facebookPrivacy Statement - Seedly
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Privacy Statement

Last Updated: Aug 13, 2021

Introduction

Seedly Pte. Ltd. (“Seedly”, "we", “us” or “our”), is part of Hyphen Group (https://www.hyphengroup.io/), a portfolio of digital financial services companies that empowers people to build healthier financial lives through easy online comparison and education tools and accelerates the digitisation of the financial industry through SaaS solutions.

Seedly operates a software as a service (SaaS) platform that offers automated budget data aggregation and portfolio visualization via its website located at www.seedly.sg, including the Community forum, content, features, tools, data, software and functions made available by us through the Website, our mobile applications (including the Seedly: Personal Finance 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) (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 data protection laws of Singapore. 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.

Collection of Information

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.

Information We Collect 

While registering for an account and/or using our Services, your Personal Data may be collected 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 will ask for your email address;
  • When you register an account on our Services, we may ask for your name and/or email address,;
  • When you register an account on our Services and/or log in through third-party social logins (i.e. 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; and
  • 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.

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)
  • financial account statements and other financial data
  • 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) and
  • information related to any of the above.

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.

Automatic Collection of Computer Data 

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;
  • 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.  You can also access your previously saved quotes;
  • 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 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.  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/.

Information Provided to us by Third-Party Sources 

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 third party providers of our Partners (defined below).

Information from Integrated Services like Facebook or Apple

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 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.

Third-Party Providers

If you opt to enter into a contract with a third party for any products or services mentioned on 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.

Accuracy and Retention of Personal Data

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.]

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

You have the right to request access to and correction of your Personal Data as held by us.  Please see the Your Rights section of this Privacy Statement for more information.

All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as permissible by applicable law(s). We will delete your original Personal Financial Data (defined below) 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 only retain your account information for as long as reasonably necessary to fulfil 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.  

Use of your data and information

We use the information we collect about you for our legitimate business interests to provide, operate and maintain 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 answer your queries and to communicate with you, for example, providing you with alerts, notifications and recommendations, or to provide customer support;
  • 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;
  • [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;
  • with your consent, for direct marketing purposes (see "Direct Marketing" below);
  • to troubleshoot, 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, property and/or rights of our users, us and/or any third party;
  • 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.

Personal Financial Data

We use the financial account statements and other financial data that you provide to us or authorise us to have access to (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.

Salt Edge Inc. End User License Terms

We have engaged the services of Salt Edge Inc. ("Salt Edge"), a third-party aggregation solution provider, in order to aid the processing of financial data by our mobile application, the Seedly Personal Finance App.  The purpose of our Personal Finance App is to allow users to understand their cashflow and budgeting needs and the Salt Edge solution assists with this.  The main terms and conditions attaching to Salt Edge Inc.’s services can be found here (the "EULA").  As a condition of accessing and using the Seedly Personal Finance App, you agree to the EULA and all other applicable Salt Edge terms and conditions including its Privacy Policy, and represent that you are the legal owner of the Account Data (as defined in the EULA) and that you have the authority to appoint, and do expressly appoint Seedly, Salt Edge and/or its third-party providers as your agent with limited power of attorney to access and retrieve Provider Account Data including but not limited to your iBanking name, your iBanking PIN/Password, your bank account balance details and/or your  bank account or card transaction details, on your behalf. You further acknowledge that neither Seedly nor Salt Edge (nor our respective third-party providers) review or analyse Account Data and you agree that we are not responsible for the completeness or accuracy of such data.  Any transactions or informational activities performed at any Partner’s website are not made through the Services and neither Salt Edge nor Seedly assume any responsibility for such transactions or activities.  You acknowledge that you are solely responsible for any changes to your Account Data, and that any such changes must be made at the Partner’s website.

Use of Non-Personal 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 and/or Personal Financial 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 the CompareAsia 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.

Anonymised Data and Anonymised Aggregate Data are not Personal Data, and consequently the provisions in this Privacy Statement are not applicable to such data.

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 the Hyphen 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 information with our partners who are financial institutions, banks, brokers, credit institutions, lenders, insurance companies, investment companies 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.
  • Agents, Consultants and Related Third Parties: We rely on service providers to help support our business, 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 and marketing service providers. 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.
  • 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.

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 not be protected to the same or similar level as it would in 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 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 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.

While, as explained above, we may also share Anonymised Data with third parties for various purposes (including marketing and advertising), please note that, unless permitted or required by law or as otherwise set out in this Privacy Statement, we will not disclose your Personal Data to any third parties without your prior consent.

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). 

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/.

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. 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

It is your responsibility to keep your Seedly user ID and password safely and treat it as 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 reasonable precautions on your part. We are not responsible for any activity 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 wish to exercise any of your above-mentioned rights, or you have any inquiries or complaints in respect of your Personal Data and/or your Personal Financial Data, please kindly address your enquiries to:

Personal Data Protection
EMAIL: [email protected]

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.  When deleting your account information , we may retain general demographical 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

Your use of this website and the Services is subject to our Terms of Use and this Privacy Statement. By using the Services, you are deemed to have accepted and agree to be bound by both of the above. We may make changes to either of these from time to time. We may notify you of such changes by any reasonable means, including by posting the revised version of this Privacy Statement on the Services. Your use of the Services following changes to this Privacy Statement will constitute your acceptance of those changes.

This Privacy Statement will be governed by and construed in accordance with the laws of Singapore.