Last Updated: 10/12/2018
The MoneySmart Group (“MoneySmart”) is fully committed to safeguarding the privacy of its customers, online and otherwise, and the success of our business depends on our ability to maintain the trust of our clients and customers.
- the information we collect about you;
- how that information may be used;
- with whom it may be shared;
- how you may access the information you provide us;
- your choices about such uses and disclosures; and
- how you can contact us for matters relating to your personal information
2. Information We Collect About You
2.1 In General
We may collect personal information that can be used to identify you, including, but not limited to, name, residential address, identification and/or passport number, date of birth, email address, employment details, information relating to financial circumstances (collectively “Personal Information”). We also collect traffic patterns relating to users on our website.
When you provide personal information, through our websites or through other channels such as phone, email, SMS, WhatsApp, and other messaging and information sharing services, the information may be sent to servers located in the Singapore and other countries around the world.
By providing this information you consent to the following:
- You are authorized to provide this information, in case you are providing this information on behalf of an entity other than yourself
- The information you provide is accurate to the best of your knowledge
2.2 Information You Provide
We may collect and store any personal information you enter on our websites or otherwise provide to us through other channels, like phone, email, SMS, WhatsApp, and other messaging and information sharing services.
This includes, but is not limited to, the following:
- Identifying information (such as your name, ID/IC/passport number, ID/IC/passport document soft copies, ID/IC/passport document hard copies, home or mailing address, e-mail address and telephone/mobile number)
- Information about your home or prospective home, your financial and loan information (such as your income, assets or debts)
- Other financial information, like credit card number
- Other personal information (such as your gender and age, number of dependents, marital status, nationality, mother’s maiden name, vehicle identification number, vehicle make, vehicle model, etc.)
The specific data we collect within the context of the above includes, but is not limited to, the following:
- Full name
- Mobile telephone number
- Personal email address
- Residential address
- Residential telephone number
- Personal documents required for the application of mortgages and insurance
- Financial product information, including, but not limited to, details of current loan amount, and details of current insurance policy
- Payment information like credit card numbers, etc.
We may collect and hold personal data of persons/entities including, but not limited to, the following:
- All customers
- Entities related to the customer, for example family members
- Job applicants
- Service providers
- Other people who we may come into contact in the course of operations.
This information might be collected in various ways including, but not limited to, the following:
- through use of our website, via the various forms,
- email marketing campaigns
- customer web surveys
- third-party web-pages
- WhatsApp, SMS, Telegram, and other messaging and information sharing services
2.3 Information from Other Sources
We may also periodically obtain both personal and non-personal information about you from business partners, contractors and other third parties, including but not limited to banks, financial institutions, and other service providers and websites. Examples of such information includes, but is not limited to, contact details, purchase details like information about your home and additional demographic information, and credit reports.
MoneySmart does not pull a credit bureau report on loan customers without permission.
2.4 Information About Others
We may also collect and store personal information that you provide to us about other people (such as co-borrowers, family members, dependents), including their name, IC/ID/passport number, IC/ID/passport number soft copies, IC/ID/passport hard copies, address, phone number, financial information or other personal information.
We use various technologies to collect information about your activities on our websites. We automatically collect information from your browser when you visit our websites. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below) and the referring website address.
A cookie is a text file made up of letters and numbers that allow us to distinguish your browser/device from another user's browser/device. This text file is stored on your computer's hard disk, or other memory, for the purpose of keeping records when you visit a website.
When you visit our websites, we may assign your computer one or more cookies, to facilitate access to our websites, to personalize your online experience and to record information about your visit to our websites. Through the use of a cookie, we also may automatically collect information about your online activity on our websites, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while on our websites. The cookie might also store some personal information about you, including, but not limited to, your full name.
Most browsers automatically accept cookies, but usually you can modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our websites, which will limit our capability to offer you a personalized experience.
2.5.2 Other Technologies
We may use other technologies, that are standard for Internet companies, to track your usage of our website. This includes, but is not limited to, web beacons 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 customize the services we offer our websites' visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
2.6 Information Collected by Third Parties
We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our websites. We and these companies may use tracking technologies, such as cookies, to collect information about users who view or interact with these advertisements and connect to our websites. Our websites do not provide any personal information to these third parties. This information allows us and these companies to deliver and gauge the effectiveness of targeted advertisements. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies.
Other third-parties, like our authorized service providers, bank partners, official third party service providers engaged by financial institutions and other financial institution partners, may also collect your personal data so as to provide you the best possible customer experience. This might be done to establish and verify your identity in the process of fulfilling our service obligations to you, and to facilitate servicing of products that you have expressed an interest in.
3. How We Use The Information We Collect
We may use information that we collect about you to:
- deliver the products and services that you have requested;
- manage your customer relationship and provide you with customer support;
- perform research and analysis about your use of, or interest in, our products, services, content, or products, services and content offered by others, through data you provide to use through use of our website, and through customer research we directly involve you in, like surveys and interviews;
- communicate with you by e-mail, postal mail, telephone, mobile devices, and/or through other messaging and information-sharing services, about products or services that you have expressed interest in, or may be of interest to you, either from us, other MoneySmart Group companies or other third parties that we liaise with, including, but not limited to, banks, insurance firms, and other financial institutions;
- develop and display content and advertising tailored to your interests on our websites and other websites;
- verify and establish your identity, for providing you the service you have expressed an interest in, purchased, or signed up for
- verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes;
- verify and establish your identity, to facilitate disbursal of prizes and other items in connection with promotions, contests, and sweepstakes;
- enforce our terms and conditions;
- where information is to be disclosed to law enforcement agencies and other relevant authorities for crime prevention and detection purposes;
- manage our business; and
- perform functions as otherwise described to you at the time of collection.
3.1 Financial information
We may use financial information, that you provide to us directly or is provided to us via third-parties, to match you with lenders or to provide lenders' conditional loan offers to you, to verify your identity, to protect against or identify possible fraudulent transactions, or otherwise as needed to manage our business.
We collect and forward your credit card and other payment information, provided to you by us, for completing the sale of certain products on our website, including, but not limited to general insurance products such as car insurance, home insurance, travel insurance, maid insurance and personal accident insurance.
4. With Whom We Share Your Information
We want you to understand when and with whom we may share personal or other information we collect about you or your activities on our websites or your use of our services.
4.1 Personal information
We do not share your personal information with others except as indicated below, or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share all types of personal information with:
4.1.1 Authorized service providers
We may share your personal information with our authorized service providers that perform certain services on our behalf in connection with your purchase interest for our products and services.
These service providers include, but are not limited to, data providers, technology providers, credit bureaus, title companies, flood or other insurance providers, appraisal companies, escrow companies, closing agents, other financial institutions, marketing and customer services firms, credit card payment processors, logistics firms as well as companies that support contests, sweepstakes, surveys, or other features offered through our websites, or that provide business analysis or website support. These service providers may have access to personal information needed to perform their functions, but are not permitted to share or use such information for any other purpose.
4.1.2 Business partners
When you express interest in products, services or promotions offered through our websites or our services, we may share your expression of interest with third-parties that enable us to serve you the information or quotes, and the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes, and, as applicable, their affiliates and third-party finder or marketing companies. When you elect to engage in a particular offer or program, you authorize us to provide your e-mail address and other personal information to those businesses.
4.1.3 Other lenders, financial institutions and investors
If you submit a completed MoneySmart form, we may share your personal information with lenders, or other financial institutions and service-providers, on the MoneySmart network with whom you are or may be matched.
We might also be required to share aggregated and anonymized data with investors or auditors. You would not be uniquely identifiable through this information.
4.1.4 Other MoneySmart Group Businesses
4.1.5 Other Situations
220.127.116.11 Legal Reasons
We may also disclose your information:
- 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.
- 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; or to enforce our websites' terms and conditions or other agreements or policies.
- 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.
18.104.22.168 Aggregated and Non-Personal Information
We may share aggregated information (i.e., information about you and other customers collectively, but not specific enough to identify you) and other non-personal information we collect under any of the above circumstances. We may also share it with third parties and MoneySmart Group companies to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources.
We may also share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our websites and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising.
22.214.171.124 Third-party websites
Generally, when MoneySmart requests for Personal Information in the course of providing you a service and/or product and where you provide us with such Personal Information, there is implied consent that you agree to provide us with your Personal Information in order for us to provide you with the requested service and/or product.
In some circumstances and as required by applicable law, we will seek your express consent when collecting your Personal Information. This is particularly where fresh consent is required for a new purpose in which your Personal Information will be used.
By providing Personal Information relating to a third party (such as (but not limited to) information of your spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and/or disclosure of the Personal Information for the purposes listed here. In general, any information you provide to us is with the implied consent of the entity whose information is being provided.
6. Retention of Information
Personal Information will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable law. MoneySmart shall cease to retain Personal Information or remove the means by which Personal Information can be associated with particular clients, as soon as it is reasonable to assume that the purpose for which that Personal Information was collected is no longer valid and retention is no longer necessary for legal or business purposes.
7. Accuracy of Information
MoneySmart endeavours to ensure that your Personal Information is as accurate and up-to-date as possible.
You may also contact us at any time if you wish to correct, amend or update your Personal Information. Please contact our Data Protection Officer for this purpose at [email protected]
8. Access rights
You are also entitled to certain access rights to your Personal Information. To make a request, please contact our Data Protection Officer at [email protected]; whereupon your request will be acknowledged and acted upon generally within thirty (30) days of receipt of such request. If for any reason, we are unable to accede to your request, you will be notified accordingly.
Please note that, in certain exceptional cases, MoneySmart is entitled to charge a reasonable administrative fee for this service which you will be advised of prior to us acting upon the request.
9. How We Protect Your Personal Information
At MoneySmart, your personal data and the information that you share with us in confidence, is treated with the utmost respect and care. Thus, the safety of your personal data is important to us and it is our policy to respect the confidentiality of information and the privacy of every individual.
This Policy outlines how MoneySmart manages the personal data we hold in compliance with the Personal Data Protection Act in Singapore and applies to everything we do with regards to that information.
MoneySmart has in place various security procedures, technical and organisational measures to safeguard your Personal Information. To protect against external attacks, we have in place robust firewalls and security measures to detect, isolate and prevent against hacking and other malware intrusions to our IT systems.
Further MoneySmart employees also undergo periodic security awareness programmes to create awareness in information security so that employees are able to identify and respond appropriately to security risks.
We use all reasonable efforts to safeguard your Personal Information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Information which is transferred from you or to you via the Internet. You should also be mindful that you are responsible for keeping your access rights confidential and secure at all times.
MoneySmart Group companies, do not hold responsibility for any data leaks or situations where your personal information and data might be compromised, through systems of our third-party service providers and other partners being compromised.
10. Job Applicants and Employees
10.1 Job Applicants
If you apply for a job with MoneySmart or any of the MoneySmart Group companies, we will collect from you only the personal data you include in the curriculum vitae (CV) that you choose to send to us and, if we interview you, any personal data that you choose to provide to us during that interview. We will use such personal data only for the purpose of deciding whether or not to hire you.
We will rely on you being deemed to have consented to us collecting and using the personal data described above for such purpose. If your job application is unsuccessful, we will retain such personal data on a ‘keep in view’ basis, unless you explicitly revoke consent to do so.
If you accept an offer of employment with us, we will ask you to provide us with personal data in addition to the personal data referred to in section 10.1 to the extent that we need it for the purpose of managing and terminating the employment relationship between you and us.
We might also store other personal information, with regards to facilitating transactions, including, but not limited to, financial information such as bank account numbers, family members’ details, and dependents’ details.
We will use and disclose both the personal data referred to in section 10.1 and such additional personal data for the purpose of managing and terminating the employment relationship between you and us.
11. Exercising your rights
11.1 Verifying your identity
To be informed of the personal data we possess, as given to us by individuals, a verification of identity will be required of the party requesting the information. Disclosure is made only to the individual whom the personal data pertains to.
Please note that all requests to have personal data removed from our databases or physical storage facilities will be entertained and performed within the company’s reasonable abilities.
11.2 Withdrawal of Consent
To make a request to withdraw consent previously given, please contact our Data Protection Officer at [email protected].
11.3 Filing a complaint
We take any and every complaint against personal data very seriously and endeavor to ensure the address and satisfaction of all complaints that come through. To make a complaint, please contact our Data Protection Officer at [email protected].
12. Visiting Our Website From Outside Singapore
13. Liabilities of Third-parties
15. Contacting Us
Attention: Data Protection Committee
Email: [email protected]