Collection of personal data
The Group only collects personal data which is knowingly and specifically supplied to it by the Client for the purpose as specified prior the supply by the Client, that is necessary to provide the Services or that is necessary for compliance with a legal obligation. Without limitation, this can occur during or before the Client:
Sets up an Account;
Uses our Services;
Provides any feedback or complaints with regard to the Services through the Website;
Uploads or submits any material through the Website; and/or participates in any marketing activity held by the Group.
Commonly collected personal data may include the following:
The Client’s name, email and postal addresses, telephone number, country of residence, nationality, age, gender, date of birth, copy of passport, business information, bank account information and other payment information;
Details of any transaction the Client makes using the Services; and/or details of any correspondence, queries, or any other forms communication (i.e. telephone, email etc.) the Client makes with the Group regarding the Services.
In addition to personal data provided to the Group, certain information related to the Client that is not considered personal data may also be collected. The Group collects this information to improve its Website and Services. Such non-personal data may include information such as details of the Client’s operating system, domain name, IP address, the internet browser used, details of the Client’s interaction with the Website and the details of any website the Client has linked from to the Website.
Use of personal data
Using your personal data
The Group collects personal data from existing and prospective clients and employees for various reasons. Any personal data will not be further processed in a manner that is incompatible with the purpose as stated before processing, for the performance of the Services, or to comply with a legal obligation. Without limitation, these purposes can include:
confirming the Client’s identity during creation of his/its Account and to ensure the Client’s eligibility to use the Services provided;
communicating with you and responding to your queries;
improving the Services and the Client’s experience on the Website;
providing you with information and updates on selected products and services that the Group thinks may be of interest to you;
administering and processing credit transactions in connection with the Client’s use of the Services;
analyzing the effectiveness of our advertisements and promotions;
customising the Client’s Website experience, as well as evaluating statistics on Website activity, such as what time you visited it, whether you have visited it before and what website referred you to it;
conducting required anti-money laundering checks;
notifying you of any changes to the Services that may be relevant to you;
conducting surveys, research and statistical analysis with the aim of helping the Group monitor and improve the Services;
supplying the Client with information that is relevant to the Client’s existing relationship with the Group; and/or any other purposes as permitted by applicable laws.
Where the Group collects personal data for a specific purpose, the Group 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.
Sharing your personal data
If agreed upon, or based on law, the Group may process, use and disclose your personal information with third parties. Such third parties may be based abroad and may include but are not limited to the following:
regulatory authorities and enforcement agencies;
any court of law or any relevant party in connection with any claim or legal proceeding;
contractors, service providers, consultants, auditors and advisors on a need to know basis;
advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions;
our subsidiaries, parent company or related companies;
professional service providers;
third parties required to process the Services for you or otherwise provide any Services to you;
web analytics tool providers, such as Google.
We may share your personal data for the following reasons:
reasons provided under ‘using your personal data’;
to enforce any provision of the Terms and/or Agreement;
to protect the rights or property of any member of the Group (including but not limited to any intellectual property rights);
to conduct investigations in respect of any possible breach of applicable laws (only if legally obliged); and/or
to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate (only if legally obliged).
In situations where a third party under contract with the Group collects and/or receives personal data about you, the Group will require the third party to act according to laws regarding personal data and to exercise reasonable care in protecting your information.
You are responsible for providing accurate and complete information about yourself and any other person whose personal information you provide us, and to notify us (either by the Website or by letter) if there are any changes to your personal information.
The Group endeavours 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, the Group strives 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 he Services, you accept the inherent security implications of engaging in transactions online over the internet and you agree that you will not hold the Group responsible for any breach of security unless we have been grossly negligent or in willful default.
Amendments to personal data / opt out
If you are a resident in Singapore
by e-mail to: [email protected]
or by postal mail to:
The Data Protection Officer in Singapore
Clarency Singapore Pte Ltd
1 Wallich Street, #14-01 Guoco Tower
If you are a resident in the EEA
by email to: [email protected]
or by postal mail to:
The Data Protection Officer in the EEA
Nederlandsche Betaal&Wissel Maatschappij N.V.
1012 JW Amsterdam
You may also decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive.
However, we encourage our Clients to lodge a complaint with the Group before lodging a complaint to the supervisory authority. We will always fully investigate your complaint.
Policy concerning Children
Individuals under the age of 18 are not eligible to use the Services offered by the Group without adult supervision. Please obtain your parents' or guardians' permission before you send any information about yourself (your name, address, e-mail address, etc.) to us or anyone else over the internet. We encourage parents to get involved with their children's use of the Internet and to be aware of the activities in which they are participating.
Governing law and Jurisdiction
the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the courts of the Republic of Singapore, if you are a resident in Singapore; or
the laws of the Netherlands and you agree to submit to the exclusive jurisdiction of the courts in the Netherlands, if you are a resident in the EEA.