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The earlier announced transition of MoneyOwl’s fund management business and insurance advisory businesses to iFAST Financial Pte Ltd (“iFAST”) is complete. As part of this business transfer, we have transferred to iFAST the personal data of investment and insurance clients, in line with the provisions of the Personal Data Protection Act 2012 (“PDPA”), as well as MoneyOwl’s Privacy Notice
MoneyOwl will continue to operate and provide other services, including its existing online Will-Writing Tool and Comprehensive Financial Planning service, but will pause the Comprehensive Financial Planning service temporarily on December 15, 2023, 6:00pm for a refresh (but edits of existing digital plans are still possible). There are also new services planned for our clients. Your personal data will continue to be retained by MoneyOwl to continue serving you as it transits to its new model of operations.
WARRANTIES, DISCLAIMERS, AND LIMITATION OF LIABILITY
even if such events are foreseeable or even if we had had been advised of the possibility of such events occurring. For the purpose of this paragraph, the term “third party” includes a Third Party Provider.
1.2 Compliance with this Policy. This Policy applies to all personal data you provide to us, or that we may collect about you. Please do not provide any personal data to us if you do not accept this Policy.
We may also require you to accept this Policy when you contact, interact, transact or deal with us, or when you access and use our websites, applications or services. If you notify us that you do not accept this Policy, we may not be able to establish a relationship with you or be able to service your requests.
1.3 Concerns and Contacting Us. If you have any feedback or issues in relation to your personal data, or about this Policy, or wish to make a complaint to us, you may contact our Data Protection Officer whose contact details are set out below. If you wish to make a formal complaint, you may also do so with any data protection regulator or authority having jurisdiction over us.
Harry Ch’ng, Data Protection OfficerEmail address: DPO@moneyowl.com.sg
1.4 Amendment to this Policy. We may amend this Policy from time to time without notice to you, to comply with applicable laws or as we update our data usage and handling processes. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. The amended Policy will take effect when made available at www.moneyowl.com.sg.
2. Personal Data
2.1 What personal data we collect. The Personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. This may include your name, address, contact information (e.g. telephone number and email address), identification number, photograph, video image and any other information that may identify you or is personal to you.
2.2 How we collect personal data. We collect personal data in the course of or in connection with your relationship with us. We may collect your personal data directly or indirectly through various channels, including when:
Depending on your relationship with us, we may also collect your personal data from third parties, including:
Our website and applications may also contain or involve certain technologies that automate the collection of data (including personal data). These technologies include cookies, web beacons and web analytics. If you do not wish to have your data collected through such technologies you may disable the operation of these technologies on your devices (where possible), or you may refrain from using our websites and applications.
2.3 Voluntary provision of personal data. Your provision of personal data to us is voluntary and you have the right to withdraw your consent for us to use your personal data at any time by contacting and submitting a request to us. Your withdrawal will take effect after your request is processed. However, if you choose not to provide us with the personal data we require, it may not be possible for us to fulfil the purposes for which we require the personal data, including providing products and services which you need from us.
2.4 Providing personal data belonging to others. In certain circumstances, you may also provide the personal data of persons other than yourself (including your family members). If you do so, you are responsible for informing him / her of the purposes for which we require his/her personal data and warrant that you are validly acting on behalf of him/her to consent to our collection, use and disclosure of his / her personal data.
2.5 Accuracy and Completeness of personal data. You must ensure that all personal data that you provide is true, accurate and complete and promptly inform us of any changes to the personal data.
2.5 Minor. If you are a child, minor or not of legal age, please inform and seek the consent of your parent or guardian, before you provide your personal data to us. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us to request for the erasure of their personal data.
3.1 We collect, use and disclose your personal data where:
3.2 General purposes. Generally, we collect, use and disclose your personal data for purposes connected or relevant to our business, including:
3.3 Marketing purposes. If you have provided us with your consent, your personal data may be used for the purposes of marketing our products, events and services and those of our strategic partners and business associates (e.g. insurance companies, banks and financial institutions), and other organisations and enterprises which are part of the NTUC Social Enterprise Group. In order for us to market products, events and services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us, or data collected from your interactions with us.
In the event that you would like to withdraw your consent given to us, please email the Data Protection Officer at the email address set out in paragraph 1.4, and we will process your request accordingly.
3.4 Legitimate business interests.Our legitimate business interests include:
3.5 Purposes involving NTUC Social Enterprise Group. NTUC Enterprise has responsibility for the organisations and enterprises within the NTUC Social Enterprise Group. Some of our business and administrative functions are also served by NTUC Enterprise. For administrative efficiencies and to allow us to better serve your needs, your personal data may also be collected, used and disclosed to NTUC Enterprise and/or an organisation within the NTUC Social Enterprise Group for the following purposes:
3.6 Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law.
3.7 Contacting you. When using your personal data to contact you for the above purposes, we may contact you via email, e-mail, SMS, telephone, pop-up notifications (when you are using our applications), or any other means.
We will not contact you for marketing purposes unless with your consent, or we are exempted by applicable law from having to obtain consent. When contacting you for marketing purposes, we will not contact you through your telephone number, unless you have specifically consented to such a mode of communication. If you do not wish to receive any communication or information from us or wish to restrict the manner by which we may contact or send you information, you may contact us to do so.
3.8 Please note that should you not consent to provide us with the relevant personal data to fulfil the purposes of collection, use and disclosure of your personal information, it may hinder our ability to continue to service or interact with you.
3.9 Where consent is not obtained, we may collect, use and disclose your Personal Data pursuant to an exception under the PDPA or other written law when the use is necessary.
4. Disclosure of Personal Data
4.1 Disclosure to NTUC Social Enterprise Group. We may disclose or share your personal data with NTUC Enterprise and/or the NTUC Social Enterprise Group for the purposes described in paragraph 3.5.
4.2 Other Disclosures. We may also disclose or share your personal data in connection with the purposes described in paragraphs 3.2, 3.3 and 3.4 above, including to the following parties:
5. Cross Jurisdiction Transfers of Personal Data
5.1 We may transfer your personal data out of Singapore for the purposes set out in paragraph 3 above. When transferring personal data outside Singapore, we will require recipients of the personal data to protect personal data at a standard comparable to that under the laws of Singapore. For example, we may enter into legally enforceable agreements with the recipients to ensure that they protect your personal data. You may obtain details of these safeguards by contacting us.
6. Protection of Personal Data
6.1 Period of retention. We keep your personal data only for so long as we need the data to fulfil the purposes we collected it for, and to satisfy our business and legal purposes, including audit, accounting or reporting requirements. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Certain information may also be retained for longer, e.g. where we are required to do so by law. Typically, our data retention period is from 6 years upwards, depending on the limitation period. In the absence of a need to retain personal data, we will either delete or aggregate it or, if this is not possible then we will securely store your personal data and isolate it from any further processing until deletion is possible.
6.2 Anonymised data. In some circumstances, we may anonymise your personal data so that it no longer identifies you, in which case we are entitled to retain and use such anonymised data without restriction, including for data analytics.
6.3 Unauthorised access and vulnerabilities. While we take reasonable precautions to safeguard your personal data in our possession or under our control, we cannot be held responsible for unauthorised or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.
7. Your Rights
7.1 You enjoy certain rights at law in relation to your personal data that we hold or control. These rights include:
7.2 Other rights. Depending on the laws applicable to you, you may also enjoy additional rights. For example, if you are resident in the European Union, you may also enjoy certain additional rights, including:
7.3 Exercising your rights. If you wish to exercise your rights, you may contact us to do so (see paragraph 1.4 above for contact details).We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may charge you a fee to process your request. We may also be permitted under applicable laws to refuse a request.
7.4 Limitations. We may be permitted under applicable laws to refuse your request to exercise your rights, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
8. Personal Data Protection Policy (For Job Applicants)
8.1 We collect, use, disclose, and protect personal data in compliance with the PDPA. Personal data collected may include but not limited to, name, address, contact details, NRIC, or other identification number, telephone numbers, email address, photograph, video image, personal data of family members, education background, employment history, references and results of employment checks.
8.2 Voluntary provision of personal data. Your provision of personal data to us is voluntary. However, if you choose not to provide us with the personal data we require, it may not be possible for us to employ you, contact you, process your application, or consider you for employment.
8.3 Providing personal data belonging to others. If you provide the personal data of anyone other than yourself (such as your character references or family members), you warrant that you have informed him/her of the purposes for which we require his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes.
8.4 Accuracy and completeness of personal data. You must ensure that all personal data that you provide is true, accurate and complete and promptly inform us of any changes to the personal data.
8.5 Protection of personal data. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
To obtain further details, you can download the complete Personal Data Protection Policy (For Job Applicants) in the provided PDF.
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