Pocketwo Pte. Ltd. (collectively, “Pocketwo”, “we”, “our”, “us”), collects information about you when you apply for or sign up for an account (“User Account”) on our website or mobile application (collectively, the “Platform”), access or use the services offered by us through the Platform, or otherwise interact with us (collectively, the “Services”). This Privacy Policy outlines how we collect, use, store and disclose your Personal Data (as defined in Clause 3 below). This Privacy Policy should be read together with, and forms part of, our Terms of Service, which are available on the Platform. Unless otherwise defined herein, capitalised terms in this Privacy Policy have the meaning given to them in those Terms of Service. Pocketwo recognises the importance of protecting Personal Data and we are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws. Please read this Privacy Policy so that you know and understand the purposes for which we collect, use, store and disclose Personal Data. By accessing and using the Platform, interacting with us or providing your data to us, and subject to your rights at law, you accept and agree to these terms and conditions. If you do not agree with any aspect of this Policy, you should immediately discontinue access or use of the Platform and Services. This Privacy Policy supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which Pocketwo may have at law to collect, use or disclose your Personal Data. We may from time to time update this Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time. Please check back regularly for updated information on the handling of your Personal Data. 1. Personal Data You agree and consent to our collection, use, disclosure, and processing of your Personal Data as may be provided to or obtained by us, in accordance with this Privacy Policy. 2. Representations and Warranties You represent and warrant that: (a) before providing any Personal Data to us, you have read and understood our Privacy Policy and, in the case of Personal Data relating to an individual other than yourself, have (or will at the time of disclosure have) provided a copy of that Privacy Policy (as amended from time to time), to that individual; and (b) you have obtained all necessary consents from each individual to whom such Personal Data relates for the disclosure of such individual's Personal Data to Pocketwo and/or other relevant parties as specified in the Privacy Policy for Pocketwo and such other parties’ collection, use and/or disclosure for the purposes specified therein, that such consents have not been withdrawn, that such disclosure is made in accordance with all applicable data protection and data privacy laws, and that such data is accurate, up to date and relevant when disclosed. 3. Your Personal Data “Personal Data” refers to any data or information about an individual from which the individual can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which may be provided to us include (depending on the nature of your interaction with us): (i) your name, NRIC number, passport number or other identification number (which will be collected, used, processed and disclosed where permitted), telephone number(s), mailing address, email address, photograph and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you; (ii) information about your use of the Platform and Services, including cookies, IP addresses, transaction details, User Account details and membership details; (iii) proof of your address of residence (including as indicated in your utility or credit card bills); and (iv) your payment related information, such as your bank account or credit card information, and your credit history. 4. Collection of Personal Data (a) Generally, we collect Personal Data in the following ways: (i) when you submit forms relating to any of our Services, or submit any online queries; (ii) when you register for or use any of our Services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us; (iii) when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online forms (such as any “Contact Us” forms on our websites), social media platforms and emails; (iv) when you use or purchase our Services; (v) when you establish any User Account; (vi) when you carry out transactions on our platform or our Services; (vii) when you request that we contact you; (viii) when you respond to our request for additional Personal Data; (ix) when you ask to be included in an email or other mailing list; (x) when you respond to our promotions and other initiatives; (xi) when you respond to our market surveys; (xii) when you submit a job application; (xiii) when we receive references from business partners and third parties, for example, where you have been referred by them; (xiv) when you submit your Personal Data to us for any other reason; and (xv) when you browse the Platform. Please refer to the Use of Cookies section below at Clause 8 for more information. (b) We may monitor or record phone calls, your usage patterns and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. (c) If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out in Clause 4 above. 5. Use and Disclosure of Personal Data (a) Our business is to understand and meet your needs and provide you with the Services that you require. To do this effectively, we need to collect a range of Personal Data about you. (b) In general, we use and disclose your Personal Data for the following purposes: (i) to provide you with the Services that have been requested; (ii) to help us review, develop, improve, manage the delivery of and enhance our Services, including analysing future customer needs, conducting market research and data analytics; (iii) to communicate with you and respond to your queries, requests and complaints; (iv) to provide ongoing information about our Services which may be of interest to you; (v) to handle disputes and conduct and facilitate investigations and proceedings; (vi) to protect and enforce our contractual and legal rights and obligations; (vii) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks (including via anti money-laundering (AML), combating the financing of terrorism (CTF) and know-your-customer checks); (viii) to manage our business operations and to comply with internal policies and procedures; (ix) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving a Pocketwo entity; and/or (x) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities. (c) In addition, we may use and disclose your Personal Data for the following purposes: (i) If you have a User Account: (A) to process your application for the User Account; (B) to maintain your User Account; (C) to provide you with the Services which you have signed up for (including to facilitate and process transactions and to seek your authorisation for such transactions); (D) to verify your personal particulars and process payment requests in relation to provision of the Services which you may be entitled to or which you may have requested for. Given the nature of the Services and to combat risks associated with financial fraud, we may for the purposes of performing transactions on our Platform require you to provide proof of your identity to a high degree of fidelity, for instance, by asking for your NRIC or passport number, or other similar identification information; (E) to communicate with you on changes and development to our policies, terms and conditions and other administrative information, including for the purposes of delivering or performing the Services offered to you; (F) to resolve complaints and handle requests and enquiries; (G) to conduct market research for statistical, profiling and statistical analysis for the improvement of Services provided to you (including through the use of server log or device information); and/or (H) to process your Personal Data in relation to any of the purposes stated in Clause 5(c)(i) above or as may be reasonably expected from your having a User Account with us. (ii) If you are a vendor, a prospective vendor or a contractor: (A) to evaluate your proposals and to conduct background checks on you or your staff; (B) to communicate with your deployed staff after award of contract who are providing products or services to us, and for any emergency or/and security concerns; and/or (C) any other purpose relating to any of the purposes stated in Clause 5(c)(ii) above or as may be reasonably expected from your being our vendor, prospective vendor or contractor. (iii) If you submit an application to us as a candidate for employment or you are an existing employee: (A) to process your application including pre-recruitment checks; (B) to provide or to obtain references for background screening/vetting; (C) to collect information about your suitability for the position applied for; (D) to provide remuneration, review salaries and bonuses, conduct salary benchmarking reviews, staff appraisals and evaluation, as well as to recognise individuals for their services and conferring awards; (E) to facilitate staff orientations and entry processing; (F) to facilitate administrative and support processes relating to your employment, including its management and termination, as well as staff benefits, including travel, manpower, business continuity and logistics management or support, processing expense claims, medical insurance applications, leave administration, training, learning and talent development, and planning and organising corporate events; (G) to provide you with tools and/or facilities to enable or facilitate the performance of your duties; (H) to compile and publish internal directories and emergency contact lists for business continuity; (I) to manage corporate social responsibility projects; (J) to conduct analytics and research for human resource planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity; (K) to ensure that the administrative and business operations of Pocketwo function in a secure, efficient and effective manner (including but not limited to examining or monitoring any computer software and/or hardware installed within Pocketwo, your work emails and personal digital and storage devices); (L) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks or surveillance and investigation); (M) to administer cessation processes; and/or (N) any other purposes relating to any of the purposes stated in Clause 5(c)(iii) above or as may be reasonably expected from your candidacy for or existing employment with us. (d) The above purposes are not exhaustive, and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions. (e) If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our Services (including discounts and special offers). (f) Your Personal Data may be disclosed to or shared with any of the following entities or persons for the purposes stated in Clauses 4 or 5 above: (i) Third-Party Payment Portals; (ii) other divisions or entities within Pocketwo; (iii) our joint venture/alliance partners and business partners; (iv) our agents, contractors, vendors, service providers and advisers, including those who have been contracted, to provide us with administrative, financial, research, operational, IT or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival; (v) any business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not; (vi) insurers or insurance investigators and credit providers; (vii) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres; (viii) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving Pocketwo; (ix) our professional advisors such as our auditors and lawyers; (x) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; (xi) anyone to whom we transfer or may transfer our rights and obligations; (xii) banks, credit card companies and their respective service providers; and (xiii) any other party as may be consented to by you, as specified by that individual or in the applicable contract. 6. How long we retain your data We retain your personal data as long as you’re using Pocketwo. In some circumstances, like cases of anti-money laundering or fraud, we may keep data longer if we need to and/or if required by law. 7. Keeping Your Personal Data Accurate and Up To Date We endeavour to ensure that all Personal Data we have about you is accurate and up to date. If there is any change in your personal particulars, contact information or other relevant circumstances which may cause your personal data to become incomplete or outdated, please contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with Services you have requested. 8. Use of Cookies (a) When you interact with us on the Platform, we automatically receive and record information on our server logs. 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 Platform, what kind of browser a visitor is 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). (b) Cookies are small text files stored 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-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor. (c) 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 part(s) of our Platform. 9. Third-Party Websites Our Platform may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Platform. We encourage you to learn about the privacy policies of such third-party websites. Once you have left our Platform, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you. 10. Withdrawal of Consent You may in certain circumstances withdraw your consent given for any purposes set out in this Policy. To withdraw your consent, you should contact us in accordance with Clause 11 below. If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our Services to you. 11. How to contact us If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please contact us immediately via any of our channels. 12. How we protect your Personal Data We use appropriate technical, organizational, administrative and physical security measures to protect any information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Unfortunately, no company or service can guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We also limit access to your Personal Data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your Personal Data on our instructions and may be subject to a duty of confidentiality in appropriate cases. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 13. International Data Transfers We may transmit or transfer Personal Data from one jurisdiction to another, and where we do so we will protect Personal Data in accordance with applicable Laws. 14. Children We do not knowingly collect or solicit Personal Data from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under 18, we will delete that information as soon as possible. If you believe that a child under 18 may have provided us Personal Data, please contact us at Clause 11 above.