1.Introduction
1.1 PIVOT Fintech Pte. Ltd. ("PIVOT") is a Singapore incorporated company (Registration number 201716150D) that offers digital investment management services using the name “SquirrelSave” and digital financial literacy platform using the name “Squirrel Treehouse”. In this Privacy Policy, “PIVOT”, “SquirrelSave”, and “Squirrel Treehouse” will be used interchangeably.
1.2 Personal information provided by you and all information generated and compiled by Squirrel Treehouse about you from time to time that fall within the definition under Section 2.1 below is collectively referred to as your "Personal Data".
1.3 Squirrel Treehouse respects the privacy of individuals and endeavours to comply fully with the Personal Data Protection Act 2012 of Singapore (“PDPA”). The PDPA is designed to protect the confidentiality of data and the privacy of individuals by regulating the ways in which Personal Data is managed.
1.4 This Privacy Policy explains how Squirrel Treehouse collects and manages your Personal Data in our possession or under our control as defined under the PDPA. Please read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data. By accessing and/or using the online website operated by us at www.squirreltreehouse.com.sg (“Site”) or through mobile applications, using our services available on our online website or through mobile applications (“Services”) or otherwise providing information to or communicating with us, you are deemed to have read, and understood this Privacy Policy, and you also consent to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.
1.5 This Privacy Policy does not supersede or replace any other consent you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have at law to collect, use, process or disclose your Personal Data.
1.6 This Privacy Policy shall be governed by, and construed in accordance with, the laws of Singapore. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore, and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Singapore.
2.Definitions
2.1 "Personal Data" is defined in the Personal Data Protection Act (No. 26 of 2012) of Singapore (“PDPA”). It refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.
2.2 The words "we", "us", "our" or any of their derivatives refer to PIVOT, SquirrelSave, and/or Squirrel Treehouse and its successors and any novatee, assignee, transferee or purchaser of Squirrel Treehouse's rights and/or obligations hereunder and any reference to Squirrel Treehouse includes a reference to such successor, novatee, assignee, transferee or purchaser.
2.3 The words "you", "your", "yours" or any of their derivatives refer to the person(s) using Squirrel Treehouse products and services which include operating any account maintained with us, accessing our online website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
3.Personal Data We Collect
3.1 Generally, we may collect your Personal Data through the following ways:
(a) when you submit an application to open an account with us;
(b) when you register for an account with us;
(c) when you complete the application form through our website or via other methods;
(d) when you use the Services that are made available on our online website;
(e) when you respond to our request for additional Personal Data;
(f) when you ask to be included in an email or other mailing list;
(g) when you communicate with us directly in relation to our products and services (by email, telephone or any other means);
(h) when you request that we contact you; and
(i) when you submit your Personal Data to us for any other reason.
3.2 When you provide Personal Data to us while using our Services, accessing our online applications or communicating with us, you are deemed to have agreed and consent to us and our authorised service providers and third parties as set out in Section 5 of this Privacy Policy to collect, use, process and disclose your Personal Data in accordance with this Privacy Policy.
3.3 We may collect, use, disclose, transfer and otherwise process Personal Data about you or individuals who are connected or associated with you including but not limited to your legal representatives (“Associated Persons”) in accordance with this Privacy Policy.
3.4 We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
3.5 The Personal Data that we collect or may collect include:
(a) personal contact data including name, telephone number, email address, residential address and correspondence address;
(b) identification or passport number, birth date, place of birth and other information that is necessary to verify your identity;
(c) next of kin contact data;
(d) occupation, education and income levels;
(e) specimen signature(s);
(f) financial and banking information;
(g) images and records of our communications with you;
(h) tax and insurance information;
(i) information related to your risk profile, investments, financial goals, knowledge, experience and/or business interests and assets;
(j) personal opinions made known to us;
(k) browsing history, patterns or other unique information such as traffic data, location data and the resources that you access on any of our online websites;
(l) internet protocol address and information associated with such address;
(m) any other Personal Data reasonably required for the purposes under Section 4 below or for us to provide the services requested by you; and
(n) any other Personal Data permitted by or required to comply with any applicable local or foreign laws, applicable statutes, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, by-laws, policies, orders, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time ("Applicable Laws") and our internal control and compliance policies.
3.6 If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children, parents and/or beneficiaries) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out in Section 4 of this Privacy Policy.
3.7 If you wish to withdraw your consent to any collection, use or disclosure of your Personal Data as set out in this Privacy Policy, you may write in to our Personal Data Protection Officer at the email address provided in Section 12 below. Upon receipt of your request to withdraw your consent, we may require reasonable time to process your request and to notify you of any likely consequences of a withdrawal of consent.
3.8 If you withdraw your consent to any or all collection, use or disclosure of your Personal Data, depending on the nature of any such request, we may no longer be in a position to continue to provide our Services to you.
3.9 Please note that withdrawing consent does not affect our rights to continue to collect, use or disclose your Personal Data where such collection, use or disclosure without consent is permitted or required under the PDPA or other applicable laws
4. Purposes of Collecting, Using and Disclosing Your Personal Data
4.1 The purposes for which your Personal Data may be collected, used or disclosed include:
(a) introducing and marketing products and services to you;
(b) offering and providing products and products to you, which may include, financial products and services;
(c) processing and assessing applications or requests made by you in connection with products and services, issuing or arranging financial reports and maintaining your account with us;
(d) designing products and services for you;
(e) processing payment instructions;
(f) operating, maintaining and providing subsequent services in relation to the applications for products and services;
(g) creating and maintaining the data requirements of products and services;
(h) verifying and conducting any eligibility, credit, physical, security, and/or identity checks in connection with provision of products and services;
(i) complying with applicable foreign and domestic laws, regulations, codes of practice or guidelines;
(j) exercising any rights under any applicable laws, legislation or regulations that we may have in connection with the products and services provided to you;
(k) meeting commitments or requirements with any legal, regulatory, governmental, tax, law enforcement or other authorities, industry bodies in any jurisdiction where we have a presence or business;
(l) complying policies and procedures applicable to our business;
(m) internal administrative purposes; and
(n) any other purposes directly related or incidental to the above-mentioned.
4.2 The purposes mentioned in Sections 4.1 above 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).
5. Disclosure of Your Personal Data to Third Parties
5.1 We may disclose your Personal Data with third parties, whether within or outside Singapore for the purposes described in Section 4 above. Examples of third parties that we may disclose your Personal Data to include:
(a) our related corporations or affiliates;
(b) persons or legal entities acting for or on our behalf;
(c) persons or legal entities engaged by us including our professional advisers;
(d) agents, contractors and/or service providers serving us; and/or
(e) persons or legal entities to whom we must make disclosures under any law, rules, regulations, codes of practice or guidelines whether in or outside Singapore.
6. Transfer of Your Personal Data Outside Singapore
6.1 We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws. In particular, we 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.
7. Collection, Use or Disclosure of Your Personal Data for Marketing
7.1 We are allowed to (i) collect and use your Personal Data in direct marketing only if you consent or do not object, or (ii) provide your Personal Data to another person or legal entity for its use in direct marketing only if you consent or do not object.
7.2 In connection with direct marketing, we may:
(a) use your name, contact details, services and products information, financial background and demographic data held by us, from time to time, in direct marketing;
(b) market the following classes of services and products offered by us and/or third-parties from time to time:
· wealth management services and products;
· financial services and products;
· insurance services and products;
· reward, loyalty or privileges programmes and related products and services; and
· donations and contributions for charitable and/or non-profit making purposes.
(c) provide your Personal Data described in this Privacy Policy to any members of our group and/or third-parties for their use in direct marketing the classes of services and products described in this Privacy Policy.
7.3 We may collect, use or disclose your Personal Data for the following purposes:
(a) improving and developing our products and services;
(b) researching, designing and launching new features / products and services;
(c) personalizing content for you and for the device you use;
(d) providing alerts, updates or information about our products and services;
(e) legal proceedings, including professional advice;
(f) communicating with you and responding to your questions or requests; and
(g) purposes directly related or incidental to the above.
7.4 If you do NOT wish for us to collect or use your Personal Data in direct marketing or provide your Personal Data to other persons or legal entities for their use in direct marketing, you may indicate your wish to opt out from marketing when you provide your Personal Data. You may also write in to our Personal Data Protection Officer at the email address provided in Section 12 below to opt out from direct marketing at any time if you wish to withdraw your consent for marketing.
8.Maintaining Accuracy of Personal Data
8.1 We will make reasonable efforts to ensure the accuracy of all Personal Data collected and processed. Appropriate procedures are implemented so that all Personal Data is regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. To ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by contacting our Personal Data Protection Officer at the contact details provided in Section 12 below.
8.2 We will endeavour to make reasonable efforts to ensure the accuracy of Personal Data held by us, and if such Personal Data is transferred to third parties, we will notify that third party of any correction to be made.
8.3 Access and/or Correction to your Personal Data:
(a) you have the right to request access to your Personal Data held by us and request correction of any of your Personal Data which is incorrect;
(b) we shall as soon as reasonably practicable respond to your request to access your Personal Data and if we are unable to respond within thirty (30) days of your request for access, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request for access;
(c) we may charge you a reasonable fee for the costs of processing and complying with your data access request. If we charge a reasonable fee, we will inform you of the fee before processing your request;
(d) if we are unable to accede to a request from you for access or correction of Personal Data, we will inform you of the reasons unless we are not required to do so under the PDPA.
9. Storing & Retention of Personal Data
9.1 We hold Personal Data in secure digital data storage, paper-based files and other storage media. We will endeavour to safeguard and protect the Personal Data we hold from misuse, loss, unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks on a reasonable and expected risk basis. We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. If we no longer require any Personal Data that we hold, that Personal Data will be destroyed or information that may identify individuals will be removed, unless retention is required to comply with legal, statutory and regulatory requirements.
10. Use of Cookies and Third-Party Links
10.1 Where our website includes hyperlinks to third party websites or other media, we have no control over the content, accuracy, opinion expressed, and other links provided at or by these third-parties or how these third-parties deal with your Personal Data. You should refer to and understand the privacy policies of such third-parties for details of how they handle your Personal Data. We shall not be responsible for the handling, implications and outcomes of your Personal Data being used by such third parties.
10.2 We may use "cookies" to distinguish you from other users and improve our internet service to you. A cookie is a small text file that’s placed on your computer or mobile device when you visit our website or mobile app. Cookies are used for various reasons, such as tracking the performance of our website, remembering your username and preferences, and collecting general information such as how users arrive at and use our website.
10.3 The cookies and tracking technologies we use help us operate our website, mobile app and services, enhance and customise your experience across our website and services, perform analytics and deliver advertising and marketing that’s relevant to you. The information collected contains no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. No customer Personal Data is stored in cookies. You can disable cookies by changing the settings of your web browser.
10.4 The cookies we use may be persistent cookies (cookies that remain on your storage media and your browser for an extended period) or session ID cookies (cookies that expire when you close your browser). We may also use other tracking technologies that enable us to recognise when someone has visited our website or opened an email that we have sent them. We may use the following cookies:
(a) Strictly necessary cookies – required for the operation of our website(s). They include, for example, cookies that enable you to log into secure areas of our website, transactional or other services.
(b) Analytical/performance cookies – to recognise and count the number of visitors, and their browsing habits. This helps us to improve the way our website works.
(c) Functionality cookies –to recognise you when you return to our website. This enables content personalisation.
(d) Targeting cookies – record your visit to our website, pages you visited and links you followed. We use this information to make our website and content more relevant to you.
10.5 There may be cookies set by third parties across our websites and services. Third party cookies enable third party features or functionality to be provided on or through our website, mobile app and services, such as advertising, interactive content and analytics. They also enable us to manage our advertising on other websites. Our affiliates and third-party service providers may use different types of persistent and session cookies as described above.
10.6 You can accept or reject cookies by amending your web browser controls. Because some are essential our website, mobile app and services might not work as intended, and may not work at all if you reject all cookies
11. General Data Protection Regulations (“GDPR”)
11.1 The General Data Protection Regulation 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union and the European Economic Area. If you are a resident of the European Economic Area (EEA), you have certain data protection rights such as:
(a) Access, update or to delete the information we have on you
(b) Rectification
(c) Objection
(d) Restriction
(e) Data portability
(f) Withdrawal of consent
(g) Log Files
11.2 Under the GDPR, a Data Controller is the entity that determines the purposes, conditions and means of the processing of personal data. The Data Processor is the entity that processes data on behalf of the Data Controller.
11.3 We are the Data Controller of your personal information and we may use and/or associate with third parties to improve our product and services. Your Personal Data is shared where appropriate with third parties that are Data Processors or Data Controllers in their own right, and you are solely responsible to check that such third parties have appropriate legal measures in place to safeguard your Personal Data.
12. Privacy Policy Changes
12.1 We may revise our Privacy Policy from time to time without any prior notice to ensure that our Privacy Policy is consistent with developments and/or any regulatory changes. We will post any privacy policy changes on this page. If you continue to use our services, operate any account maintained with us, access our online websites or mobile applications, and/or otherwise provide information to or communicate with us, you are deemed to have acknowledged, accepted and agreed to such changes without reservation.
12.2 For further enquiries regarding our Privacy Policy, please contact our Personal Data Protection Officer at dpo@squirrelsave.com.sg or +65-6631-8933.
12.3 This Privacy Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with our Terms and Conditions, and Account Opening Agreement.
