Last Updated: 16 Apr 2024
Seedly Pte. Ltd. (“Seedly”, "we", “us” or “our”), is part of MoneyHero Group, a group of companies that provide price comparison services as well as financial services, insurance products, communications and other products and services across Asia.
The www.seedly.sg (“Website”), including the Seedly Community forum, content, features, tools, data, software and functions made available by us through the Website, our mobile applications including the ShopHero App (the “Mobile App”) and any other websites or applications we operate including http://ownthefuture.sg/ (unless those websites or applications have posted separate or additional terms of service) are owned by Seedly and have been created to provide information to our visitors (“you” and “your”) about our products and services (together, the “Services”).
The Services are owned by Seedly and its licensors and have been created to provide information to our visitors (“you” and “your”) about our products and services and those of third-party providers. Security and safety of your data and information is a top priority. We explain here what information and what Personal Data we collect, why we collect it, how we use and disclose it and how we protect Personal Data in compliance with the Personal Data Protection Act 2012. Please be sure to read this entire Privacy Statement before using our Services. When you use, access or interact with our Services, you are agreeing to our Terms of Use and consenting to the practices described in this Privacy Statement with respect to the collection, use and disclosure of your information. Further, when you use and/or access the Seedly Community forum, you consent to the Seedly Community Guidelines.
In this Privacy Statement, the terms "Personal Data" and/or “Personally Identifiable Information” means any data relating directly or indirectly to a living individual which is capable of being used to identify that individual.
We collect information about you in three main ways: when you provide it to us, with automatic technologies and when third party sources provide it to us.
While registering for an account and/or using our Services, your Personal Data may be collected or or provided by you to us in various ways.
The following are examples (without limitation) of the circumstances in which we collect Personal Data:
● When you subscribe to receive updates from us, we may ask for your email address and telephone number;
● When you register an account on our Services, we may ask for your name, email address, telephone number and/or mobile number;
● When you register an account on our Services and/or log in through third-party social logins (e.g. Google Sign-in, or Apple or Facebook Login Feature), we may collect your email address and/or basic profile info (profile picture and full name) and any other data that you would have explicitly consented to our collection;
● When you contact us by telephone, we may ask for your name, email address and/or phone number, so that we can contact you regarding your enquiry;
● When you reach out to us for support, give us feedback, participate in optional surveys, subscribe to marketing, attend our events, participate in product research or training or otherwise interact or communicate with us, we may ask for your name, email address and/or phone number and any other personal information you choose to share;
● when you use any of the features or play any of the games made available to you on any of our mobile applications;
● When you use our Mobile App, we may collect data or information such as your device's internet protocol address (e.g. IP address), browser type, browser version, the pages of our Mobile App that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data ; and
● When you access the Mobile App by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
The Personal Data we may ask you to provide includes (without limitation):
● name
● address
● email address
● telephone number
● date of birth
● age
● gender
● nationality
● any messages if you write to us using the "contact us" form
● your saving goals
● your residency status
● your income
● details of the products you are looking for (for example, the size of loan)
● passport number, NRIC or other identity copies and details (where required for purchasing a product)
● education history
● assets
● employment status
● employer or company details
● details of beneficiaries, such as joint policy holders and minor beneficiaries (where required for purchasing a product)
● details of your travel or other personal information relevant to the purchase of certain insurance products
● financial details about you, including details related to the payment method(s) such as credit card, debit card and/or bank account information (when purchasing a product);
● lifestyle information;
● preferences such as details that you have shared with us as to how you would like to be contacted, and your preferred products and brands. and
● information related to any of the above.
In addition to the above, in order to provide features of our Mobile App such as promotions, offers, plans and interesting things near you, we may (with your prior permission) collect information regarding your location. You can enable or disable access to your location information at any time, through your device settings.
Most often, the provision of the above data is on a voluntary basis. However, if you do not provide sufficient information to us, third party products and service providers may not be able to provide the requested information, products or services to you.
In addition, when you use the Services, we may automatically collect certain data about how you access and interact with our Services which may, when combined with other information about you, constitute Personal Data. Automated technologies, such as our use of ‘cookies’, web beacons and similar technologies help us achieve our goal of providing you with the best possible service. When you access our Services, our servers will record, or track information sent from the browsers. This can include the following information (without limitation):
● attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software and device identifiers;
● device locations, including specific geographic locations identified through GPS signals or other means;
● connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
● the website from which you have reached the Services;
● the Website pages viewed;
● details of the products and services on the Services that you look at, information, tools and content available on our Services that you use;
● time spent on the Services;
● links from our Services that you click on;
● quotes you request from our Services
● your transactions on our Services and details of any payments made by you (including bank account and credit card details and any other account identification information); and
● information related to any of the above.
Our use of cookies enables us to:
● provide you with a more personalized experience on our Services if you have logged in to your account on our Services. It allows us to remember you when you revisit our Services;
● study browsing habits on the Services if you have logged in to your account on our Services. The more we understand what products you are interested in, the greater our ability to offer you customized solutions and targeted advertisements and other marketing materials; and
● obtain information regarding the number of visitors to the Services and the pages viewed.
In most cases, cookies are deleted when you close your browser; these are referred to as session cookies. However, persistent cookies stay on your browsing device either until such time as you delete them, or they expire. By using the Services, you consent to us using cookies. Such use of data does not disclose any of your Personal Data, and we will not collect, process or use any of your Personal Data in this regard.
You can alter your computer browser settings to block or delete cookies. If you opt to block or delete cookies of the Services, you may not be able to access certain products or services and this could have an effect on the performance of the Services on your system (for example, banner ads may not display properly). If you have registered an account with us, you may be required to re-enter your password more frequently during your use of our Services if you choose to disable cookies.
In some cases, we also use cookies or similar technologies provided by trusted third parties. The Services use Mixpanel and a feature of Google Analytics, both of which are widely consumed analytics solutions, to record similar non-personal information regarding you and your activity on the Services. This setup allows for a more accurate tracking of our users by associating that user with the same ID over various sessions and devices. This approach may combine analytics data with other Personal Data about you that we have collected by our Services. Any such combined data will be treated as Personal Data by us and used in accordance with this Privacy Statement. By registering an account with us and using the Services, you consent to us using session unification in this way.
We may use features in Google Analytics and Google Display Network, including advertising and remarketing, that allow us to target ads to you and report on demographics and interests (for example, via our Mobile App). These tools use cookies and other information to show ads based on your past actions on our Services. If you would like to opt out of these features please visit https://www.google.com/settings/ads/.
Finally, when you use the Services, we may also receive information about you from other third parties we have engaged such as business associates, subcontractors, analytics providers, platform providers and search information providers, aggregation service providers such as Salt Edge Inc. (as further detailed below) or, pursuant to your request, from credit reference agencies and/or third party providers of our Partners (defined below).
If you decide to register an account with us or log in through or otherwise grant access to a third-party service such as Apple, Google and/or social networking site such as Facebook (“Integrated Services”), we may also collect Personal Data that is already associated with your Integrated Services account. These Integrated Services will authenticate your identity and provide you the option of sharing additional information with us. Should you choose to register or log in to our Services with your Integrated Services account, you are explicitly giving us permission to use, share and store the credentials you provide, your name, email address(es), date of birth, gender, current city, profile picture URL and other information that the Integrated Services makes available to us, in a manner consistent with this Privacy Statement. You should check your Facebook or other Integrated Services privacy settings to understand and change the information sent to us through Facebook Connect or other Integrated Services. Please review each Integrated Service's terms of use and privacy policies carefully before using their services and connecting to our Services in this way.
By providing us with your Personal Data or that of a family member, you warrant that such data is true and accurate, and undertake to notify us as soon as practicable of any change or alteration to the same. Any loss or damage caused to the Services or to the person responsible for the Services or to any third person through the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility. When you give us Personal Data about another person (or persons) such as a family member, you should have the authority to act on such person’s behalf (whether by appointment or by law in your capacity as legal guardian). This includes providing consent to our processing of their Personal Data. If for any reason you are concerned as to whether you are permitted to provide us with another person’s information, please contact us at the email address listed below before sending us anything.
We may retain customer and/or user Personal Data for as long as your account with us is active and not deleted; as reasonably necessary for us to provide or offer our services to you and/or your organization; as long as we consider necessary for to fulfill the purposes we collected it for (further detailed in the "What do we use your Information for?" section below), including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When we have no ongoing legitimate business need to process your Personal Data, we may either delete or anonymize it.
You have the right to request access to and correction of your Personal Data as held by us. Please contact us at [email protected] at any time if you wish to correct, amend or update your Personal Data. We aim to acknowledge and act upon your request promptly. To help us respond in the most timely and appropriate way, please be as specific as possible in your request or inquiry.
What do we use your Information for?
We use the information we collect about you for our legitimate business interests to operate and the Services, to enhance and customize users’ experiences with the Services and to improve and grow our business. Depending on the nature of your relationship with us, we may use your Personal Data for some or all of the following purposes:
● to set up and administer your account with seedly.sg and/or the Mobile App;
● to answer your queries and to communicate with you, for example, providing you with alerts, notifications and recommendations, or to provide customer support;
● to verify and authenticate your account for the Services;
● to allow you to access and use our Seedly Community service;
● to enable you to access online application forms on third party external sites;
● to analyze customer behavior, market trends and client demographics so that we can improve our services and to enable us to provide a more personalized service and more relevant communications to you;
● to combine Personal Data with information obtained through the use of cookies, web beacons or similar technologies to improve the Services and user experience;
● where you have registered an account with us, to enable us to save your Personal Data so that you do not have to re-enter it each time you request a quote or apply for a product;
● to store the data in order to be able to provide the Services on our servers or servers provided by third parties and to manage our business operations efficiently;
● where you have signed up to receive electronic communications from us, to send you marketing and/or promotional materials on our latest products and services or those of carefully selected third parties;
● with your consent, for remarketing and personalization purposes (as further described below)
● where you have registered an account with us, to send you service-related messages including, without limitation, a welcome/confirmation email when you register your account and to enforce our Terms and Conditions and other policies. You may not opt-out of receiving service-related messages from us, unless you deactivate your account
● where you have registered an account with us, to send you personalized special reports, exclusive member offers and latest feature announcements in relation to your account. You may not opt-out of receiving membership-related messages from us, unless you deactivate your account
● to diagnose and prevent service, security or technical issues affecting the Services;
● to monitor, detect, investigate and prevent fraud, illegal activity or abuse of the Services;
● to protect the safety, integrity and/or rights of our users, us and/or any third party;
● to personalise your experience and tailor recommendations, advertising and offers presented to you, including through the development of insights about you and your needs based on profile matching and your interactions with the products, services and offerings of our Services;
● to comply with our legal and regulatory obligations; and
● to enable us to provide services and products related to the above and/or otherwise related to your use of the Services.
We may for these purposes and for such other purposes set out in this Privacy Policy contact or communicate with you via mail (including email), voice call, SMS or other communication (including by text or image) applications (such as ‘Whatsapp’, ‘iMessage’ or ‘Telegram’). Please note that when communicating with you via communication applications including Whatsapp, iMessage or Telegram, we do not intend to collect any Personal Data from you and any provision of your Personal Data is on a voluntary basis and at your own risk.
To provide you with valuable personalised suggestions and experiences, we may process your personal information using automated and/or manual (human) methods. Our automated methods may include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience when using the Services.
We may participate with our marketing partners for the purposes of delivering personalized advertisements to you based on the usage data and/or Personal Data that we have collected from you, including your email address.
From time to time, we may participate in retargeting and behavioral advertising services. Users of the Services are, by submitting their information to us, consenting to our use of these remarketing services and the related processing of their Personal Data. To opt-out of participation, you may send an email, from the email address you are opting out of, to the email address provided in our contact information below. In addition, depending on how you access the Services (by computer or mobile device), you can control the placement of cookies and other data collection methodologies for purposes of opting out; however, as mentioned above opting out may have an impact on your ability to avail of our services.
Anonymised Data
For the purpose of producing and sharing statistical collective data amongst our users, we may generate anonymous data from or based on Personal Data collected from our users, so that the results are no longer personally identifiable with respect to that user ("Anonymised Data") and/or aggregate or incorporate such Anonymised Data with or into other similar data or information collected from other users or derived from other users' use of the Services ("Anonymised Aggregate Data"). Any such meta data is produced in such a manner that the underlying data will be no longer identifiable or attributable to any specific user. We may use such Anonymised Data and/or Anonymised Aggregate Data for various business purposes, including but not limited to:
● providing, maintaining, supporting and improving the Services;
● conducting marketing or analytical research, compiling statistical reports and performance tracking;
● developing and/or improving our other services and products or those provided by MoneyHero Group; and
● sharing such Anonymised Data and Anonymised Aggregate Data with our affiliates, agents or other third parties with whom we have a business relationship.
In the event we anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, we may use this information indefinitely without further notice to you.
How do we Disclose your Information?
We are committed to keeping your Personal Data and other information shared with us confidential. There are, however, certain circumstances in which we may disclose or transfer your Personal Data to certain third parties without further notice to you, as set forth below:
● Related Companies: We may share your Personal Data with our affiliates in MoneyHero Group (subsidiaries/affiliated companies of CompareAsia Group Limited) that provide services to or share services with us, some of which are located outside of Singapore.
● Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of, or in preparation for, a change of control, merger, acquisition, restructuring, dissolution or similar event, we may disclose or transfer Personal Data to a third party.
● Partners: We may be required to share your information with our partners who are financial institutions, banks, brokers, credit institutions, lenders, insurance companies, securities and investment services providers, and other money and financial service providers whose products may be displayed on our Services from time to time (“Partners”) or when you have requested the products and/or services our Partners, which requires us to provide your Personal Data to them in a pre-populated form or by API. In order for you to redeem a reward on our Services, we may also need to share those details with the relevant Partner in order to authenticate your reward redemption.
● Public Forums: We may provide opportunities for you to publicly post reviews, questions, comments, suggestions or other content, which may include personal information, such as your name or user name. Anything you share in a public forum is public, and you should think carefully before you decide to share.
● Agents, Consultants and Other Service Providers: We rely on service providers to help support our business and the Services, for example (without limitation) our third-party payment service providers, data hosting and storage providers, IT and analytics service providers, back office support, business consultants, legal service providers, marketing service providers and other sub-processors. When we engage another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
● Marketing Partners. We may share your Personal Data with our marketing partners including third party service providers, advertisers, advertising networks and platforms, advertising agencies, and data aggregators to serve and offer personalized ads. We may share Personal Data with our marketing partners to correlate and match our list with our marketing partners’ lists for purposes of creating an “audience” for serving personalized ads.
● Legal Requirements: We and/or any of the third parties listed above may also be required to disclose your Personal Data to any court, law enforcement body, government department, regulator or industry body of any country where required by the laws of Singapore or any other jurisdiction, or in response to a lawful request in Singapore or elsewhere. We may also need to disclose your Personal Data in order to (i) identify, contact or bring legal action against any person who may be causing damage to or interfere with our and/or any third party’s rights or property (whether intentionally or otherwise) and/or (ii) to help with anti-money laundering and counter-terrorist financing requirements of our Partners or other third parties.
The companies within the MoneyHero Group currently operate in Singapore, Hong Kong, Taiwan, the Philippines and Malaysia. MoneyHero Group typically works with vendors and partners who operate predominantly in South East Asia but from time to time, we may work with vendors and partners in other parts of the world such as the United States. In connection with the purposes set out in this Privacy Statement, your Personal Data may be transferred outside Singapore. That means your Personal Data may be subject to different data protection regimes than that of Singapore. However, we will take all reasonable measures to ensure that your data is processed and stored securely, regardless of the country in which it is processed or stored. By using our Services and/or submitting any Personal Data to us, you acknowledge and agree that your Personal Data may be processed in and transferred to jurisdiction(s) other than your country of residence which may have different data protection laws that those in your country.
By using our Services, you consent to the use, transfer and disclosure of your Personal Data as set out above.
Keeping you Updated Regarding our Services & Direct Marketing
After you use our Services, and provided you have subscribed to receive our communications, we may use your Personal Data (including your name, address, email address and telephone number) to contact you about news, offers, events, and promotional campaigns in relation to price comparison services and/or financial services, insurance, communications, online content and other products and services that we feature on the Services from time to time.
For example, this may include credit cards, mortgages, personal loans, insurance products, broadband services etc.. We may use other data collected about you, including but not limited to your age, location, income bracket, employment, browsing history, purchases and quotes requested in order to provide materials that are customized and relevant to you. You may opt-out of receiving our newsletter and other direct marketing communications at any time by clicking on the unsubscribe link contained in our email to you.
These communications are separate to those you will receive as a result of registering an account with us. In addition to account-related communications, our logged in users will receive exclusive and/or advance access to personalized content available and distributed only to them, which may be sent by email. As a logged in user you may not opt-out of receiving membership-related messages from us, unless you deactivate your account.
With your explicit consent, we may also provide your Personal Data (including your name, address, email address and telephone number) to our Partners so that they may contact you with news, offers, events, and promotional campaigns in relation to price comparison services and/or financial services, insurance, communications, online content and other products and services that we feature on the Services from time to time.
We may also share Anonymised Data and Anonymised Aggregate Data, provided your identity will not be disclosed by such sharing, with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services, but please note that, unless permitted or required by law or as otherwise set out in this Privacy Policy, we will not disclose your Personal Data to any third parties without your prior consent.
If you have registered your Singapore phone number with any or all of the Singapore Do Not Call (“DNC“) registers (being the No Voice Call Register, the No Text Message Register and the No Fax Message Register), we will not send you promotional and marketing messages via calls, SMS, communication or data applications, and other means, to the extent the respective Register(s) is/are applicable. However, if you have previously consented to our sending you such calls or messages to your Singapore phone number, we will continue to do so until you withdraw such consent in writing, regardless of your DNC nominations (prior or subsequent to such consent).
Please note that after opting out, you may still continue to receive non-marketing messages, such as product updates and service notices as permitted under applicable laws. If you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you messages via phone call, SMS, communication or data applications, and other means about Services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt out of receiving such messages by requesting for withdrawal by writing to [email protected].
If you have any questions or concerns about the communications you are receiving from us, you can get in touch with us at any time, free of charge (see "Your Rights" below).
Third-Party Providers
If you opt to enter into a contract with a third party through our Services, the data you provide to the third party will be transferred to that third party and controlled by the third party in accordance with that third-party provider's privacy policy. Therefore, you should contact them directly for additional information in relation to their privacy policies and read all policies, terms and conditions before entering a contract. We are not responsible for how third-party providers use your Personal Data.
Data Security
We are fully committed to safeguarding the privacy of our customers, online and otherwise, and the success of our business depends on our ability to maintain the trust of our clients and customers. We apply Defense in Depth approach in securing Personal Data entrusted to us by our customers and continuously improve those measures to address security risks. We use Amazon Web Services, Inc (“AWS”) as our technology infrastructure service provider to power the main core of our Services. Data we collect is stored in data centers operated by AWS which offer best-in-class security. For more information, please visit: https://aws.amazon.com/security/.
When you register for an account with us, you will be asked to choose a password. It is your responsibility to keep your password safe, and not share it with anyone. We are not responsible for any transactions conducted by a third party that has logged in to your account using your password. If you suspect that your account has been used by someone other than you, please notify us straight away.
Despite our security precautions, we cannot fully guarantee the security of your Personal Data because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Data over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Data on a secure device within a secure environment.
Consent
This Privacy Statement supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
Use of the Services by Minors
The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not access or use our Services.
Improving our Services
In order to ensure that the services we offer you continue to meet your requirements; we might ask for your feedback. Any feedback or other information you submit to us will, unless otherwise stated, be used in accordance with this Privacy Statement and our Terms of Use.
Your Rights
You have the right to check whether we hold Personal Data about you and to require access or correction of your Personal Data. You can also unsubscribe from receiving our newsletter and other promotional communications from us at any time by clicking on the unsubscribe link in our email to you. You are also entitled to opt out of receiving direct marketing emails from us, our affiliates and any of our Partners.
If you have an account with us, you can access and/or correct the personal data we have in our possession through the account settings in the Mobile App or Website (as the case may be). If you do not have an account with us, you will have to submit a written request to us at the email address below, and we will arrange for the access or correction of your personal data subject to the verification of your identity.
If you wish to exercise any of your above-mentioned rights, or you have any inquiries or complaints in respect of your Personal Data, please kindly address your enquiries to:
Personal Data Protection
[email protected]
70 Shenton Way, #18-08 Eon Shenton, Singapore 079118
Deleting Your Account
If you wish to delete your account or request that we no longer use your information to provide you with our Services, please send your request to [email protected] and we will delete your account as soon as practicable but in any event within 72 hours of completion of all identification verification requirements in connection with your request. If you wish to delete your account for the Mobile App, you may do so via the account settings in the Mobile App. When deleting your account information, we may retain general demographic information about you such as your general activity history and will remove any personally identifiable information associated with this data so that it can no longer be associated with you for research or statistical purposes.
Changes to this Privacy Policy
We may need to revise or update this Privacy Policy from time to time to reflect changes in our Services, our business or applicable law. We reserve the right to modify this Privacy Policy periodically without prior notice. Your continued access or use of the Services after any changes or revisions to this Privacy Policy will be deemed to constitute your agreement with the terms of such revised Privacy Policy. We will always include a ‘last revised’ date as part of our privacy policy. You may check this page periodically to stay informed of our Privacy Policy.