- 1.1 This Policy provides information on the obligations and policies of EF in respect of Personal Data. EF undertakes to use reasonable efforts in applying these principles and the processes set out in its operations.
- 1.2 For the purposes of this Policy and in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of EF or that which shall be collected by EF in the future.
- 1.3 EF’s officers, management, and members of staff shall use reasonable endeavors to ensure that all collection, storage, disclosure and/or usage of Personal Data shall be done in an appropriate manner in accordance with the PDPA and this Policy, and to respect the confidentiality of and keep safe any and all Personal Data collected, stored, disclosed and/or used for, or on behalf of, EF.
- 1.4 By interacting, registering, submitting information to, signing up for or in general accessing https://www.efundsme.com/ and its sub-webpages (collectively “Platform”), you agree and consent to EF as well as its representatives and/or agents collecting, using and disclosing your Personal Data, including disclosing such Personal Data to EF’s authorised service providers and relevant third parties in the manner set forth in this Policy.
- 1.5 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to EF in respect of your Personal Data, and your consents herein are in addition to any rights which EF may have at law to collect, use or disclose your Personal Data.
2. Data Protection Officer (“DPO”)
- 2.1 Where you legitimately request the correction of and/or access to your Personal Data which is in the possession and control of EF, EF shall provide and/or correct that data within a reasonable timeframe and in accordance with its standard procedures as stated hereinafter.
- 2.2 In accordance with the PDPA, EF has established a process for receiving and responding to any query or complaint that may arise with respect to the application of the PDPA. To ensure that EF receives your complaints and enquiries, please send the same via email to the DPO at firstname.lastname@example.org.
- 2.3 If your Personal Data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to EF on your behalf.
- 2.4 Should you not wish EF to use your Personal Data or not to receive materials or communications from EF, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within thirty (30) days. Please note however that this will affect our ability to attend to your needs.
3. Statement of Practices
- 3.1 As part of its day-to-day activity, EF may collect from you, through various means including via the Platform, events, and any forms used by EF from time to time, some or all of the following Personal Data:
- Name (first and surname);
- Postal Address;
- Country of birth;
- Phone number (including mobile);
- Office number;
- Email address;
- Date of birth;
- Bank account details;
- IP addresses; and
- Photographs and images.
- 3.3 EF collects Personal Data for processing your registration and to provide you with services which you may require; to conduct market research and analysis; for direct communications and marketing through voice calls; text messages; email; direct mail and facsimile messages; for payment purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification; maintaining and updating your details; and informing you of new developments, services, promotions of EF and other third parties which we are associated with.
- 3.4 In order to carry out the functions described above, EF may, from time to time, disclose your Personal Data to the following:
- Regulators and law enforcement officials;
- Third party service providers, consultants and vendors;
- Banks and other entities processing payment;
- Potential buyers or investors of EF or any of EF’s affiliates; and
- Any agent or subcontractor acting on EF’s behalf for the provision of EF’s services.
- 3.5 EF may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
- To the extent that EF is required to do so by the law;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise or defend EF’s legal rights;
- To the purchaser (or prospective purchaser) of any business or asset which EF is (or is contemplating) selling;
- To any person and/or entity for the purpose of processing such information on EF’s behalf;
- To third parties who provide services to EF or on its behalf;
- To any third party that purchases EF or EF’s business or any part of EF or EF’s business;
- With your consent; and
- For the purposes of disaster recovery.
Optional Provision of Personal Data
3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve EF’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional, although failure to provide the requested data may prevent EF from providing the service to you.
3.7 Under certain circumstances, telephone calls made to EF may be recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.
4. Transfer of Personal Data Overseas
Personal Data will be processed by EF, its affiliates, agents and third parties providing services to EF in Singapore, in jurisdictions outside of Singapore, as well as the country which you are residing in. At all times, EF will comply with the requirements of the PDPA.
5. Accuracy of Personal Data
Where possible, EF will validate data provided using generally accepted practices and guidelines. To assist in ensuring the accuracy of your Personal Data in the possession of EF, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
EF uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside EF, other than to you or as described in this Policy. However, EF cannot ensure or warrant the security of any information you transmit to EF and you do so entirely at your own risk. In particular, EF does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of EF’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
- check whether EF holds any Personal Data relating to you and, if so, obtain copies of such data; and
- require EF to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 EF reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a) and (b). Upon payment of the administrative fee as advised by EF, your request shall be processed within 30 days.
7.3 If you wish to verify the Personal Data you have submitted to EF or if you wish to check on the manner in which EF uses and processes your Personal Data, EF requires proof of identity before releasing any Personal Data. You must therefore keep such information of proof of identity safe as you will be responsible for any action which EF takes in response to a request from someone using your details.
8. Storage and Retention of Personal Data
EF will delete, as reasonably possible, or otherwise anonymize any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of EF and where the Personal Data is deleted from EF’s electronic, manual, and other filing systems in accordance with EF’s internal procedures and/or other agreements.
9. Contacting you
You hereby grant EF your clear and unambiguous consent to contact you using all of your communication means you have provided to EF including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated herein. It is your responsibility to inform EF of any withdrawal of consent, should you wish to withdraw such consent.
10. Change Policy
EF reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by EF. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection, use and disclosure of Personal Data by EF. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. EF is not responsible for the privacy and conduct practices of these third party websites, so you should read their privacy policies before disclosure of any Personal Data to these websites.
12.2 EF will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to EF’s Platform.
12.3 The Platform does not target and is not intended to attract children under the age of 18 years old. EF does not knowingly solicit Personal Data from children under the age of 18 years old or send them requests.