Privacy Statement

Keeping you safe and secure.

Posted: July 08, 2016 (v1.02)

Introduction

Seedly is a software as a service (SaaS) platform that offers automated budget data aggregation and portfolio visualization via a mobile application. Security and safety of our clients’ data and information is top priority. We explain here how we handle and protect your information. This was also constructed in accordance to the Laws of Singapore and the Personal Data Protection Act, (collectively known as the PDPA)

Anonymous User Policy

Seedly is an anonymous service and we do not request your address, identification number, phone number, or other information by which you may be personally identified (collectively, your “Personal Identification Information”). However, should you provide us with information, for example name and email, we will treat it with upmost confidentiality to keep it secure.

For your added protection, please refrain from including any Personal Identification Information or other non-public information in your communication with us.

In the event your Data contains any Personal Identification Information, Seedly is not programmed to read, process or store such information. This information will also not appear in your Seedly user area or in the reports generated by us.

Our Data Retention policy further dictates that we will delete your original Personal Financial Data (as defined below) within a reasonable time after the relevant financial information therein has been extracted and processed into our database for the purpose of generating reports. Or when you request us to do so via the mobile application.

Whilst we take all reasonable steps to implement and comply with the above measures, please be informed that these measures are provided on a best-effort basis. In the event any such Personal Identification Information is inadvertently captured either in your Seedly user area or in any report generated by Seedly, please immediately notify us so that we may promptly rectify the situation.

Communicating with us

We offer two specific communication methods that are designed to maintain your anonymity in the course of your interaction with us.

The first communication method is to utilise the customer service messaging box found in the Seedly user area on the mobile application under “Contact Us”.

The second communication method is via anonymous email. Upon opening your account, we will ask you to register an email address that will be linked to your Seedly account. We encourage you to set up an email address which contains no information from which your personal identity may be inferred, for the sole use of Seedly. If required, we can guide you on the setup of such an email address.

Aside from the above, you may still communicate with us via telephone, third party internet voice and chat providers, social media communication channels or via any email address that you regularly use. In such cases, we may receive information that discloses or could be used to establish your identity. We will, however, respect the confidentiality of such information (as with any other information that we receive from you) and will only use and/or retain the information strictly in accordance with our usage policy (see Use of Your Data and Information below).

Subscription payment

As of now, Seedly is offering two forms of service as a free and premium model. We offer you the facility to make your Seedly subscription payments anonymously using your credit or charge cards. Our payment processor is Braintree, a division of PayPal, and only requires input of your credit card number, expiry date and card security code (Visa CVV2 or Masters CVC2) on their secure platform. You do not have to provide us with your name, address, phone number or other Personal Identification Information to make payment. The receipt of payment will be sent to your email account registered with us.

You may also choose to make payment to us by some other method but please be reminded that, in such cases, we may again receive information that discloses or could be used to establish your identity. We will, however, again respect the confidentiality of any such information and will only use and/or retain the information strictly in accordance with our usage policy (see Use of Your Data and Information below).

Use of your data and information

Personal Financial Data

We use the financial account statements and other financial data that you provide to us or authorise us to have access (collectively, your “Personal Financial Data”), in order to deliver the Seedly service you have subscribed to. We will maintain such data as strictly confidential and will not sell, lease or distribute the same to any third party (other than certain trusted third party service providers involved in the operations of our business and performing services on our behalf, with restricted access to customer data and information, on a need-to-know basis only, and in compliance with this Privacy Statement) without your documented approval, unless we are required or requested to do so by law or any regulatory authority for the jurisdiction that we operate in. For the avoidance of doubt, Personal Financial Data for this purpose does not include information that is aggregated with similar data from other users to produce Meta Data as described below, or is otherwise no longer identifiable to any specific Seedly user.

Meta Data

For the purpose of producing statistical collective data amongst Seedly users (“Meta Data”), we may aggregate your Personal Financial Data together with similar data from other Seedly users. Meta Data will be produced in such a manner that the underlying data will be no longer identifiable to any specific user. We may share Meta Data amongst Seedly users as part of the service provided, and also with our business partners and other third parties to help us make improvements and/or enhancements to our products and services and for marketing, research and academic purposes.

Personal Identification Information

As stated earlier, should you voluntarily provide us with any of your Personal Identification Information, we treat such information with strict confidentiality. We will not sell, lease, or distribute the same to any third party without your documented approval, unless we are required or requested to do so by law or any regulatory authority for the jurisdiction that we operate in. Such data will be used solely to facilitate communication, and processing of internal administrative and record keeping.

Salt Edge End User License Terms

Seedly adopts a third party aggregation solution which aids the mobile application in processing the financial data. The main terms can be found here, but the truncated important points will be identified here. In accessing and using the Services you represent that you are the legal owner of the Provider Account Data and that you have the authority to appoint, and do expressly appoint Salt Edge and/or our third party providers as your agent with limited power of attorney to access and retrieve Provider Account Data on your behalf. You further acknowledge that Salt Edge does not (nor do our third party providers) review or analyse Provider Account Data and you agree that we are not responsible for its completeness or accuracy. Any transactions or informational activities performed at any Provider’s website are not made through the Services and Salt Edge assumes no responsibility for such transactions or activities. You acknowledge that you are solely responsible for any changes to Provider Account Data, and that any such changes must be made at the Provider’s website.

Keeping your data and information safe

What we do

We are committed to the safety and security of your data and information. We place your data and information in a protected and secure database and deploy firewalls, SSL and encryption technology for data transmission. We subject ourselves to regular checks by third party security evaluation specialists and restrict access to customer data and information by our staff on a need-to-know basis only. We also implement and maintain procedures to monitor staff activity regarding such access. On top of these measures, we implement the Anonymous Users Policy as mentioned earlier.

The aforementioned security efforts do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not warrant that our servers or network will be immune from such attacks. We are not liable for any loss or damage arising from such risks.

What you should and should not do

You should keep your Seedly user ID and password strictly confidential at all times and not share these details with anyone. In public areas, you should exercise caution and not leave your computer unattended whilst logged into your account. You should also avoid using public computer terminals to access your Seedly account, unless you can adequately verify that the terminal is free from spyware and that you can erase all of your information upon exiting the terminal. We will not be liable for any loss or damage arising from unauthorised access to your account due to any failure to comply with these precautions.

Other data

Seedly may record certain non-personal information such as website usage and browsing activity, data displayed or clicked on (such as UI elements), and others (such as IP address, cookie ID, and referrer URL). Along with cookies, Seedly may also use third-party tracking technologie, such as Mixpanel and Google Analytics, to record similar information regarding you and your activity on the Seedly application. We may grant access to your data and information to certain trusted third party services providers that we work with, but only to perform the service on our behalf with restricted access to customer data and information on a need-to-know basis only, and in compliance with this Privacy Statement.

Data Retention

We will delete your original Personal Financial Data within a reasonable time after the relevant financial information has been extracted and processed into our database for the purpose of generating reports.

We will retain your account information for as long as you use Seedly. If you decide to stop the service, we will delete all such data within a reasonable time after the termination of the service, subject to retention for purposes of complying with applicable laws, resolving disputes, enforcing the terms of our agreement with you and protecting Seedly’s intellectual property rights.

Changes

Your use of this Site is subject to these Terms of Use. By using the Site, you are deemed to have accepted and agree to be bound by these Terms of Use. We may make changes to these Terms of Use from time to time. We may notify you of such changes by any reasonable means, including by posting the revised version of these Terms of Use on the Site. Your use of the Site following changes to these Terms of Use will constitute your acceptance of those changes. These Terms of Use will be governed by and construed in accordance with the laws of Singapore.

Please inform us of any changes to your Personal Identification Information and Personal Financial Data that you provide to us and we will take steps to update our records after receiving such notification.

Contact

If you have questions or concerns about this Privacy Statement or about our use or retention of your Personal Identification Information or Personal Financial Data, please contact us via email at support@Seedly.sg, or via physical mail, addressed to Seedly Pte. Ltd, 21 Heng Mui Keng Terrace, Singapore 119613, or contact us (weekdays 10:00 – 18:00 Singapore time).