PRIVACY POLICY

This Privacy Notice (“Notice”) sets out the basis which Ask Panda ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA"). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

  1. As used in this Notice: 
    "customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and 
    "personal data" means data, whether true or not, about a customer who can be identified: 
    (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

  2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

  3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative") after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

  2. We collect information from or about the computers, phones, or other devices where you install or access our Services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices. This includes, but are not limited to: (a) Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers; (b) Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals., (c) Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

  3. We collect information about the people you are connected to and how you interact with them, such as the people you communicate with the most. We also collect contact information you provide if you upload, sync or import this information (such as an address book) from a device.

  4. We may collect and use your personal data for any or all of the following purposes:

    1. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

    2. verifying your identity;

    3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

    4. managing your relationship with us;

    5. processing transactions;

    6. sending you information and updates about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

    7. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

    8. any other purposes for which you have provided the information;

    9. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

    10. any other incidental business purposes related to or in connection with the above.

  5. We may disclose your personal data:

    • where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or

    • to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.

  6. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

 

WITHDRAWING YOUR CONSENT

  1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

  2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

  3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 10 above.

  4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

 

ACCESS TO AND CORRECTION OF PERSONAL DATA

  1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

  2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

  3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

 

PROTECTION OF PERSONAL DATA

  1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

  2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

ACCURACY OF PERSONAL DATA

  1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

 

RETENTION OF PERSONAL DATA

  1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

  2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

 

TRANSFERS OF PERSONAL DATA

  1. Your personal data may be transferred to, stored, used and processed outside of Singapore. In doing so, we will comply with the obligations under the PDPA.

 

DATA PROTECTION OFFICER

  1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner: 
    Tel: +65 6221 0958
    Email: info@askpanda.com

 

EFFECT OF NOTICE AND CHANGES TO NOTICE

  1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

  2. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

 

PERSONAL DATA NOTICE (BORROWER/LENDER)

 

  1. From time to time, Ask Panda may collect from the following information and data:

    1. personal data about a Borrower’s or Lender’s , partners, directors, officers or authorised signatories, employees, borrowers, payors, payees, guarantors, other security providers, and other natural persons related to a Borrower or Lender (collectively all of the foregoing who are natural persons, "Relevant Individuals"). Such personal data may include names, identification particulars, date of birth, contact details and other relevant personal information; and

    2. information and data generated in the ordinary course of the relationship with Ask Panda. Such personal data may include signatures, answers to questions intended for security verification, emergency contact numbers or call back contact details.

    3. We collect information from or about the computers, phones, or other devices where you install or access our Services, depending on the permissions you’ve granted. We may associate the information we collect from your different devices, which helps us provide consistent Services across your devices. This includes, but are not limited to: 1.) Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers; 2.) Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals., 3.) Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

    4. We collect information about the people you are connected to and how you interact with them, such as the people you communicate with the most. We also collect contact information you provide if you upload, sync or import this information (such as an address book) from a device.

  2. Personal data of a Relevant Individual may be processed, kept, transferred or disclosed in accordance with the Personal Data Protection Act 2012.

 

Deemed Consent

  1. A Borrower will be deemed to have consented (or obtained the consent of the Relevant Individuals) to the collection, use and disclosure of the above mentioned personal data of Relevant Individuals by the Borrower’s continued dealing, use of Ask Panda ‘s services, and/or acceptance of the terms and conditions contained herein. A Lender will be deemed to have consented to the collection of the above mentioned personal data of Relevant Individuals and the use of it (for Permitted Purposes only) by Ask Panda, by the Lender’s continued dealing, use of Ask Panda’s  services, and/or acceptance of the terms and conditions contained herein.

  2. All other parties, including any guarantor or any institution providing escrow services to Ask Panda, agree to the collection, use and disclosure of the personal data by such persons continued dealing, use of Ask Panda’s services, and/or acceptance of the terms and conditions contained herein.

 

Purposes for which Information is Used and Disclosed

  1. Information and data of or relating to the Borrower or Lender may be used and disclosed, including to places in or outside Singapore for the following purposes (collectively, "Permitted Purposes"):

    1. to make decisions relating to the arrangement of the Loan and maintaining accurate "know your client" information;

    2. to verify the identity or authority of representatives who contact Ask Panda, or may be contacted by Ask Panda, and to carry out or respond to requests, questions or instructions from verified representatives or other individuals pursuant to the current security procedures; and

    3. to conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits, reviews and troubleshooting activities.

 

Parties to whom Personal Data may be Disclosed for the Permitted Purposes

  1. Personal data of the Borrower or Lender may be disclosed, where permitted by applicable law, to the following entities (without limitation) (whether inside or outside Singapore) below for the Permitted Purposes or for processing in accordance with any Permitted Purposes on a need to know basis:

    1. any agent, contractor, or third party services provider which provides banking, remittance, administrative, mailing, telecommunications, call centres, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, payment, debt collection, credit reference checks or securities clearing or other services to Ask Panda ties in connection with the operation of business of Ask Panda;

    2. any person or entity which is part of Ask Panda and is under a duty of confidentiality to the disclosing Ask Panda entity although only to the extent necessary to fulfil the relevant Permitted Purposes;

    3. any person or entity to whom Ask Panda is under an obligation or otherwise required to make disclosure pursuant to legal process, or any other foreign or domestic legal and/or regulatory obligation, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities; and

    4. any actual or proposed assignee of Ask Panda or transferee of Ask Panda’s rights in respect of any Borrower or Lender, or all or any part of the assets or business of Ask Panda, or any party giving or proposing to give a guarantee or third party security to guarantee or secure the obligations of the Borrower.