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1. Introduction
1.1 This Privacy Policy sets out the regulations and policies of Personal Data processed by Fin Points Technology
Pte. Ltd. (“FinPoints”, “we” or “us”) in accordance with the Personal Data Protection Act 2012 of Singapore.
1.2 By accessing FinPoints’ mobile application, you undertake that you have read, understood and accepted the
terms of the Privacy Policy. Your usage or ongoing usage of FinPoints’ Services shall also be taken as your
consent to be legally bound by this Privacy Policy.
1.3 You acknowledge that FinPoints reserves the right to amend or update this Privacy Policy at any time without
prior notice to you. The amendments to the Privacy Policy shall become effective immediately upon publication
on FinPoints’ mobile application. You shall regularly review this Privacy Policy on the FinPoints’ mobile appli-
cation.
2. Definitions And Interpretations
2.1 Throughout this Privacy Policy, unless the context otherwise requires, the following words and expressions shall
bear the following meanings:
(a) “FinPoints” means Fin Points Technology Pte. Ltd. (Company Registration No. 201930020R) whose
registered office is located at 1 Temasek Avenue, #24-01A, Millenia Tower, Singapore 039192.
(b) “PDPA” means the Personal Data Protection Act 2012 of Singapore and its respective published
amendments.
(c) “Personal Data” means “data, whether true or not, about an individual who can be identified:
(i) from that data; or
(ii) from that data and other information to which the organisation has or is likely to have access”,
as provided by the Personal Data Protection Act 2012 of Singapore.
(d) “Services” means the services as provided in FinPoints’ mobile application.
2.2 The headings to the clauses and sections in this Privacy Policy are for reference only, and shall be ignored
when construing the meaning of any provision of this Privacy Policy.
3. Personal Data Collected
3.1 We collect your Personal Data from the following methods:
(a) client on-boarding or application or other forms;
(b) communication with FinPoints via telephone, fax, email or other forms of electronic communication;
(c) FinPoints’ associates or related companies;
(d) your appointed agents, representatives or advisers;
(e) when you visit our mobile application or use our Services (to collect Personal Data described in Clause
3.2(g) and (h) below); and
(f) publicly available sources or third parties when we need to conduct background checks on you.
3.2 Personal Data collected by FinPoints includes but not limited to the following:
(a) your personal details, e.g. name, telephone number, email address;
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(b) identity verification documents, e.g. ID, passport;
(c) financial details, e.g. bank account, payment card information;
(d) information about your income and wealth including details about your assets and liabilities, account
balances, trading statements, tax and financial statements;
(e) profession and employment details;
(g) your use of Services, including but not limited to the pages you have visited; and
(h) technical information, including but not limited to your devices, type and version of the operating system,
time zone.
4. Purpose of Personal Data Collected
4.1 You consent and allow FinPoints in processing the Personal Data:
(a) to provide the Services;
(b) to comply with applicable laws, regulations and directions from regulatory authorities;
(c) to verify your identity;
(d) processing payment or credit transactions;
(e) to monitor and record calls and electronic communications for processing and verification of instructions;
(f) to monitor and record calls for business analysis, training or service improvement purposes;
(g) to ensure that the content can be displayed or updated on your device;
(h) in providing suitable marketing materials or information to you;
(i) any other purposes that we notify you at the time of obtaining consent;
(j) any other purposes incidental or relevant to the above
5. Disclosure of Personal Data
5.1 FinPoints may disclose your Personal Data to third parties:
(a) under any requests and orders from regulatory authorities;
(b) to meet our legal and regulatory obligations;
(c) in compliance with any requests made by legal and regulatory authorities;
(d) if it is necessary to perform FinPoints’ contractual obligation, including but not limited to FinPoints’ as-
sociates or related companies or third party service providers whereby they shall strictly comply with
the PDPA and this Privacy Policy; or
(e) when you have given us consent.
5.2 We may disclose your Personal Data to the following authorised third parties:
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(a) relevant regulatory authorities when we are required to do so;
(b) your appointed auditors and professional advisors;
(c) your appointed agents, representatives or advisers;
(d) our third party service providers who are necessary to perform our contractual obligations to you;
(e) banks or other financial institutions;
(f) our advisers or agents where it is necessary for us to obtain their advice;
(g) our auditors when it is necessary for them to perform their auditing functions;
(h) our technological or data storage provider;
(i) third parties appointed to conduct customer background checks;
(j) third parties and their advisers who are seriously interested in acquiring all or part of our business;
(k) other third parties who are necessary to perform our contractual obligations with you.
6. Retention Period
6.1 FinPoints shall retain your Personal Data in accordance with Section 25 of the PDPA. We shall cease to retain
your Personal Data as soon it is reasonable to assume that:
1.
(a) the purpose for which that personal data was collected is no longer being served by retention of the
personal data; and
(b) retention is no longer necessary for legal or business purposes.
7. Management of Personal Data
7.1 FinPoints has taken all reasonable commercial standards of technology and operational security to safeguard
your Personal Data and mitigate potential risks of a security breach.
7.2 FinPoints train our employees and provide internal educational trainings to the employees handling Personal
Data to respect the confidentiality of customer information and the privacy of individuals. Furthermore, FinPoints
implemented procedures to safeguard Personal Data where employees are only given access to your Personal
Data if it is necessary to perform FinPoints’ contractual obligation.
7.3 You acknowledge that FinPoints cannot guarantee on the absolute protection and security of the Personal Data.
You acknowledge that FinPoints shall not be liable for any malicious and fraudulent acts committed by third
party beyond FinPoints’ control provided that FinPoints has taken all reasonable commercial standard of care
and has not been negligent in safeguarding your Personal Data.
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8. Client’s Right
8.1 Under the PDPA, you retain the right to:
(a) access your Personal Data;
(b) inquire FinPoints whether the Personal Data has been disclosed by FinPoints within a year before the
date of the request;
(c) rectify or amend your Personal Data;
(d) restrict the processing of Personal Data;
(e) object against Personal Data processing for direct marketing purposes; or
(f) demand FinPoints to delete and erase your Personal Data.
8.2 You acknowledge that FinPoints may need your Personal Data to fulfill its contractual obligation with you, and
as such your demand for deletion of your Personal Data may result in termination of all Services provided by
FinPoints.
9. Jurisdiction
9.1 All disputes or differences which shall at any time arise between the Parties concerning this Agreement or its
construction, or the effect or the rights, duties or liabilities of the Parties under it, or any other matter in any way
connected with or arising out of the subject matter of this Agreement shall be referred to a single arbitrator to
be agreed upon by the Parties, or in default of agreement to be nominated by the Director for the time being of
the Singapore International Arbitration Centre in accordance with the International Arbitration Act.
9.2 This Privacy Policy shall be governed by and construed in all respects in accordance with the laws of Singapore,
and the parties agree to submit to the non-exclusive jurisdiction of the courts of Singapore.
10. Language
10.1 The official language of this Privacy Policy shall be English. We may provide this Privacy Policy in other lan-
guages for information purposes only and in the event of any inconsistency or discrepancy between the English
version of this Privacy Policy and any other language version, the English version shall prevail.
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