COLLECTION OF PERSONAL DATA
Personal data refers to data about an individual who can be identified from either that particular data, or from that data and other information which Incubatrix has or is likely to have access to. Such personal data shall also refer to the data which is already in our possession or the data to be collected by us.
Commonly collected personal data of our Users include (but is not limited to):
personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
financial details (e.g. income, expenses, and/or credit history);
images and voice recordings of our conversations with you;
employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
tax and insurance information;
information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
to the extent that a User is an entity, information about individuals who will act on behalf of the entity, detailed financial and business information about the entity;
trading/banking information (e.g. bank account numbers);
credit card number and related account and billing information;
invoice related information (e.g. payment terms, payment due date, quantum); and/or
personal opinions made known to us (e.g. feedback or responses to surveys).
Collection of personal data
Wherever possible, we only collect personal data directly from you. Without limitation, this can occur during or before you: -
register for an Account;
submit an application or request for the use of Services;
use the Services; and/or
submit, post or upload any User-Generated Content;
In addition to personal data provided to us, certain information related to you that is not considered personal data may also be collected. We collect this information to improve the Platform and/or Services. Such non-personal data may include information such as your IP address, the internet browser and operating system you use, details of your interaction with the Platform and/or Services, preferences and other types of non-personal data. We use this information about your computer to perform routine Platform maintenance, to generate aggregate Platform traffic reports and enhance the performance of our Platform on different browsers and devices.
We may also receive personal information about you from other sources if you have given permission for that information to be shared. This may include information from commercially available sources, such as public databases and data aggregators, and information from third parties.
USE OF PERSONAL DATA
Using your personal data
We collect personal data from our existing and prospective Users and employees for various reasons. Without limitation, these purposes include:-
providing and improving our Services and your experience on the Platform;
authenticating your access to the parts of the Services that you are authorized to access;
reviewing, processing and confirming any request or application submitted by you in connection with the use of the Services, including the processing of any Transaction, collection of fees and distribution of returns;
conducting Background Checks;
analyzing the effectiveness of our advertisements, competitions and promotions;
customising your Platform experience, as well as evaluating statistics on Platform and Service activity, such as what time you visited it, whether you have visited it before and what site referred you to it;
making the Platform easier to use and tailoring the Platform and/or Services to the interests and needs of our Users;
marketing and communicating with you in relation to the Services offered by us, our dealers and relevant service partners;
processing, managing and administering Accounts in relation to your use of the Services;
sending you information you have requested;
responding to your comments or queries;
resolving disputes, collecting fees, distributing returns, troubleshooting problems;
fulfiling a legal or regulatory requirement;
detecting, preventing or otherwise addressing fraud or security issues;
improving the quality of the Services with market research and surveys;
supplying you with information that is relevant to your existing relationship with us; and/or
suggesting products or services which we think may interest you.
Personal data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for legal or business purposes.
Sharing your personal data
Incubatrix shares your personal information with trusted third parties and strategic partners that assist Incubatrix with its business operations and to provide the Services. We may also share your personal data with trusted third parties and strategic partners that help Incubatrix market to Users and potential Users. Such parties may either be in Singapore or abroad and may include:
any member in our Group;
our advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions;
financial service providers and payment providers including credit card companies and their services providers to enable Users to qualify to use the Services;
third parties for the purpose of raising funds in respect of the Transactions;
third parties required to process or deliver Services to you including but not limited to payment protection providers, insurance companies, country managers, freight forwarders, inspection agents, logistics providers, financing providers, sales support and marketing agents;
law enforcement or government authorities where they have followed due legal process to request us to disclose the information;
third parties who wish to send you information about their products and services, but only if you have given us your consent to do so;
third party providers of services, such as data processing; and/or
web analytics tool providers, such as Google.
We share your personal data for the following reasons: -
reasons provided under ‘using your personal data’;
verification of your identity;
processing Transactions for the use of our Services;
to protect the rights or property of any member of the Group (including but not limited to any intellectual property rights);
to respond to claims that you violated the rights of third-parties;
to conduct investigations into possible breaches of applicable laws; and/or
to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate.
In situations where a third party under contract with Incubatrix collects personal data about you, we use commercially reasonable efforts to require the third party to exercise reasonable care in protecting your information.
AMENDMENTS TO PERSONAL DATA / OPT OUT
You have a right to access, change and remove the personal data held by Incubatrix. If you wish to do so, please contact our Data Protection Officer at firstname.lastname@example.org. You may also access, change and remove your personal details by clicking on 'My Account'. You may also decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive.
To the extent not required by Incubatrix in connection with providing the Services, if you do not want your personal data to be shared among affiliates, business partners or unrelated third parties, you may opt-out of such information sharing by sending us an email at email@example.com.
Incubatrix uses reasonable measures to protect your personal data and to store it securely. Where personal information is entered on the Platform, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) technology. However, due to the inherent nature of the Internet as an open global communications vehicle, no method of transmission over the Internet or method of electronic storage is 100% secure. While security cannot be guaranteed, we strive to protect your personal data and are constantly reviewing and enhancing our security protocols to ensure that your personal data is not subject to unnecessary risks.
TRANSFER OF PERSONAL DATA
We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
In the event that Incubatrix, or substantially all of its assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such data bases containing User personal information may be one of the transferred assets. In using the Platform and/or the Services, you consent to such transfer of your personal data.
Incubatrix is committed to complying with the Do Not Call ("DNC") provisions set out in the PDPA. If you have registered your telephone number with the DNC Registry, Incubatrix will not send you promotional and marketing messages via phone calls, text messages and faxes. However, if you have previously given Incubatrix consent to contact you for such purposes, we will continue to do so until you withdraw your consent. If you no longer wish to receive marketing and/or promotional messages from Incubatrix and had previously provided Incubatrix with your consent to do so, you can withdraw your consent by contacting us at firstname.lastname@example.org.