Privacy policy

QUINCUS

PRIVACY POLICY

Version 1.00 

Published on 6 October 2020

QUINCUS PRIVACY POLICY (SINGAPORE)

1. INTRODUCTION

This privacy policy (“Privacy Policy”) sets out basis which Quincus Pte. Ltd. (UEN: 201840956E), its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Quincus”, “we”, “us”, “our” or the “Group”) may collect, use, process, disclose and/or transfer personal data (defined below) in accordance with the Singapore Personal Data Protection Act (“PDPA”). 

This Privacy Policy applies to personal data of individuals (“you”, or “your”) in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, process, disclose and/or transfer personal data for our purposes. 

2. DEFINITIONS AND INTERPRETATION

The following definitions apply in this Privacy Policy unless inconsistent with the context or otherwise specified:

“personal data”	means any data, regardless of its format, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access.
“Services”	The use of Quincus’ mobile applications and websites as well as products, features and other services operated by Quincus from time to time.

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

3. COLLECTION OF PERSONAL DATA

Depending on the nature of your transaction with us, the personal data which we may collect from you includes (but is not limited to) your name and identification information such as your local identification number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, location and financial information such as credit card numbers, debit card numbers or bank account information. 

Such personal data may be collected from you or from persons authorised by you to disclose your personal data to us through the following means, which are not exhaustive: 

(a) when you access and/or use the Services; and

(b) when you complete a user profile or registration form for the purposes of setting up an account with us.

We may also receive personal data regarding you from the following third parties and other sources, which are not exhaustive: 

(c) our business partners, such as systems integrators, logistics service providers or partners, freight forwarders;  

(d) marketing service providers or partners; and 

(e) governmental sources of data.

4. PURPOSES

We may collect, use, process, disclose and/or transfer your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the Services requested by and/or accessed by you;

(b) managing your relationship with us;

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

(d) carrying out reasonable business activities such as audits, risk management, business reporting, service quality control, statistical and trend analysis and other related or similar activities; 

(e) complying with any internal policies, applicable laws, regulations, codes of practice, guidelines or rules (including those related to fraud, anti-money laundering and anti-terrorism), or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(f) sending you marketing communications including newsletters, notifications about new merchant additions, merchant engagements or merchant offers, conducting product surveys, advertising of similar products and services and event invitations, and you have the right to unsubscribe from such marketing communications;

(g) enforcing or defending our rights, contractual or otherwise, including investigations and participating in potential or actual litigation, arbitration or other legal process;

(h) any other purposes for which you have provided your personal data; and

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

These purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

The personal data that you provide us will not be sold, traded, licensed, offered or otherwise used for commercial marketing purposes that are not related to Quincus and/or the Services. 

5. DISCLOSURE AND TRANSFER OF PERSONAL DATA

We may disclose and/or transfer your personal data both within and outside of Singapore for the purposes specified above and as permitted or required by applicable laws and regulations to the following entities: 

(a) any entity within the Group;

(b) any persons and entities involved in the provision of the Services to you, including merchants, credit card companies and processors and third-party payment providers;

(c) any third-party service provider, agent, contractor or other organisation which we have engaged to carry out any of the purposes specified above; 

(d) any third party involved in or in connection with potential or actual litigation, arbitration or other legal process with us; 

(e) any person or entity to whom we are under any obligation or otherwise required to make disclosure pursuant to legal process or legal or regulatory obligation or request, including disclosure to any relevant governmental and/or regulatory authorities, whether in Singapore or abroad; and

(f) any person to whom disclosure is reasonable considered by us to be necessary.

We will reasonably endeavour to ensure that any third party who receives your personal data from us shall handle such personal data in accordance with the PDPA. 

Where we transfer your personal data to countries outside of Singapore, we will obtain your consent for such transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.  

6. COOKIES

Cookies are files with small amount of data and may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive.

As with most websites, our website also uses cookies to collect information. Such cookies include:

(a) strictly necessary cookies: such cookies are essential in order to enable you to navigate our website and use its features;

(b) performance cookies: such cookies collect information on how visitors use our website and are used to improve our website;

(c) functionality cookies: such cookies allow our website to remember choices that you make such as your account username and language and provide a personal experience; and 

(d) third party cookies: such cookies come with certain functions on our website for which we use third party suppliers such as Facebook Connect. in such case, we recommend that you consult the privacy policies of such third parties for information regarding their use of cookies. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website. By using our website without deleting or rejecting some or all cookies, you agree that we can place those cookies that you have not deleted or rejected on your device.

7. WITHDRAWING YOUR CONSENT

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 using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing to our data protection officer at the contact details provided below. 

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 ten (10) business days of receiving it. 

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 same manner. 

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.

8. PROTECTION OF YOUR PERSONAL DATA

We are committed to protecting your personal data and will use reasonable endeavours to safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. 

In this respect, we have introduced appropriate administrative, physical and technical measures such as storing personal data on secured servers maintained in controlled facilities, using up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and we limit access to your personal data to authorised persons on a confidential and need-to-know basis. 

In respect of your financial information, we use credit card processors that comply with strict industry standards and we implement techniques to allow payments to be processed in our systems without saving such financial information. 

9. ACCURACY OF PERSONAL DATA

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 at the contact details provided below.

10. ACCSES TO AND CORRECTION OF PERSONAL DATA

Subject to certain exceptions, you may request a copy of or correction to your Personal Data held by us by contacting our data protection officer at the contact details provided below. 

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

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. 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).

11. RETENTION OF PERSONAL DATA

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

12. CONTACT US

Should you have any questions regarding this Privacy Policy, or if you wish to make any request regarding your personal data, please contact our data protection officer by email at info@quincus.mycodelibraries.com. 

13. AMENDMENTS AND MODIFICATIONS

We may amend, vary or modify this Privacy Policy in its sole discretion from time to time without any prior notice. The latest version in force is available at www.quincus.com/privacypolicy.

Your continued use of our Services after we update the Privacy Policy on our website will constitute your acknowledgment of the revisions and your consent to abide and be bound by the latest version of the Privacy Policy.

14. GOVERNING LAW

This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore.