PRIVACY POLICY

Version 1.0

1. INTRODUCTION

MWA Capital Pte. Ltd. (“We”, “Us” or “Our organisation”) is a company incorporated under the laws of the Republic of Singapore, licensed and registered with the Ministry of Law as licensed moneylender, having its registered address at 3 Philip Street, Royal Group Building, #13-01, Singapore 048692. We respect the privacy of our users, as well as members of the public. This policy (this “Privacy Policy”) is based on the Singapore Personal Data Protection Act 2012 as amended from time to time (“PDPA”) and all associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Singapore. It sets out the basis on which any personal data we collect from you, or that you provide to us, will be disclosed, used and/or processed.

By visiting or using the Website, the App or any of the Services (as defined below), or by giving or making available your Personal Data to us, you agree and consent to the collection, use , disclosure and processing of your Personal Data in accordance with the terms of this Privacy Policy. Please review this Privacy Policy carefully prior to visiting or using any such pages or otherwise providing any Personal Data.

In this Privacy Policy, the following terms shall have the meanings set out below:

“App” means the mobile application developed by MWA Capital.

“Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access. This refers to any such data which we may already have in our possession, or collected previously through other Services which may have been provided by us. Examples of such Personal Data include:

(a) your name, email and postal addresses, telephone number, country of residence, nationality, age, gender, date of birth, salary details, employer information, tax assessment details, NRIC and FIN number, occupation, business information, bank account information and other payment information;

(b) details of any transactions you make using the Services;

(c) information about your use of the Website, the App and the Services including your IP address which we may record through the use of internet cookies; and

(d) details of any correspondence, queries, or any other forms of communication (i.e. telephone, email etc.) you make with us regarding the Services

“Processing” means in relation to personal data, the carrying out of any operation or set of operations in relation to the personal data, and includes any of the following: recording, holding, organising, adapting, altering, retrieving, combining, transmitting, erasing or destroying personal data.

“Services” shall mean any service which is provided by us.

“Website” shall mean www.mwacapital.com.sg

2. COLLECTION OF PERSONAL DATA

This Privacy Policy supplements but does not supersede nor replace any other consent that you may have previously provided to us, nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/or retention of your Personal Data.

Generally, your Personal Data may be collected by our organisation either directly or by third parties who work with us in the following situations:

(a) when you submit forms to us to register to receive the Services;

(b) when you use the Services;

(c) when you access the Website and/or the App, submit information through the Website and/or the App and/or your browser loads our internet cookies;

(d) when you respond to surveys or questionnaires from us or third parties we engage;

(e) through Closed-Circuit Television System (CCTV) recordings when you visit our premises;

(f) when you communicate with us or any of our third party partners in relation to the Services;

(g) through photography, videography and/or sound recordings when you participate in any of our events and/or activities;

(h) when you provide any feedback or complaints with regard to the Services through the Website, the App or otherwise;

(i) when you upload or submit any material through the Website, the App or otherwise;

(j) when you submit Personal Data to us for any other reason; and/or

(k) when we collect Personal Data by other lawful means.

In addition to Personal Data provided to us, certain anonymous information related to you that is not considered Personal Data may also be collected. We collect this information to improve the Website, the App and the Services. Such data may include information such as details of your operating system, the internet browser you use, details of your interaction with the Website and/or the App and the details of any website/application from which you visited the Website and/or the App.

3. USE OF COOKIES

The Services, the Website and the App may use data collection devices such as “cookies” and other technologies such as pixel tags and web beacons to personalize your online experience, help analyze the flow of the Website and/or the App and measure promotional effectiveness. "Cookies" which are small files that reside on your computer's hard drive generally contain an anonymous unique identifier and are accessible only by the website that placed them there and not by any other website. We may offer features that are only available through the use of a “cookie”.

We also use cookies to recognize you when you login to the Website and/or the App and to store your preferences and customized settings. Cookies may also help us provide you with information based on your interests.

You may choose to enable or disable cookies in your web browser or mobile application. Most web browsers and mobile applications automatically accept cookies but you can modify your device to prevent that or to notify you each time a cookie is set (if your browser/ application permits you to do so), although in such a case you may not be able to access certain features on the Website and/or the App which may be restricted or rendered inoperable. In addition, you may delete cookies that have already been placed on your hard drive. For further details please refer to the help menu in your browser and/or mobile application.

4. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

Generally, our organisation may collect, use, disclose and/or process your Personal Data for the following purposes:

(a) confirming your identity during creation of your account and to ensure your eligibility to use the Services provided;

(b) communicating with you and responding to your queries;

(c) improving the Services and your experience on the Website and/or the App;

(d) administering and processing transactions in connection with your use of the Services;

(e) customising your Website and App experience, as well as evaluating statistics on Website and App activity, such as what time you visited it, whether you have visited it before and what website or mobile application referred you to it;

(f) conducting required anti-money laundering checks;

(g) notifying you of any changes to the Services that may be relevant to you;

(h) conducting surveys, research and statistical analysis with the aim of helping us monitor and improve the Services;

(i) supplying you with information that is relevant to your existing relationship with us; and/or

(j) any other purposes as permitted by applicable laws, legislation or regulations.

Where we collect personal data for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons.

5. DISCLOSURE OF YOUR PERSONAL DATA

We take securing your personal data and preserving your privacy very seriously. Unless we expressly state otherwise elsewhere in this Privacy Policy, we will not offer, publish or share your personal data with third parties, without seeking your explicit permission. We will never sell your data.

However, we may process, use and disclose your personal information with trusted third parties and strategic partners that work with us from time to time, in connection with any service (including the Services), transaction, promotion, questionnaire, or communication with us or otherwise. Such third parties may either be in Singapore or abroad and may include but are not limited to the following:

(a) cregulatory authorities and enforcement agencies;

(b) any court of law or any relevant party in connection with any claim or legal proceeding;

(c) our contractors, service providers, consultants, auditors and advisors on a need to know basis;

(d) our subsidiaries, parent company or related companies (collectively, the “Group”);

(e) professional service providers, including but not limited to registered trust companies, security agents and corporate secretarial service providers in connection with any matters relevant to the Services;

(f) third parties required to process the Services for you or otherwise provide any Services to you;

(g) financial institutions including credit card companies and their services providers;

(h) 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; and/or

(i) web analytics tool providers, such as Google.

Other than the purposes to which you have consented, we will keep confidential any Personal Data which you provide to us. However, subject to any applicable law, legislation or regulation, we may disclose your information in circumstances such as, but not limited to, the following:

(i) where disclosure is necessary for any purpose which is clearly in your interest, if consent cannot be contained in a timely way;

(ii) where disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;

(iii) where disclosure is necessary for any investigation or proceedings;

(iv) where disclosure is to a public agency and such disclosure is in the public interest;

(v) where such disclosure without your consent is permitted and/or required by the PDPA or any other applicable law;

(vi) where disclosure is necessary to enforce any provision of the terms of use of the Website and/or the App;

(vii) where disclosure is necessary to protect the rights or property of any member of the Group (including but not limited to any intellectual property rights);

(viii) where disclosure is necessary to conduct investigations in respect of any possible breach of applicable laws; and/or

(ix) where disclosure is necessary to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate; and

(x) where such disclosure without your consent is permitted and/or required by the PDPA or any other applicable law.

Our servers are hosted in Singapore. We will not transfer your Personal Data overseas without your express consent.

6. SECURITY

We endeavour to take all reasonable steps to protect your Personal Data and to store it securely. However, 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. In using the Services, you accept the inherent security implications of engaging in transactions online over the internet and you agree that you will not hold us responsible for any breach of security unless we have been grossly negligent or in wilful default.

7. ACCESS, CORRECTION AND WITHDRAWAL OF CONSENT

7.1 Access

You may request access to your Personal Data currently within our possession and/or control. This should be done by submitting a request to our Data Protection Officer. As our obligations under the PDPA require us to ensure that your Personal Data is protected, we will request information from you to verify your identity before disclosing any information to you. Following your request, our Data Protection Officer might also contact you in order to seek clarification on the specific information which you require.

We will respond to any request within a reasonable time of such a request being made, but in any case no later than 30 days from the date of the request. There may be circumstances where, by law, we will not be required or able to accede to your request. Where this is the case, we will notify you of this within a reasonable time.

Please note that we may charge a reasonable fee for the handling and processing of your request. You will be informed of the fee before your request is processed.

7.2 Correction

You will endeavour to ensure that your Personal Data in our possession is accurate and complete so as to facilitate us making any decision in relation to providing the Services to you.

You may request that corrections be made to your Personal Data in our possession. This should be done by submitting a request to our Data Protection Officer. Following your request, our Data Protection Officer might also contact you in order to seek clarification on the specific information which you would like us to correct. We will respond to any request within a reasonable time of such a request being made, but in any case no later than 30 days from the date of the request. There may be circumstances where, by law, we will not be required or able to accede to your request. Where this is the case, we will notify you of this within a reasonable time.

7.3 Withdrawal of Consent

Where you have provided consent or your consent has been deemed, you may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession and/or under our control by submitting a request via email to our Data Protection Officer.

We will process your request within 10 days of receiving your notification. Please note that where your Personal Data is required for us to provide you with any Services, we may cease the provision of such services without any liability.

8. RIGHT TO AMEND THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time to take into account any changes in law or for any other reason. If we update this Privacy Policy, we will post a new version on the Website. We will also post a notice of the changes on the Website or notify you by email (sent to the email address specified in your account). We encourage you to periodically review this page for the latest information on our privacy practices.

Your continued use of the Website, the App and the Services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided. If there is a conflict between two versions of the Privacy Policy to which you have agreed or been deemed to agree, the more recent version shall take precedence unless it is expressly stated otherwise.

9. LINKS TO OTHER SITES

The Website and the App may contain links to other sites. We are not responsible for the privacy practices or the content of such websites and/or applications.

10. MISCELLANEOUS

10.1 Policy concerning Children

Individuals under the age of 21 are not eligible to use the Services offered by us. If you are under the age of 21, please stop using the Services and leave the Website immediately. If you have downloaded the App, please delete it immediately.

10.2 Language

In the event of any conflict between the English language version of this Privacy Policy and any foreign language translation versions thereof, the English language version shall govern and prevail. All disputes, claims and causes of action (and related proceedings) will be communicated in English.

10.3 Governing law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore. You agree to submit to the exclusive jurisdiction of the courts of the Republic of Singapore.

11. CONTACT US

If you have any questions relating to your Personal Data in our possession, or would like to make any requests concerning such data, please contact our Data Protection Officer using the contact information provided below:

Email contactus@mwacapital.com.sg
Address MWA Capital Pte. Ltd. 3 Phillip Street #13-01 Royal Group Building Singapore 169205
Attention Data Protection Officer