PRIVACY POLICY

MONEYTREE TECHNOLOGIES PTE. LTD. (“we” or “us”) is committed to protecting and respecting your privacy.

  1. This policy (together with our main Terms of Use and any other documents referred to in it) sets out the basis on which any personal data (the “Data”) we collect from you, or that you upload, will be processed by us. Please read the following carefully to understand our views and practices regarding your Data and how we will treat it.
  2. By providing your Data to us, you consent to the collection, use, disclosure and transfer of your Data in the manner and for the purposes set out below.

INFORMATION WE MAY COLLECT

  1. We may collect and process the following data:
  • information that you provide by filling in forms on WealthFolio (“our Portal”), including information provided at the time of registering to use our Portal, subscribing to any services provided by us, posting material, completing any tests or analyses, reporting a problem with our Portal, or requesting further services;
  • information that we receive when you log in to our Portal through MyInfo, a Singapore Government service that enables users to use their SingPass to log in to our Portal;
  • information that you have authorised a third party to release to us, including your insurance companies, insurance agents, financial advisers and/or customers;
  • documents or images that you upload onto our Portal, including any medical reports or medical images;
  • details of transactions you carry out through our Portal;
  • details of your visits to our Portal and the resources that you access;
  • if you contact us, a record of that correspondence; and
  • responses to surveys that we send to you, although you do not have to respond to them.

IP ADDRESSES

  1. We may also collect and process information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

COOKIES

  1. Our Portal uses cookies to distinguish you from other users of our Portal. This helps us to provide you with a good experience when you browse our Portal and also allows us to improve our Portal.

 WHERE WE STORE YOUR DATA

  1. The Data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your services ordered by you, the processing of your payment details and the provision of support services. By submitting the Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Data is treated securely and in accordance with this privacy policy.
  2. All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Portal, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
  3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Portal; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

USES MADE OF THE INFORMATION

  1. We use information held in the following manner:
  • to ensure that content from our Portal is presented in the most effective manner for you and for your computer;
  • to provide you with information, products or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;
  • to provide you with information, products or services which we feel may interest you, where you have consented to be contacted for such purposes;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • to notify you about changes to our services;
  • to investigate any complaints relating to the use of our Portal or any suspected unlawful activities; and
  • for the purposes of data analytics, conducted on our behalf by third party vendors.

DISCLOSURE OF YOUR INFORMATION 

  1. We may disclose your Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap. 50).
  2. We may disclose your Data to third parties:
  • for the purposes of providing products or services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, processing payments in connection therewith or otherwise in connection with your use of our Portal;
  • where a third party claims that any content posted or uploaded by you to our Portal constitutes a violation of their rights under Singapore law, in which case we may disclose your identity to that third party;
  • in the event that we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets; or
  • if we or substantially all of our shares or assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
  1. We may also disclose your data to a governmental or regulatory body, law enforcement, or other authorities, in order to enforce our terms of use for the Portal, to cooperate with any direction, request or order from such parties or to report any suspected unlawful activity.

CONSENT

  1. By providing your Data to us, you consent to the collection, use and disclosure of your Data by us for the purposes set out in this privacy policy (“Purposes”). 
  2. Where any Data relates to a third party, you represent and warrant that the Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.
  3. Each use of our services by you shall constitute a fresh agreement for us to collect, use and disclose the Data in accordance with this privacy policy.
  4. You may withdraw your consent and request us to stop using and/or disclosing your Data for any or all of the Purposes by submitting your request to us in writing. Should you withdraw your consent to the collection, use or disclosure of your Data, it may impact our ability to proceed with your transactions, agreements or interactions with us. Prior to you exercising your choice to withdraw your consent, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies) or undertaking any steps as we may be entitled to at law.

ACCESS AND CORRECTION

  1. The Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”) gives you the right to access your Data. Your right of access can be exercised in accordance with the PDPA. Any access request may be subject to a fee of an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you.
  2. In the event that you wish to correct and/or update your Data in our records, you may inform us in writing of the same. In certain cases, Data may also be corrected or updated via the Portal.
  3. We will respond to requests regarding access and correction as soon as reasonably possible. 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 PDPA).

ACCURACY

  1. We endeavour to ensure that all decisions involving your Data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Data.

RETENTION

  1. We may retain your 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 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 Data was collected, and is no longer necessary for legal or business purposes.

THIRD PARTY POLICIES

  1. Our Portal may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.

DATA INTERMEDIARY

  1. Where we process your Data as a data intermediary on behalf of a third party, we will process your Data in accordance with the instructions of the third party and shall use it only for the purposes agreed between you and the third party. All such Data will be protected and retained in accordance with this privacy policy and the terms of the PDPA.
  2. We will take steps to inform the third party of any requests, complaints or questions that you may have regarding such Data.

CHANGES TO OUR PRIVACY POLICY

  1. Any changes we may make to our privacy policy in the future will be posted on our Portal and, where appropriate, notified to you by e-mail.

CONTACT

  1. Questions, comments and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Officer at admin@wealthfolio.co.