Data Protection Policy
1 1 8 CREDIT (S) PTE LTD
Data Protection Policy (DPP)
Effective 2 July 2014
The Purpose of this notice (“Data Protection Policy”) is to inform you of how 1 1 8 CREDIT PTE LTD (“118 CREDIT”) manages your Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act. Please take a moment to read this Data Protection Policy so that you know and understand the purpose for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for services offered by us, I hereby authorize “118 CREDIT” collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclose such Personal Data to our authorized service providers and any credit bureau, approved or gazette by Registrar of Moneylenders and Insolvency & Public Trustee’s Office of which 118 Credit are members or subscribers (or to its compliance committee) in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provide to “118 CREDIT” in respect of your Personal Data, and your consents herein are additional to any rights which any of the companies may have at law to collect, use or disclose your Personal Data.
“118 CREDIT” may from time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your right at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updates from time to time on our website. Please check back regularly for updated information on the handling of your Personal Data.
1. Personal Data
In this Data Protection Policy, “Personal Data” refer to any data, whether true or not, about an individual who can be identified (a) from that data or other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us.
2. Collection of Personal Data
- Generally, we collect Personal Data in the Following ways:
- When you submit any form, including but not limited to application or declaration
- When you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
- When you interact with our staff, including customer service officers, relationship managers and other representatives for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
- When your images are captured by us via CCTV cameras or via photographs or videos taken by us.
- When you use our services provided online, such as our websites and subscribed directory
- When you request that we contact you or when you respond to our request for additional Personal Data.
- When you use our websites
- When you submit your Personal Data to us for any other reason.
- If you provide us with any Personal Data relating to a third party (e.g. informant on your employer, spouse, children or parents by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us within their Personal Data for the respective purpose.
- You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
3. Purpose for the Collection, use and Disclosure of Your Personal Data:
- Generally, “118 CREDIT” collects, uses and discloses your Personal Data for the following purpose :
- Responding to, processing and handling your complaints, queries, requests, feedback and suggestions ;
- Matching any Personal Data held which relates to you for any of the purposes listed herein ;
- Preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks ;
- Complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
- Any other purpose relating to any of the above; These purpose may also apply even if you do not maintain any loan with us, or have terminated these loans.
- In additional, “118 CREDIT” collects, uses and discloses your Personal Data for the following purpose depending on the nature of our relationship:
- If you are a prospective customer :
- evaluating your financial needs
- assessing and processing any applications or requests made by you for services offered by “118 CREDIT” ; and /or
- any other purpose relating to any of the above
- if you are guarantor :
- ensuring the ongoing credit worthiness of customer;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issues by any legal or regulatory bodies which are binding to “118 CREDIT” (including but not limited to disclosure to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence )
- any other purpose relating to any of the above
- If you are a prospective customer :
- In relation to our loan services or in your interactions with us, we will use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
- “118 CREDIT” will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties,
- 1. Credit reporting agencies ( DP Information Network Pte Ltd , Dun & Bradstreet (S) Pte Ltd , Credit Association Singapore (Formerly known as MLAS)
- Our professional advisors such as our auditors and lawyers;
- Relevant government regulators, government ministries, statutory boards or authorities and/ or law enforcement agencies, including the Money Authority of Singapore, the Accounting and Corporate Regulatory Authority, and the Insolvency and Public Trustee Office, to comply with any directions, laws, guidelines, regulations or schemes issued or administered by any of them.
- Our professional advisers such as our auditors and lawyers;
- Any other party to whom you authorize us to disclose your Personal Data to.
- When you interact with us on our website, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor on, what operating system a visitor is using a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page)
- Cookies are small text file store in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browser offer the option to refuse cookie, and if you refuse our cookie then we do not gather any information on that visitor.
- Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain party(s) of our website
6. Data Security
- “118 CREDIT” will take reasonable efforts to protect your Personal Data in our Control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, Trojan horses, spyware or adware). You should be aware of the risks associated with using our website.
7. Contacting Us – Feedback of your Personal Data
- If you :
- have any question or feedback relating to your Personal Data or our Data Protection Policy;
- would like to withdraw your consent to any use of your Personal Data as set out in Data Protection Policy ; or
- would like to obtain access and make corrections to your Personal Data records you can approach us via the following channels:
- Email us : firstname.lastname@example.org
- Call our hotline : 6835 7666
- Talk to our staff
- You may also write to our Data Protection Officers as follows :
Data Protection Officer
175A Bencoolen Street
#11-08 Burlington Square
Or email us: email@example.com
- If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, “118 CREDIT” may not be in a position to continue to provide service to you. Any withdrawal of consent may also result in the termination of any agreement you have with “118 CREDIT” and you being in breach of your contractual obligations or undertakings. “118 CREDIT’S” legal rights and remedies in such event are expressly reserved.
8. Governing Law
- This Data Protection Policy and your use of this website shall be governed in all respect by the laws of Singapore.