Privacy Policy

PRIVACY POLICY FOR USERS

This Privacy Policy (“Policy“) sets out the manner in which GIVEPLEASE PTE. LTD. (“we“, “us“, or “our“) may collect, use, manage, disclose or otherwise process personal data of all users of this application, terminal, platform, or website (as the case may be) in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) as may be amended from time to time (“PDPA“). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Policy:

“user” means an individual or organisation who uses our application, terminal, platform, website or any other software or product which we may introduce from time to time, whether for the purposes of providing or collecting a donation or otherwise;

“personal data” means data, whether true or not, about a user who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access; and

“Platform” means our application, terminal, platform, website or other service which is used by you.

2. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF DATA

3. Depending on the nature of your interaction with us, some non-exhaustive examples of personal data which we may collect from you include name (principal and alias, if any), identification numbers such as national registration identity card number, foreign identification number, work permit and birth certificate, residential address, email address, telephone number, nationality, country of birth, gender, race, dialect, date of birth, marital status, employment information and financial information such as credit or debit card details.

4. We may request certain types of data from you in connection with your use of the Platform. Examples of the types of data which we may request and collect include, but are not limited to:

(a) information relating to your bank account, such as your bank account number and bank transactions conducted on the Platform;

(b) information about you from data source(s) approved by us;

(d) your contact information, including your telephone number, email and mailing addresses;

(e) information from your device including but not limited to your location information, internet protocol address, media access control address, network interfaces, device type and model, and other forms of data from your device in connection with the use of the Platform;

(f) information relating to the version of the Platform on your device or your use of the Platform, including but not limited to information relating to the usage of the various functionalities, features or clicks on the Platform as well as device permissions such as the permission to push notifications, use location services, use any connectivity services, and other similar information;

(g) fingerprint, face identification enrolled by, where applicable, the relevant fingerprint recognition feature or face recognition feature on your device;

(h) your captured face data;

(i) your login credentials for using the Platform;

(j) such other information as may be provided by, or collected from you in connection with your use of the Platform;

(k) analytics tags in respect of your use of the Platform;

(l) cookies (small data files which are sent to your browser or device to store and track information about you when you use the Platform); and

(m) server logs recording the activity created by the device on which you are using the Platform.

5. We generally do not collect your personal data unless:

(a) it is provided to us voluntarily by you directly or by a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative“) after:

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and

(ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or

(b) collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

6. We may collect and use your data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services offered by us such as account registration, facilitating logins, pre-filling electronic forms or populating your profile data;

(b) to process future payments and to read your bank transactions conducted on the Platform;

(d) contacting you from time to time to inform about charities, donations, appeals, the Platform, newsletters, and other services;

(e) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(f) managing your relationship with us;

(g) administering, operating, providing, maintaining and protecting our business and the Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised individuals do not access the information on the Platform);

(h) processing your requests, including payments or credit transactions;

(i) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(j) deriving and displaying your transaction and/or donation history including details of organisations to which the user has donated;

(k) any other purposes for which you have provided the information;

(l) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

(m) analysing the effectiveness of the functionalities and features of the Platform and user preferences relating to the Platform in order to improve general user experience. We may use information collected through such analytics tags in combination with your data (such as transaction history and demographic information) to understand more about the profile of our users;

(n) any other incidental business purposes related to or in connection with the above.

7. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any change in the purposes for which we collect your Personal Data, we will inform you of such change by way of electronic mail, phone or mobile messaging by utilising the details registered on the Platform. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer at the contact details provided in clause 26. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so.

8. We may disclose your personal data to unaffiliated third parties including our third-party service providers in limited circumstances as set out below:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.

9. We do not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not provide personal data of any kind whatsoever. If a child under the age of 13 provides us with personal data, a parent or guardian of that child may have this information deleted from our records by contacting our Data Protection Officer at the contact details provided in clause 26.

WITHDRAWING YOUR CONSENT

10. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided in clause 26.

11. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within twenty (20) business days of receiving it.

12. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 10.

13. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

14. If you wish to make:

(a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or

(b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided in clause 26.

15. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

16. We will respond to your request as soon as reasonably possible. In general, we will provide our response within twenty (20) business days. Should we not be able to respond to your request within thirty (30) business days after receiving your request, we will inform you in writing as soon as reasonably practicable. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so except where we are not required to do so under the PDPA.

PROTECTION OF PERSONAL DATA

17. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced commercially reasonable administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

18. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

19. You are responsible for keeping your login information and passwords confidential.

ACCURACY OF PERSONAL DATA

20. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided in clause 26.

RETENTION OF PERSONAL DATA

21. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

22. We will cease to retain your personal data or anonymise such data as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

23. We will not sell your personal data to third parties.

24. We may share, transfer or disclose data with charities (or other donees) or service providers such as Stripe Payments Singapore Pte Ltd, cloud computing and secure database providers and other relevant third-party service providers in connection with your use of the Platform, unless such sharing is prohibited by law.

25. We may transfer your personal data to countries outside of Singapore in the manner and for the purposes described in this Policy. When transferring your personal data outside of Singapore, we will protect your personal data to a standard comparable to the protection accorded under the PDPA by ensuring that the recipient is either in a jurisdiction that has comparable data protection laws, or is contractually bound to protect your personal data with standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

26. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Contact No. : +65 3138 3782

Email Address : dpo@givepls.com

27. If you wish to submit feedback or a complaint regarding our handling of your personal data, you may write to our Data Protection Officer at the contact details provided in clause 26. Kindly also include the following details when writing to our Data Protection Officer:

(a) name, contact number and address of the person submitting the feedback or complaint; and

(b) relevant details such as the time period of the incident, employees of GivePlease Pte. Ltd. who were involved in the incident (if relevant), and copies of documents where required.

EFFECT OF POLICY AND CHANGES TO POLICY

28. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

29. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

EXCLUSION OF LIABILITY AND INDEMNITY

30. In no event shall we and/or any of our member companies be liable to you for any loss, damage, costs, charges and/or expenses of whatsoever nature and howsoever arising including legal fees on a full indemnity basis, cost of funding and loss or cost incurred by you as a result of or in connection with:

(a) any access, use or the inability to access or use the Platform, use of or reliance on the contents of the Platform;

(b) any transaction performed on the Platform;

(d) any system, server or connection failure, error, omission, interruption, interception, delay in operation or transmission, or computer virus;

(e) any use of or access to any websites linked to the Platform;

(f) any service, product, information, data, software or other materials obtained from the Platform or from any other websites linked to the Platform;

(g) breach or violation of any third-party rights, including but not limited to the violation of any proprietary or intellectual property rights or the enforcement of any of these general terms of use.

GOVERNING LAW AND JURISDICTION

31. Nothing in this Policy shall limit the rights of the data subject under the PDPA. This Policy shall be governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts.

Effective date : 18^th August 2020

Last updated : 18^th August 2020