Last
Updated: 24 October 2024
Your personal information is important to us
and it is our policy to respect and protect your personal information.
This Privacy Policy outlines how we collect,
use, manage and share personal information, including special or sensitive
personal data, that we collect through our internet-based platform, accessed
via our website at pointsource.co (the “ Platform”), as well as personal information
collected from time to time from other lawful sources. It also tells you how you can exercise your
privacy rights.
If you
have any questions or concerns about our use of your personal information, then
please contact us using the contact details provided at the bottom of this
Privacy Policy.
1.
What personal information do we collect about
you?
Personal information is any information that
can be used to identify you or that we can link to you and which we have in our
possession or control.
The types of personal information that we
collect about you, directly or indirectly,
typically include: your name, contact details, your employer or
organisation that you represent and certain details related to your employment,
e.g. your job designation and work related contact details.
We collect or receive personal information in a
few different ways:
Information you provide to us:
We collect personal information from your
interactions with us via the Platform (for example, when you register as a
user, when you communicate with us or other parties on our Platform or where
you have consented to our Customer providing such information to us) or
personal information that you otherwise give to us (for example, when you email
us or contact us via other channels).
Often, you choose what personal information to provide to us, but
sometimes we require certain information in order for you to use, and for us to
provide you and/or the organisation you represent with, the Platform and our
services.
Information we obtain from other sources:
From time to time, we may also collect or receive information about you from
third party sources such as publicly available databases, credit reference
agencies and other lawful sources. We may collect this information to assist us
in providing, evaluating and improving our Platform, products and services, or
to help us comply with legal and compliance requirements including but not
limited to compliance with anti-money laundering and sanctions regulations. We
will only collect information from third party sources where these third
parties have represented that you gave your consent to disclose your personal
information with us or that they are otherwise legally permitted or required to
disclose your personal information to us.
Information collected automatically
through your use of our Platform: We
will also collect information on an automated basis when you use our Platform
or our services. We log usage data when you visit or otherwise use our
Platform. Specifically, the information we collect automatically may include
information like internet protocol (“IP”) address, device type, unique device
identification numbers, browser-type, broad geographic location (e.g. country
or city-level location) and other technical information. We may also collect
information about how your device has interacted with our Platform, including
the pages accessed and links clicked.
We may also collect precise geolocation data
pertaining to your device, if you have consented to providing this to us
through your device settings. We may use this information to provide, promote,
and improve our services (for example, understanding the country you reside in)
and for related reasons, such as sanctions, fraud prevention and security
purposes. Please note that if you do not consent to providing your geolocation
data, certain features of the Platform may not work.
The information we collect automatically
enables us to better understand the visitors who come to our Platform, where
they come from, and what content on our Platform is of interest to them. This
enables us to improve the quality and relevance of our Platform to our
visitors.
We use cookies and similar technologies (e.g.,
web beacons, pixels, ad tags and device identifiers) to recognize you and/or
your device(s) on, off and across the Platform, including when you use
different devices. To learn more, please review our cookie policy located at
[insert URL/ hyperlink]
In addition to collecting and processing
personal information, the following types of data about your use of the
Platform and/or your use of our services, may also be collected for the
following purposes:
·
metadata (ancillary usage data, e.g. IP
address) may be used for providing services and related internal or regulatory
compliance uses, such as the provision of service performance statistics);
·
anonymised data and anonymised aggregated data
(anonymised data aggregated with anonymised data from other service provider
users) may be used for providing, maintaining and supporting the service
provider services, compiling statistical reports, performance tracking,
transaction categorisation and merchant identification services.
2.
How do we use your personal information?
We rely on one or more of the following lawful
grounds to collect, use, process and disclose your personal information:
• Purposes of collection:
We may use your personal information for the purposes described in this Policy
or of which you have otherwise been notified of.
• Consent: We may use
your personal information for the purposes you have consented to.
• Performance of a
contract: We may need to collect and use your personal information
to fulfil the contract between us and our Customer for the services requested
and/or to perform our obligations under such contract.
• Compliance with law or
regulation: We may use your personal information as necessary to
comply with applicable law/regulation.
We may collect, use, process and disclose your
personal information for the following purposes (and subject to your further
consent if required by applicable law):
· providing
you and/or the organisation you represent with products and services as
subscribed to or requested by you, including products and services provided by
our affiliates, joint venture partners, business alliance partners, Customers,
and other relevant third party providers
· processing
applications for products and services and completing instructions or requests;
· providing
customer service, customer support and technical support, including in relation
to product updates;
· market
research and surveys with the aim of improving our products and services;
· marketing,
business development and promotional purposes;
· for our
legitimate business interests, such as undertaking business research and
analysis, managing our operation of the Platform and our business;
· investigating
any complaints or queries you may have;
· to comply
with and monitor compliance with applicable laws and regulations, including
without limitation laws and regulations relating to anti-money laundering,
anti-bribery and trade sanctions), voluntary codes, internal policies
(including that of our affiliates’), contractual obligations (including between
us and our affiliates) and other requirements;
· preventing
and responding to actual or potential fraud or illegal activities;
· maintaining
the security of the Platform, including to verify your identify, to investigate
or prevent possible or actual fraud or other violations of any agreement
between us and the employer or organisation you represent, our User Terms or
this Privacy Policy and/or in connection with possible attempts to harm our
users, visitors, or other third parties;
· To seek
professional advice, including in connection with any legal proceedings
(including any prospective legal proceedings), for obtaining legal advice or
for establishing, exercising or defending our legal rights;
· where you have applied for a position with us,
to review and process your job
application.
We may also record or monitor your use of our
Platform and services for our business purposes which may include analysis of
usage, measurement of site performance and generation of reports.
We may also collate, process and share any
statistics based on an aggregation of information held by us provided that any
individual is not identified from the resulting analysis and the collation,
processing and dissemination of such information is permitted by law.
3.
How do we share your information with third
parties?
Depending on the purpose of processing your
personal information, personal information may be disclosed to:
• our affiliates anywhere in the world,
including any officer, employee, agent or director of any affiliate;
• our joint
venture partners, business alliance partners, third party providers of related
services (including financing services) or other investors or potential
investors (in connection with the actual or potential merger, sale,
acquisition or investment), provided we inform the relevant third party it must
use your personal information only for the purposes disclosed in this Privacy
Policy;
• our professional advisers and other
service providers in order to provide administrative, financial, legal,
accounting, information technology, authentication, research or other services;
• anyone authorised by you or the
employer or organisation you represent, as specified by you or the employer or
organisation you represent or in any contract with you or the employer or
organisation you represent;
• any person to whom disclosure is
required or permitted under applicable laws or regulations;
• anyone we consider necessary to
facilitate requests for services or applications for products in relation to
the Workspace you access; and
• anyone we consider necessary in order
to provide services in connection with a product or service, including our
Customer and their nominated Users.
The persons identified in this paragraph 3 may
contact you directly to obtain additional information necessary for the
purposes set out in this Privacy Policy. We may be kept in copy or may
otherwise be kept informed of such communications on the Platform and may
assist you in ensuring that the requisite additional information is provided.
4.
Keeping your data secure
The security of your personal information is
important to us. We use appropriate technical and organisational measures to
protect the personal information that we collect and process about you,
designed to provide a level of security appropriate to the risk of processing
your personal information. While we
monitor our systems for possible vulnerabilities and attacks, we cannot
guarantee 100% security of any information that you send us. Accordingly, you
will not hold us liable for any unauthorised disclosure, loss or destruction of
your personal information arising from such risks.
When using external service providers, we
require that they adhere to security standards mandated by us. We may do this
through contractual provisions, including any required by relevant privacy
regulators, and oversight of the service provider.
Personal information may be transferred to, or
stored at, locations outside of Singapore or the place of original data
collection. In all cases, however, any transfer of your personal information to
another location will be compliant with applicable data protection law.
Regardless of where personal information is transferred, we will take steps to
ensure that appropriate technical and organisational measures are put in place
to protect your personal information.
5.
Data Retention
We retain your personal information in line
with our legal and regulatory obligations and for business and operational
purposes. The period of retention will vary in accordance with the data type,
the purpose for which are processing your personal information and our legal
obligations. Subject to applicable law, we will cease to retain your personal
information when we no longer require such personal information for the
purposes we originally notified you of or for any business or legal needs.
6.
Your rights
You may have a variety of data protection
rights, depending on your geographical location and applicable law. These
rights may include:
• the right to request access to
the personal information we hold about
you (please note that there may be circumstances in which we are entitled to
refuse requests for access to copies of personal information);
• the right to request that we correct
or update your personal information if it is inaccurate or incomplete;
• the right to request withdrawal of
consent to process your personal information (please note that in certain
circumstances it may be lawful for us to continue processing without your
consent).
You can exercise your rights by contacting the
Data Protection Officer using the contact details set out below.
7.
Updates to this Policy
We may update this Privacy Policy from time to
time in response to changing legal, technical or business developments. When we
update our Privacy Policy, we will take appropriate measures to inform you,
consistent with the significance of the changes we make. We will obtain your
consent to any material Privacy Policy changes if and where this is required by
applicable data protection laws. You can see when this Privacy Policy was last
updated by checking the “last updated” date displayed at the top of this Privacy
Policy.
8.
Third party websites and services
The Platform may contain links to third-party
websites or mobile apps, including social sharing features and other related
tools. The Platform may also permit you to set settings to allow your data to
be disclosed to third parties for the purpose of such third parties providing
products and services to you (such as our joint venture partners, business
alliance partners and other third party providers of related services
(including finance services)). We will always endeavour to require our joint
venture partners, business alliance partners and other third party providers of
related services on the Platform to comply with applicable data protection
laws, such as through contractual provisions. However, please be aware that we
do not control these third parties, third party websites or apps or their
collection or processing of your personal data. This Privacy Policy does not
apply to any information you give to the owner of these third party websites or
apps or that are otherwise collected by these third parties. We encourage you
to read the privacy policy of any third party before you provide them with any
information or request or accept services from such third parties.
9.
Contacting us
You may contact us by writing to our Data Protection Officer at privacy@pointsource.co.