This Privacy Policy (“Privacy Policy”) explains to you how International Capital Solutions Pte Ltd (UEN No. 201526317H), a company duly incorporated in Singapore (“we”, “us” or “CapSol”) manages your personal data. Please read through this Privacy Policy carefully so that you know and understand the purposes for which we collect, use and disclose your personal data.

By browsing, accessing or using the Website and/or the Service, you consent to us collecting, using, disclosing, retaining and processing your data in accordance with this Privacy Policy. If you do not agree to any of the terms in this Privacy Policy, you must not use or access the Service, or the Website.

In this Privacy Policy, “include” (and its derivatives, such as “including” and “includes”) means to include without limitation and every occurrence of this term shall be construed as defined aforesaid, whether or not capitalised; “Service” means the online peer-to-business financing platform owned and operated by CapSol at the Website, and includes the Website, Service Content and all features, content, services and applications offered by us to you or made available to you by us on or through the Website or otherwise in connection therewith and any and all updates, upgrades, supplements and releases thereto as may be provided by us from time to time; “Service Content” means (i) content, features, data, information, applications, text, audio, image or other files or materials produced, generated, displayed in or otherwise made available by us through or in relation to the Service (including Listings); and/or (ii) data and information relating to the use of the Service, the users of the Service and the transactions on the Service. “Website” means the website owned and operated by CapSol at www.capitalsolutions.com.sg, such as may be amended or updated by us from time to time.

We reserve the right, at our sole discretion, to change, modify or otherwise alter this Privacy Policy at any time. Should you have any questions regarding this Privacy Policy, please contact us using the contact information listed at the end of this Privacy Policy.

This Privacy Policy covers our collection, use and disclosure of your information through the Service and the Website. Unless otherwise provided herein, it does not cover any collection, use or disclosure by third parties of your information or personal data through the Service, or through websites, software, products or services that we do not control or own, or through any third party applications, features or services made available via the Service, or the Website.

 

WHAT KINDS OF INFORMATION WE COLLECT

Personal Data

We collect, use, retain and process the following Personal Data (“Personal Data”) from you when you use the Service, register for an account with us, provide us information (via email or through the Service), update or add information to your account or profile pages, send us messages, comments, questions, testimonials or suggestions, participate in polls, surveys and other communication channels and services in relation to the Service, or when you otherwise correspond with us regarding the Service:

  • your first and last name, NRIC or other identification numbers, email address, physical address, date of birth, phone number(s), bank account number(s);
  • your account usernames and passwords;
  • information disclosed to us about you by third parties;
  • content which you have contributed to or posted on the Service or Website;
  • information regarding your use of the Service; and/or
  • information which you transmit or receive using the Service and which identifies you or another person.

For the avoidance of doubt, we consider Personal Data to mean information that can be associated with a specific person and which can be used to identify that specific person whether from that data or from that data in combination with other information that we have or are likely to have access to. Personal Data does not include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.

Collection and use of Personal Data

You agree that we can collect, use, retain, process and disclose to third parties, the Personal Data and such other information or data as you may provide or make available to us (through the Service or otherwise) in the manner as described in this Privacy Policy (and in the relevant privacy policies of third party service providers referenced in this Privacy Policy) and for purposes which include:

  • providing you with the use of and improving, the Service, the Website or other services we make available to you;
  • to provide you with personalised services, or to customise your user experience of the Service;
  • to contact you about your account and our services, including sending you information regarding the Service and keeping you informed of new features, updates or releases related thereto or information relating to new products and services;
  • provide you with advertising and marketing information;
  • to respond to, process and handle your queries, feedback and suggestions, provide services, complete transactions you have requested and/or generally for administering and/or managing our relationship with you;
  • sending you updates and publications, where you have requested or consented to be on our mailing list;
  • sending you information on any updates or changes to our terms and conditions, guidelines, policies and/or other administrative information;
  • to perform audit, compliance, “know-your-client” or other verification checks such as may be required to comply with applicable laws or our internal or corporate financial, compliance, accounting or other policies;
  • to troubleshoot and/or resolve problems with the Service, or to resolve disputes;
  • to suggest that you use or take advantage of certain features within the Service;
  • any purposes which we notify you of at the time your Personal Data is collected from you or disclosed to us; and
  • as we believe to be necessary or appropriate:
  • in any manner permitted under applicable law, including laws outside your country of residence;
  • to comply with legal process and applicable laws and regulations (or any request or direction of any public and government authorities, including public and government authorities outside your country of residence);
  • to enforce terms and conditions applicable to the Service;
  • to protect our rights, privacy, safety, property, operations or those of any of our users or affiliates;
  • to allow us to pursue available remedies or limit the damages that we may sustain;
  • if we reasonably believe that an emergency exists involving immediate danger of death or serious physical injury to any person that requires immediate disclosure of communications or your Personal Data; and
  • to prevent, detect, mitigate and investigate potentially illegal acts, fraud and/or security breaches and to assess and manage risk, including to alert you if fraudulent activities have been detected on your accounts.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Service, we may collect and maintain records of such information into a file specific to you.

All Personal Data collected is stored in our database and may be archived elsewhere.

Non-Personal Data

When you use Service and/or the Website, we may collect, use, disclose, retain and process (or our systems may automatically collect, use, disclose, retain and process) directly or through Third Party Services:

  • log data, including your unique User Device number, the IP address of your computer or device, information about your computer or mobile internet browser type and operating system, the dates and times of your use of the Service, the number and frequency of visitors to or the Website, the URL that you just came from and the URL you next go to (whether these URLs are on Website or not);
  • session and usage data about your use of the Service, including connection and service-related data such as information relating to the connection request, server communication and data sharing, network measurements, quality of service and date, time and location of usage; and/or
  • aggregate information about the use of the Service (which may contain log data and session and usage data) in respect of a group or category of services or users but which contains no personally identifiable information about the users,

(collectively “Non-Personal Data”).

For the avoidance of doubt, “Non-Personal Data” is information that does not identify you or any other individual and does not include Personal Data.

Collection and Use of Non-Personal Data

We may use Non-Personal Data for any purpose, including:

  • for our own internal purposes;
  • to measure traffic patterns;
  • for the purpose of system administration;
  • to enable us to analyse, research and track usage of the Service including conducting internal research on user demographics, interests, behaviour and trends among our users;
  • to provide, improve and modify the Service or the Website;
  • to improve our algorithms, measure service usage, publish summaries online or offline, develop new features;
  • to enable us to improve on the Service and/or Website; and/or
  • for promotion and marketing purposes.

 

COLLECTION AND USE OF DATA THROUGH THIRD PARTY SERVICES

You acknowledge that we or Third Party Services may collect, use and/or retain data which include your Personal Data and Non-Personal Data when you use the Service and/or the Website and you consent to such collection, use and retention by us or the relevant third parties, including in the manner as set out in this Clause 2 and in the relevant third party privacy policies referenced herein.

Amazon Web Services

Data and information (including Personal Data and Non-Personal Data) relating to, in connection with, processed and/or used by the Service and/or the Website are stored on servers provided by Amazon Web Services. Amazon Web Services is a subsidiary of Amazon.com. Their privacy policies may be found at http://aws.amazon.com/privacy/ and http://www.amazon.com/privacy respectively.

 

SHARING DATA WITH THIRD PARTIES

  • We may disclose your Personal Data and Non-Personal Data in the ordinary course of our business to certain third parties approved by us (which may or may not be in Singapore), to use on our behalf or otherwise, including:
  • to our affiliates, agents, service partners and third party providers, to facilitate or enable our provision of services to you and the development, support, maintenance and operation of the Service;
  • to our third party service providers who provide services such as website hosting, maintenance, data analysis, payment processing, order fulfilment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services, or to which we may outsource one or more aspects of our business, but only to the extent necessary for them to carry out their services for us;
  • to identify you to anyone to whom you send messages through and transact with on the Service;
  • to a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings);
  • to our partners and investors or potential partners and investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business;
  • to an acquirer of our business or assets or any part thereof; and/or
  • for any of the purposes for which your Personal Data may be used by us as set out in this Privacy Policy including under Clause 2

We use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage and related technology required to provide you with our services and enable you to use the Service. These third parties are located outside our offices and may also be located outside your country of residence. By submitting your Personal Data to us, you agree to our disclosure of your Personal Data to such third parties and their use of the same.

Your Personal Data may be stored and processed in any country where we or our service providers have facilities and by using the Service you consent to the transfer of your Personal Data to countries which may be outside of your country of residence and which may provide for different and less stringent data protection rules than in your country. If you object to your Personal Data being transferred or used as described in this Privacy Policy, please immediately stop using the Service.

 

COOKIES

When you visit the Website, we may send one or more “cookies” to your computer hard drive through your web browser. A cookie is a small file containing a string of information that a website stores on a visitor’s computer and that the visitor’s browser provides to the website each time the visitor returns. Any use of cookies by us will be solely for the purposes of improving the quality of access to and use of the Service, or the Website. Purposes for which cookies will be used include:

  • storing user preferences and tracking user trends (such as how people use the Service and their access preferences);
  • obtaining information on how and when pages in the Website are visited and by how many people; and
  • enabling you to enter your login information less frequently.

 

SECURITY

We use commercially reasonable physical, administrative, technical and electronic measures and safeguards to protect your information from unauthorised access. Please be aware that no security measures that we take to protect your information is absolutely guaranteed to avoid unauthorised access or use of your Personal Data or is impenetrable. We hereby disclaim all liability for the security of your Personal Data, which may be compromised by unauthorised entry, use or disclosure, hardware or software failure and other factors.

You are solely responsible for protecting your username and password that are used to access the Service, against unauthorised access and use and for all actions taken with such username and password. You acknowledge that if you lose control of your username and password, you may lose substantial control over your Personal Data and be potentially subject to legally binding actions taken on your behalf by an unauthorised user. If your username and password has been compromised for any reason, you should immediately change the same. You should also sign off once you have finished using a shared computer.

 

RETENTION PERIOD

We will retain your Personal Data (including Personal Data from closed accounts) for as long as we deem necessary and relevant for our operations and/or to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Your Personal Data may or may not be encrypted while stored or archived by us.

 

CHANGES TO THE PRIVACY POLICY

  • We may modify or revise the terms of this Privacy Policy at any time in the exercise of our sole discretion, with or without notice to you, and you agree to be bound by all such modifications or revisions. We may (but shall not be obliged to) notify you of changes to this Privacy Policy by email or through the Service, or by displaying the new terms on-screen when you next use the Service. Notwithstanding the foregoing, you agree that you are responsible for periodically reviewing the Privacy Policy for any changes and keeping yourself informed of the most up-to-date version of this Privacy Policy, at the Website.
  • If you do not agree to any modification or revision to this Privacy Policy, you are to stop using the Service immediately. Your continued use of the Service after a change or update has been made will constitute your assent to and acceptance of the revised Privacy Policy.

 

CONTACTING US / REPORTING VIOLATIONS

Please contact our Data Protection Officer by email in writing at [insert email address] if:

  • you have any questions or feedback relating to your Personal Data or this Privacy Policy, or if you wish to report any violations or abuse of the Service;
  • you wish to retrieve historical data;
  • you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us; and/or
  • you wish to opt out from receiving marketing-related emails, texts, phone messages or other communications from us on a going-forward basis.

In your request relating to (b), (c), (d) above, please make clear what information you would like to have changed, or otherwise let us know what limitations you would like to put on our use of your Personal Data. We will try to comply with your request as soon as and to the extent reasonably practicable. You acknowledge that we will not be able to remove your Personal Data from the database of any other users with whom you have shared such information or from the databases of third parties which you previously authorised us to share such information with. Please also note that if you do opt out of receiving marketing-related communications from us, we may still send you important administrative messages and that you cannot opt out of receiving such administrative or other important messages.

This Privacy Policy shall be governed by and construed in accordance with Singapore law.
Last updated: 15 September 2015