Privacy
policy

This is the privacy policy (“Privacy Policy”) for LatitudePay by LatitudePay Singapore Pte. Ltd. (“LatitudePay” or “we” or “our” or “us”). We take our obligations to protect personal data seriously and have in place policies and practices dealing with data protection. We ask that you read this Privacy Policy carefully as it contains important information on how we collect, use, process and disclose personal data in our possession or under our control, including information on: our policies and practices for meeting our obligations under laws, regulations and guidelines which concern data protection;

how you may access, correct or make other requests in relation to your personal data in our possession or control as permitted by applicable laws; and
details of our data protection complaints procedure.

1. COLLECTION, USE, DISCLOSURE AND PROCESSING OF YOUR PERSONAL DATA

1.1 By commencing an application with us, or when providing us personal data applying for any of the services and/or products we offer, you consent to us collecting, using, disclosing, and processing such personal data in the ways set out below.

1.2 This Privacy Policy covers personal data (including personal and credit information of you or your co- applicants, authorised third parties, joint card holders or any other person’s personal data that you provide in interactions with us, or to third parties including businesses who are related corporations, with whom we have an arrangement, partnership, or joint venture with) that may be collected, used, disclosed and/or processed by us. Where you provide personal data related to other persons, you warrant that you have informed them of the purposes for which we are collecting their personal data and that they have consented to your disclosure of their personal data to us (and our service providers and agents) for those purposes, including all purposes as set out in this Privacy Policy.

1.3 The types of personal data that we collect would vary based on the product or service that you sign-up for but could include the below (not an exhaustive list):

personal and contact details such as name, addresses and telephone number(s) including those previously held, email address, phone number and date of birth;
any information you provide us in your interactions with us including via the LatitudePay app, phone, email, or other means of communication;
employment information such as employment status, income, liabilities;
government issued identifiers where permissible by law and where required to meet our legal obligations;
your financial information including information from other financial institutions, transaction information on your accounts with our office including those made through our digital channels and those through third parties that work with us; and
personal data which you had previously provided to OctiFi Pte. Ltd. and its related corporations.

1.4 We also collect personal data from third party sources, for example (not an exhaustive list):

merchants;
other third parties with whom we have an arrangement or relationship with (such as OctiFi Pte. Ltd., its related corporations and third party service providers in respect of your existing account with OctiFi Pte. Ltd.);
from public agencies or other public sources;
a credit reporting body;
a third party with whom we have an arrangement, partnership or joint venture such as collection agents, research agencies, marketing agencies;
your employer;
another financial institution;
an introducer such as a broker, agent, dealer and retail partner;
someone authorised to act on your behalf (e.g. financial adviser, executor, administrator, trustee, guardian, attorney, accountant or consumer advocate);
a government body; and one or more of our related companies, in Singapore or overseas.

2. PURPOSES OF COLLECTION, USE, DISCLOSURE AND PROCESSING

2.1 We may collect, hold, use, disclose and/or process your personal data for one or more of the following purposes:

General

to verify your identity;
to conduct research and analysis to improve our products and/or services;
to develop new products and services
internal management purposes, including securitisation, risk management, credit scoring and portfolio analysis (including to help prevent defaults and deal with financial hardship);
provide you with the product(s) or service(s) and to manage those product(s) or service(s) through the entire lifecycle including assessing your application, preparing required documentation such as credit contracts, establishing your account, processing receipts, payments, and invoices;
to respond to legal processes or to comply generally with any applicable laws, governmental or regulatory requirements of any relevant jurisdiction (and any applicable rules, codes of practice or guidelines), and requests of any governmental or other regulatory authority with jurisdiction over us, including, without limitation, meeting requirements to disclose under the requirements of any applicable law, assisting in law enforcement and investigations by relevant authorities, conducting audit checks or surveillance and investigation, whether in Singapore or elsewhere;
to send you marketing materials;
such purposes that may be informed to you when your personal data is collected;
any other reasonable purposes related to the aforesaid or for which you have provided any information to us; and/or
any other incidental business purposes related to or in connection with the above;

Transactions

to assess your credit applications (including in relation to the guarantors provided by you);
to assist in the collection of overdue payments;
to participate in the credit reporting system;
to undertake securitisation activities and debt assignments; and/or
to conduct and complete transactions (including providing products or services that have been requested), performing our obligations or exercising our rights as set out in binding contractual terms, and otherwise to manage your relationship with us; Support and assistance
to facilitate customer service (e.g. providing information on status and updates) and to respond to your requests or any enquiries submitted by you or on your behalf;
to investigate and rectify technical issues; and/or

conduct feedback, analysis and development activities to improve your experience.

2.2 We may also collect, hold, use, disclose and/or process personal data for purposes related to that which you have provided the personal data, in circumstances other than set out in this Policy where required, or permitted, by laws applicable to us or in any relevant jurisdiction, or where we have obtained your consent through other means (for example, pursuant to notices at our premises).

2.3 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way (for example, where we use personal data to enforce our rights under a contract with you).

3. THIRD PARTIES WHO MAY BE PROVIDED WITH PERSONAL DATA

We may disclose your personal data to the following, whether located within or outside Singapore, for the purposes set out or otherwise referred to in this Policy:

third parties to whom you authorise our disclosure of your personal data (through this Form, the Policy or otherwise);
our auditors, professional consultants, lawyers and other advisors;
our business partners, service providers and/or agents (including organisations involved in our securitisation arrangements, who purchase our debt and/or to whom we assign our debt to);
insurers, credit providers, courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as agreed or authorised by law;
organisations wishing to acquire an interest in any part of our business (including its receivables) for assessing or implementing any such acquisition;
introducers such as brokers, dealers and retail partners and merchants;
service providers such as customer service organisations, call centres, mailing houses, researchers, collections agents, data analysts;
other financial institutions, credit providers, card schemes such as Mastercard or Visa;
your nominated referees;
additional cardholders, joint account holders or other persons (if any) authorised by you to operate or access your credit facility; and
organisations through whom you choose to make payments to us.

4. ACCURACY

We generally rely on the accuracy of personal data provided by you or your authorised representatives. In order to ensure that our records of your personal data is current, complete and accurate, please update us if there are changes to your personal data by writing to our Data Protection Officer at the contact details at the end of this Privacy Policy.

5. OTHER WEBSITES AND MOBILE APPLICATIONS

6. SECURITY AND RETENTION

6.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and loss of any storage medium or device on which your personal data is stored, we have introduced appropriate administrative, physical and technical measures, including to protect personal data from unintended access.

6.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure, and LatitudePay cannot and does not guarantee that our systems or applications are invulnerable to security breaches. LatitudePay makes no warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.

6.3 We keep your personal data only for so long as we need the personal data to fulfil the purposes we
collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or
reporting requirements. In some circumstances, we may anonymise your personal data so that it can no
longer be associated with you, in which case we are entitled to retain and use such data without
restriction.

7. ACCESS, CORRECTION AND OTHER REQUESTS

7.1 If you wish to make

(i) 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,

(ii) a correction request to correct or update any of your personal data which we hold about you, or
(iii) other request in relation to your personal data, as permitted by applicable data protection laws, you may submit your request by contacting the Data Protection Officer.

7.2 You may be required to submit certain forms or provide certain information in order for your request to be processed. Where permitted by law, we may charge you a reasonable fee to process your request, and will inform you of the fee before processing your request.

7.3 We will respond to your request as soon as reasonably possible, and in accordance with applicable law.

8. CONSENT WITHDRAWALS

8.1 The consent that you provide for the collection, use, disclosure and processing of your personal data will remain valid until such time it is withdrawn by you. You may withdraw consent and request for us to stop using and/or disclosing your personal data by submitting a request in writing to our Data Protection Officer at the contact details provided below.

8.2 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 will seek to process your request within ten (10) business days of receiving it.

8.3 If you withdraw your consent to any or all use of your personal data or do not consent to the collection of your personal data by us, we may not be able to provide or continue providing you with products and/or services which you have requested. You understand and agree that in such instances where LatitudePay requires your personal data to fulfil a contractual obligation to you and you withdraw your consent to collect, use, or disclose the relevant personal data for those purposes, LatitudePay cannot be held liable for breach of that agreement. LatitudePay’s legal rights and remedies in such event are expressly reserved.

8.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws in any jurisdiction.

9. Changes and revisions to this Privacy Policy

You acknowledge that we have the right to revise and amend this Privacy Policy. We will post any changes to this Privacy Policy through the LatitudePay app or our website, or such other means as we deem appropriate. Please refer back to this Privacy Policy regularly. Your continued use of the LatitudePay app, our products and services, or where you continue to provide personal data to us following our posting of any such changes will constitute your acknowledgement and acceptance of such changes.

10. Contact Us

Should you have any request or questions regarding this Privacy Policy, please contact our Data Protection Officer by email at dataprotection@latitudepay.asia.

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