You Technologies Group (Singapore) Pte. Ltd. (“YouTech”, “we”, “us” or “our”) values your privacy and is committed to managing any personal data (“Personal Data”) entrusted to us. We have implemented technical and organisation measures to ensure the appropriate security in Personal Data processing and to prevent breaches and leaks of Personal Data. We have also put in place this privacy policy (“Policy”) to set out how we may process your Personal Data in accordance with the Personal Data Protection Act 2012 (as amended from time to time) and any other applicable laws.

1. What is the purpose of this Policy?

This Policy is a document to help you understand how we manage your Personal Data, and the purpose for the collection, use and disclosure of such Personal Data.

2. What is Personal Data?

Personal Data is data that can directly or indirectly identify a natural person. This includes data (whether correct or incorrect) which you provide directly to us or which we receive from other third party sources. Some examples include:

• personal identification information (e.g. name, contact details, address, date of birth, identity card / passport details);

• images and biometric identifiers (e.g. facial recognition, fingerprint recognition, retina recognition, voice recognition);

• employment details (e.g. occupation, directorship, share ownership);

• information you share with us (e.g. content information stored on your mobile device, contact information from your address book);

• information on your activities, habits, preferences and interests relating to your use of our products and services (including but not limited to YouTrip and YouBiz); and / or

• other electronic data or information relating to you including your login information, device’s operating system and platform, browser type and version, plug-ins, device type, unique device identifier, GPS data, location data, web or mobile analytics such as clickstream and page interaction data.

3. Purpose for the collection, use and disclosure of your Personal Data

We collect, use, disclose and / or process your Personal Data for the following purposes (“Purposes”):

• processing your application, including but not limited to verifying your identity and evaluating your financial and legal track record, for our products and services;

• administering and / or managing your relationship or account with us;

• processing and / or dealing with any of your request and any necessary investigations relating to your request;

• carrying out due diligence or other screening activities in accordance with legal or regulatory obligations or risk management procedures that may be required by law or by us;

• carrying out your instructions or responding to any of your enquiries;

• requesting feedback or participation in surveys, as well as conducting market research and / or analysis for statistical, profiling or other purposes for us to improve and design our products, understand customer preferences and market trends, and to review, develop and improve the quality of our products and services;

• providing media announcements and responses;

• dealing with any matters relating to the services and / or products which you are applying for or have already applied for, including mailing to you correspondences, statements, invoices, reports or notices, processes which involve disclosing certain Personal Data about you in order to carry out the aforementioned delivery, as well as disclosing certain Personal Data on the cover of envelopes / mail packages);

• investigating fraud, misconduct, unlawful action or omission, and any suspicion of the aforementioned;

• complying with the applicable laws and our regulatory obligations in administering and managing your relationship with us; and / or

• any other purposes related to any of the above.

We may also use and process your Personal Data for other marketing and promotional related purposes such as (“Additional Purposes”) via post, email, telephone call, SMS, mobile app notification, website, and / or online messaging service:

• providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;

• sending you details of products, services, special offers and rewards, either to our users generally, or which we have identified may be of interest to you;

• notifying you on events or activities organised by us, our partners, sponsors or advertisers, and the processing the registration for such events or activities; and / or

• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or other third parties.

We wish to emphasise that we do not sell your Personal Data to any third parties.

4. Withdrawal of consent

You may communicate your objection to our use and / or disclosure of your Personal Data for any of the Purposes or Additional Purposes as stated in this Policy at any time by contacting our Data Protection Officer using the contact details stated below.

However, please take note that depending on the nature and specifics of your objection, we may not be able to accede to your request because of certain legal and regulatory requirements or be able to continue to provide our products or services to you.

5. Disclosure of Personal Data

We will take reasonable steps to protect your Personal Data against unauthorised disclosure. To the extent permitted by law, we may transfer or disclose your Personal Data for the Purposes and Additional Purposes stated in this Policy, to the following entities or parties, whether they are located overseas or in Singapore:

• our affiliates;

• counterparties and their respective financial institutions in relation to payments and other transactions;

• agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to us;

• vendors or other third party service providers, including but not limited to credit bureaus, advertisers and event management companies, in connection with promotions and services offered by us;

• professional advisors and external auditors, including legal advisors, financial advisors and consultants;

• co-branded and other business partners; and / or

• any other party to whom you authorise us to disclose your Personal Data to.

We may also disclose your Personal Data in the following circumstances:

• if we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about you will be one of the transferred assets;

• if we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request; and / or

• in order to: (i) enforce any terms and conditions and / or agreements between you and us or to investigate potential breaches; or (ii) protect our rights, property or safety, our customers or others. This includes but is not limited to exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. Storage and retention of Personal Data

When it is necessary, we may send or transfer your Personal Data to affiliated companies located in other countries or to other receivers in the ordinary course of our business (e.g. sending or transferring your Personal Data to be stored on server/cloud in other countries). If the recipient country does not have data protection standards commensurate to that required under the laws of Singapore, we will ensure that we continue to comply with the higher data protection standards of Singapore.

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. In particular, we are required, as an entity licensed by the Monetary Authority of Singapore, to retain data, documents and information we collect (which may include your Personal Data, documents and information) as part of complying with our anti-money laundering and countering the financing of terrorism obligations for at least 5 years after the termination of our business relationship with you or the completion of transactions you have undertaken with or through us. Please note that these retention requirements prevail over any right to erasure requests under the applicable data protection laws.

We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, 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. We may erase, destroy, or anonymise the Personal Data when it is no longer necessary or when the period lapses.

7. Accessing your Personal Data and correction requests

Should you wish to access a copy of or request for correction of your Personal Data held by us, you can submit your request to our Data Protection Officer by contacting us via:

Email:

dpo@you.co

Mail:

Data Protection Officer
You Technologies Group (Singapore) Pte. Ltd.
9 Raffles Place, #26-01 Republic Plaza,
Singapore 048619

Please note that we may need to ask for your identification number and other necessary details during the process to verify your identity. We reserve the right to refuse your requests to access and / or correct your Personal Data for reasons permitted by law.

We reserve the right to charge a reasonable fee for processing your request to access or retrieve your Personal Data.

8. Acknowledgement and consent

By providing your personal information to us, or using our website, or signing up for or accessing products or services we offer during any of our interactions, either directly with us or through our agents and / or partners, you are consenting to the following:

• we may collect, use, disclose and / or process your Personal Data for the Purposes and Additional Purposes as described above;

• we may collect Personal Data about you from sources other than yourself and use, disclose and / or process the same for one or more of the Purposes and Additional Purposes as described above; and

• we may disclose your Personal Data to our third party service providers or agents (including but not limited to legal advisors) for the Purposes and Additional Purposes as described above.

9. Telephone calls, emails and text-based enquiries

To provide service and continuously improve our service, all communications between you and us, whether made via telephone calls, emails and / or text-based modality may be recorded and monitored.

10. Research

For research or statistical purposes, we may use or disclose to others anonymised or aggregated data.

11. Use of cookies

We and third parties with whom we partner, may use cookies, tags, scripts, web objects, advertising identifiers (such as mobile device identifiers including but not limited to Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) during your use of our website, mobile application, social media channels, and customer contact channels. Cookies may contain unique identifiers and are stored or used in, including but not limited to, your computer or mobile device, emails we send to you, and our web pages. By using our website and / or mobile application, you consent to us on the usage of Cookies.

Cookies may transmit information about you and your use of our service, including but not limited to:

• IP address;

• browser / device type;

• website or mobile application visited before you came to our website or mobile application;

• which pages you viewed on our website or mobile application; and

• time spent on our website or mobile application.

Cookies may be stored persistently or stored only during an individual user session.

Cookies enable us to provide and develop a more personalised browsing and usage experience on our website and mobile application, and improve the experience of displaying targeted advertising to you.

We may allow third parties to use Cookies on our website and mobile application to collect the same type of information. Third parties may be able to associate the information they collect with other additional information they collected about you from other sources. We do not necessarily have access to or control over the Cookies they use.

We may share non-personally identifiable information about you with third parties, such as advertising identifies, location data, or encrypted account identifier to improve the experience of displaying targeted advertising on platforms including but not limited to search engines and social media channels.

You may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser, if you do not wish your Cookies to be collected. You may also be able to limit our sharing of some of this information through your mobile device settings.