Privacy Policy

Last Updated: 28 August 2019

  1. DATA PROTECTION NOTICE

    This Data Protection Notice ("Notice") sets out the basis which Transwap Private Limited ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA") and Payment Services ("PS") Act. This Notice 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.

    Please read this policy carefully as this Privacy Policy is legally binding when you use our Services. By using our website (our "Website"), you are accepting and consenting to the practices contained in this policy.

    By continuing your interactions with us, such as by submitting information to us, or using our Services, you confirm that you understand and consent to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) in the manner as set forth in this Privacy Policy.

    In the event of any inconsistency between different versions of this policy, the English version shall prevail.

    For the purpose of the relevant data protection regulations, the company in charge of your information is Transwap Private Limited (UEN 201427511E), a company incorporated under the laws of Singapore, with its address at 29 Media Circle, Alice@Mediapolis, South Tower, #02-06, Singapore 138565.

  2. PERSONAL DATA

    As used in this Notice:

    "customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

    "personal data" means data, whether true or not, about a customer 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.

    Depending on the nature of your interaction with us, some examples of personal data which we collect from you include full name, identification number, residential address, email address, telephone number, nationality, gender, date of birth, employment information, bank account information, payment reason, geographical location, specimen signature and photograph.

    We may also need additional commercial and/or identification information from you, e.g. if you send or receive certain high-value or high volume transactions, or as needed to comply with our obligations under applicable laws and regulations, including but not limited to our anti-money laundering obligations.

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

    We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them for example, banks and payment service providers you use to transfer money to us; banks and payment service providers of your recipient; business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers; search information providers; and regulators.

  3. PROTECTION OF PERSONAL DATA

    We generally do not collect your personal data unless it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative") after you (or your authorised representative) have been notified of the purposes for which the data is collected.

    We wish to emphasise that Transwap does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or any applicable law.

    To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. Please be assured that when we disclose your personal data to other parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.

    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.

  4. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

    For the purposes of complying with Notice to Payment Services Providers (Specified Payment Services on Prevention of Money Laundering and Countering the Financing of Terrorism ("PS Notice 01"), we are obliged to collect the following information from you for identification:

    Information that you give us:

    You may give us information about you by filling in our registration forms on our Website or by any other means of correspondence. This includes (but not limited to):

    1. full name, including any aliases;
    2. unique identification number (such as an identity card number, birth certificate number or passport number, or where the customer is not a natural person, the incorporation number or business registration number);
    3. the customer’s –
      1. residential address; or
      2. registered or business address, and if different, principal place of business, as may be appropriate;
    4. date of birth, establishment, incorporation or registration (as may be appropriate); and
    5. nationality, place of incorporation or place of registration (as may be appropriate).

    Subjected to PS Notice 01, we are obliged to verify the identity of each natural person by requesting from you or/and third party for reliable, independent source data, documents or information.

    Information we collect about you:

    We collect details of the transfers you carry out via our Website, including the geographic location from which the transaction originates.

    Our Website uses cookies. A cookie is a small text file placed on your computer or mobile device when you visit our website. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions, track use of our Website and to compile statistics about activities carried out on our Website.

    Information we receive from other sources:

    We are also working closely with third parties and may receive information about you from them for example, banks and payment service providers you use to transfer money to us; banks and payment service providers of your recipient; business partners; sub-contractors in technical, payment and delivery services; advertising networks; analytics providers and search information providers.

    We collect and use your personal data for any or all of the following purposes:

    1. verifying your identity;
    2. processing payment transactions;
    3. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
    4. 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;
    5. communicating with you, including providing you with updates on changes to products and services, including any additions, expansions, suspensions and replacements of or to such products and services and their terms and conditions;
    6. conducting screenings or due diligence checks as may be required under applicable law or regulations;
    7. monitoring products and services provided by or made available through us;
    8. financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes; or
    9. seeking professional advice, including legal advice.

    We may disclose your personal data:

    1. a. where such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you; or
    2. 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.

    The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws and including, where applicable, a period to enable us to enforce our rights under any contract with you and to comply with applicable laws.

  5. WITHDRAWING YOUR CONSENT

    1. 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 below.
    2. 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.
    3. 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 5a above.
    4. 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.
    5. Notwithstanding to clause 5a to 5b, we may collect, use and disclose your personal data without your consent for the purpose of complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
  6. ACCESS TO AND CORRECTION OF PERSONAL DATA

    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 below.

    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.

    Please note that we, as a payment service provider, is allowed by law to deny your request to access or, correct an error or omission in relation to the types of personal data set out in clause 4a to 4e unless we are satisfied that there are reasonable grounds for such request.

    We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. 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).

  7. 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 in writing or via email at the contact details provided below.

  8. RETENTION OF PERSONAL DATA

    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.

    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.

  9. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

    All information you provide to us is stored on Amazon Web Services ("AWS") cloud servers. AWS infrastructure puts strong safeguards in place to help protect your privacy. All data is stored in their highly secure data centres. AWS manages dozens of compliance programs in its infrastructure. This means that segments of your compliance have already been completed.

  10. DATA PROTECTION OFFICER

    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:

    Name of DPO : Ryan Yan

    Contact No. : +65 6100 9788

    Email Address : ryan.yan@transwap.com

  11. AMENDMENTS AND UPDATES OF OUR PRIVACY POLICY

    We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way Transwap uses your data or any changes to the laws and regulations applicable to Transwap. We will make available the updated policy on this page.

  12. EFFECT OF NOTICE AND CHANGES TO NOTICE

    This Notice 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. We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

    Effective date : 28/08/2019

    Last updated : 28/08/2019

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