have granted to us. Such as the make and model of your mobile device, operating system, hardware version, device setting, file and software names and types, device identifiers, device locations through GPS, Bluetooth or WiFi Signals or such other connection information of your service provider or ISP, browser type, language and time zone, mobile phone number and IP address.

Aggregate Data

For each visitor to our Services, our server automatically recognises information regarding your domain name (or that of the visitor’s access provider) but not the email address or other information that allows you to be identified (unless you choose to interact with us through activities such as subscribing to our mailing list or signing up for an event). We also collect aggregated information regarding user access or visits to our Services. Information collected automatically and aggregated information do not identify you personally and will only be used by use for analytical and statistical purposes, such as determining the countries from which our visitors originate.

Handling of Personal Data

Only authorised staff have access to your Personal Data. Our authorised staff are required to abide by their contractual obligations to maintain the confidentiality and privacy of your Personal Data at all times.

Disclosure of Personal Data

We do not sell any Personal Data in our possession to anyone or any third party for any purpose. Your Personal Data will not be published on our website. We will only disclose your Personal Data in circumstances that: you have expressly or implicitly consented to, or deemed to have consented to; that have been specifically notified to you; are necessary for the operation of our Services; or otherwise only in limited circumstances such as to government departments, statutory boards, regulatory or law enforcement agencies or in accordance with the applicable laws.

Compliance by Third Parties

In the event that we may be required to share your Personal Data with any third party we will notify you beforehand and obtain your consent.

We may have outsourced one or more services or facilities offered through our Services to third party service providers (“Vendors”). In such cases, we may provide some of your Personal Data, or you may be required to provide your Personal Data, directly to the Vendors. These Vendors are subject to confidentiality and data protection obligations and other legal restrictions that prohibit their use of the information we provide them for any other purpose except for the specific outsourced operation. Where the Vendor collects Personal Data directly from you, you will be notified accordingly and all information that you provide to them and their use of the information will be strictly between you and the Vendor. If you provide Personal Data directly to a Vendor, then their use of the Personal Data that you provide to them will be governed by their applicable privacy policy.

Without prejudice to the foregoing, our Services may contain links to other internet sites which are outside our control and are not covered by this Policy. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used in accordance with their privacy policy, which may differ from ours.

Security Measures in Place to Protect Personal Data

To protect and safeguard the confidentiality of your Personal Data and to ensure that they are safe, secure and private, we adopt the following systems security and monitoring measures:-

Firewalls, anti-virus protection and intrusion detection systems to detect and prevent any forms of illegitimate activities and/or illegal intrusions of our network systems;
Regular security reviews of our systems;
Vigilant monitoring to detect any suspicious online activities at our website.

We are committed to monitoring our security system constantly for potential situations that could compromise the security or the privacy of our customers, online users and visitors to our website and to exploring new technology continually to enhance our security system. Nevertheless, we do not warrant the security of your Personal Data transmitted to us using our website and internet and online services. This is because you accept the risks that any of your Personal Data transmitted to or received by us using our website and internet and online services may still be accessed and/or disclosed by unauthorised third parties.

Your responsibility in safeguarding your Personal Data

If you wish to access our website, the best way is to directly enter our website address in the browser address bar and not via hyperlinks within emails (unless those emails are sent by us).

Clear your browser’s cache and history after each session. Default files on a computer, sometimes called "cache" files can retain images of Personal Data or otherwise sent to or received by us at our website, making them a potential target for a system intruder. Therefore, we strongly advise that you clear your browser’s disk cache and history after each visit to our website.

Do not use a shared computer or an Internet cafe; computer to access our website because such computers may be installed with certain software which could capture your Personal Data or otherwise without your knowledge.

If you have installed or downloaded any software which claims to speed up your internet connection or other software, games, screensavers etc, you should be aware that they may be spyware which has the ability to track your internet sessions and/or gain access to your Personal Data and Internet browsing history. We recommend that you uninstall such spywares.

Do not leave your personal computer unattended during your online session whereby your Personal Data may be viewed by unauthorised persons.

Ensure that your personal computer has the latest anti-virus, anti-spyware and firewall software and updates to guard against new viruses. Make sure that your computer’s operating system and browser software are updated with the latest security patches.

If you wish to access our app, the best way is to directly download our app from the Google Play Store or the Apple Store on your personal mobile device.

Do not use the app or log into your account on a device that does not belong to you.

Do not leave your personal devices which have the app downloaded and your account logged in unattended.

Ensure that your devices, including your mobile phone, tablet or otherwise, have the latest anti-virus, anti-spyware, anti-malware, anti-ransomware and/or firewall software and updates to guard against cybersecurity threats.

Update us whenever you have changed your contact details in order for us to contact you in a timely manner on any issues or matters relating to your access to our website.

Contact us should you notice something suspicious or encounter any issues, difficulties or irregularities in accessing our website.

Do not open email attachments from strangers, install software or run programs from unknown sources or origins.

Delete junk or chain emails.

Email messages sent to us over the Internet containing your Personal Data cannot be guaranteed to be completely secure and you assume all risks arising or in connection thereto.

It is important that you do your part to ensure that any Personal Data provided to us via our Services or email or any other channels of communication are done in a safe and secure manner. We will not be liable to you for any losses, damages, expenses, costs (including legal costs) and charges (whether direct or indirect, foreseeable or unforeseeable, special or consequential or economic loss) incurred or suffered by you arising out of you sending email messages containing your Personal Data to us over the Internet or for any error, fraud, forgery, system failure or anything beyond our control or in connection with your failure to adhere to the terms and conditions herein and the terms and conditions of access to our website under and/or your failure to follow the above recommended security measures.

Access to Personal Data

Under the Act, you have the right of access to your Personal Data in our possession or under our control or information which may have been used or disclosed by us within a year before the date of your request. Your request to us for access must be made in writing and subject to payment of any fees that we may prescribe.

Correction of Personal Data

If you have any reasons to believe that any Personal Data which you have provided to us is inaccurate, incorrect, incomplete or not updated, you may write to us. We will, after using reasonable efforts to verify the authenticity of the request, promptly update your records accordingly within seven (7) working days from the date of receipt of your request.

Retention of Personal Data

Your Personal Data will be retained by us for as long as the original purposes or the legal or business purposes for which your Personal Data was collected continues. If retention is no longer necessary, we will use reasonable efforts to delete, destroy or de-identify your Personal Data unless retention of the same is required to satisfy legal or regulatory requirements or to protect our interests or in accordance with our policies.

Ways in which Personal Data may be collected

Personal data may be collected from you through our website in a variety of ways, including but not limited to the following:

for the purpose for which the information was provided;
when you visit, access or use our Services;
when you communicate with us electronically and through other means;
when you respond to surveys or feedback forms we might ask you to complete;
when you open an Account with us;
when you register on our Services as a user, whether to sign up for exclusive online features, or for any other purpose available through registration;
when you interact with us through social media websites and other websites and apps;
when you share content on our Services with other parties; and
to conduct due diligence checks on you in accordance with all applicable laws and for us to comply with all legal and regulatory obligations, including Anti-Money Laundering and Countering the Financing of Terrorism.

We may also collection information through automatic data collection and tracking technologies which include:

Personal data may also be collected from you through the use of cookies. Cookies are small data text files stored in your computer, laptop or mobile device that send information about your previous visits to and activities on our website. These cookies will not give us any personal information about you. We reserve the right to use the cookies to recognise your browser and thereby customise and optimise our website to your preferences. You can accept or delete cookies, however please note that if you do erase or block the cookies, you may not be able to utilize some features on the Services. In such situations, we shall not be held liable for any loss or damage resulting from your inability to use those features. These cookies are categorised into four categories:

Strictly necessary cookies. These cookies are essential for the function and operation of our Services.
Performance cookies. These cookies collect anonymous information on the users of our websites and apps to enable us to improve the operation of our websites and apps. For example, by ensuring that users are able to use custom features.
Functionality cookies. These cookies retain choices you make such as user ID, email ID and other preferences in order to personalise our Services for you as you navigate through our Services.
Targeting cookies. These cookies record your browsing habits to allow us to provide advertising relevant to you and your interests. We may share this information with third parties for this purpose on an anonymous basis.

Information may also be collected through the use of web beacons which may be contained in our website, apps or e-mails that permit us to, for example, count users who have visited the pages or opened an e-mail and collect other related website and app statistics.

Log files may also be used to capture your activity on our Services, such as the content engaged and the frequency or duration of such activity.

Use of Personal Data collected through our Services:

Without prejudice to any other provision of this Privacy Policy, any Personal Data collected through our Services will be used and/or disclosed by us for any one or more of the following purposes:

to process and, where necessary, respond to your requests and queries;
to verify and process your personal particulars and to ensure you are eligible to access and use the services provided;
to process your registration on the website and in connection with your usage of the Services after such registration;
to process your subscription to the E-newsletter and for purposes related to your subscription;
to process any online purchases or donations made by you, including effecting payment;
to communicate with you;
to enforce our legal rights and remedies under this Privacy Policy and the Terms of Service;
for marketing research, user profile and statistical analysis;
to send you information, promotions, updates and marketing and advertising materials in relation to our products and services and those of third party organisations;
complying with applicable laws and regulations, the requests of law enforcement and regulatory officials, or orders of court; and
for any other purpose including the disclosure of such information to third parties for commercial/business reasons.

Your usage of any services provided by us through our Services is also subject to our Terms of Service which are incorporated by reference into this Privacy Policy. If there is any conflict, inconsistency or ambiguity between this Privacy Policy and the Terms of Service, this Privacy Policy will prevail.

Notifications

We may send you notifications from time to time. You may not opt out of receiving certain service-related notifications when using our Services. You are deemed to have consented to the receipt of all such notifications, updates, marketing or otherwise, through the use of our Services. Such notifications include but are not limited to:

Necessary elements of your transactions on our Services or any service we may provide, such as confirmations of particular actions you have taken or confirmation of particulars;
Are required for legal or security purposes;
Meant to inform you of changes to our policies, operations or services;
Information updates issued by us;
User surveys or other requests for user feedback;
Seminars, talks or courses available; and
Marketing offers from us or sent on behalf of third parties through our Services.

Customer Service and Enquiries

You may at any time withdraw your consent to the collection, use or disclosure of your Personal Data by giving reasonable notice to us. If you withdraw your consent, we will inform you of the expected consequences of your withdrawal.

If you have any queries, concerns or complaints relating to the collection, use or disclosure of your Personal Data, please email us at admin@genwealth8.sg. We will attend to your queries, concerns or complaints as expeditiously as possible.

We may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and us. We may do so in order to resolve queries in the future and/or for the purpose of ensuring security, staff training and complying with its legal and/or regulatory responsibilities.

Amendments to the Policy

We may amend this Policy from time to time and will make available the updated Policy on our Services. By continuing to access our Services you agree to be bound by the terms and conditions of the Policy, as amended from time to time. The effective date of the Policy is the “Last Updated” date identified at the top of the page. You are responsible for ensuring we have an up-to-date and deliverable e-mail address and/or phone number for you and for periodically visiting our Policy to check for any changes.

Governing Law and Submission to Jurisdiction

This Policy is governed by Singapore law and you agree to irrevocably submit to the exclusive jurisdiction of the courts of Singapore.