Privacy Policy

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This Privacy Notice and its Addendum(s) (“Privacy Notice”) describe how Seedflex Technologies Pte Ltd, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Seedflex”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of Seedflex's platform and websites (respectively “Platforms” and “Websites”), as well as products, features and other services globally, operated by Seedflex (collectively, “Services”).

This Notice applies to our users (collectively "you", "your" or "yours")

“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information and financial information.

We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Notice with your consent, or in compliance with applicable laws, such as where:

• it is required for us to comply with legal requirements;
• it is required for us to enter into or perform a contract with you; and/or
• for our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Notice.

1. Collection of Personal Data

We collect Personal Data about you in the ways listed below. We may also combine Personal Data collected via these various channels:

When you provide your personal data to us

We collect your personal data when you provide it to us, for example when you:

• Complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
• Provide information to assess your eligibility to provide our products;
• interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
• participate in contests or events organised by us (such as the pictures, audio, or videos you may submit, which may include images of yourself);
• verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);      
• fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information);

When our services are used

Personal Data may be collected through the normal operation or use of our Platform and Services. Some examples are:

• your location information;
• feedback, ratings and compliments;
• information about how you interacted with our Platform, Website or
• device information (such as hardware model and serial number, IP addresses), versions, GPS location, IMEI number, and advertising identifiers or any information that may indicate device or app modification);

From other sources

We may collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:

• referral programmes;
• our business partners, such as payment providers, on-demand platforms;
• insurance and financial providers;
• credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;    
• publicly available or governmental sources of data;
• marketing services providers or partners.

Sensitive Personal Data

Some of the Personal Data that we collect may be sensitive in nature. This may include Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We collect sensitive Personal Data only with your consent and/or in strict compliance with applicable laws. In the event that you are required to furnish any documentation or information to us for any Purpose which may contain such sensitive Personal Data (which is not required that Purpose), you agree to redact such sensitive Personal Data before providing such documentation or information to us.

Seedflex only collects, uses and discloses personal data with an individual’s consent or as otherwise permitted under the applicable laws and regulations.

‍2. Use of Personal Data

Seedflex may use your Personal Data for the following purposes set out in the list below. (“Purposes”).

Providing services

Your Personal Data will be used to provide, personalise, maintain and improve our Platform, Websites and Services. This includes using your Personal Data to:

• create, administer and update your account;
• process, manage or verify your eligibility for or application of products,
• conduct due diligence checks and risk assessments / analysis;
• verify your identity and age (where necessary);
• offer, obtain, provide, facilitate or maintain financing solutions;
• personalise your platform experience (such as to recommend products and services relevant to you);
• make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service
• perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
• protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
• invite you to participate in our surveys and studies;

Safety and security

We use your data to ensure the safety and security of our Services and all users. This includes:

• verifying your identity when you log in to the platform;
• using device, location, profile, usage and other Personal Data to prevent, detect and combat fraud or unsafe activities;
• monitoring compliance with our terms and conditions and policies.

User support

We use Personal Data to resolve user support issues. For example, we may:

• investigate and address concerns;
• monitor and improve our user support responses;
• respond to questions, comments and feedback; and
• inform you about steps taken to resolve user support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate development of insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect/prevent/prosecute crime, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

• comply with court orders or other legal, governmental or regulatory requirements;
• enforce our Terms of Service or other agreements; and
• protect our rights or property in the event of a claim or dispute.

Marketing and promotions

We may use your Personal Data to send you marketing communications relating to customised products or services (that may be of interest or relevance based on your profile), For example, we may:

• send you special offers that may be of interest or relevance to you
• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by various means, where applicable (including by SMS, chat applications (e.g. WhatsApp, Telegram, LINE, Viber, WeChat, Zalo), push notification, call, and by email).

If you wish to unsubscribe to the receiving of such marketing communications, please click on the unsubscribe link in the relevant email or message.

Please note that while you may opt out of marketing or promotion communications, Seedflex may still send you account and / or service-related messages (such as two-factor authentication, information on your transactions, rewards, etc.).

3. Disclosure of personal data

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the Seedflex group share resources, such as infrastructure and technology with each other to provide you with a consistent, relevant and secure experience when you use our products or Services, and for the Purposes set out in this Privacy Notice.

With Seedflex service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

• payment processors and facilitators;
• debt collectors;      
• credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
• background check and anti-money laundering service providers;
• cloud storage providers;
• document storage and management providers;
• advertising and marketing partners and platform providers;
• data analytics providers;
• research partners, including those performing surveys or research projects
• educational and training institute partners;
• insurance and financing partners;    
• third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
• service providers who perform identity verification services; an

‍With our legal advisors and governmental authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

• where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or    
• where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

Business transfers

We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Data will however remain subject to our obligations made in any pre-existing Privacy Notice that you have agreed to.

Seedflex will not sell, rent, lease or release your Personal Data for secondary purposes unless your consent has been previously obtained in accordance with the law.

4. Retention of personal data

We retain your Personal Data for the period necessary to fulfill the Purposes outlined in this Notice unless a longer retention period is required or allowed by law. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to erase, destroy, anonymise or prevent access or use of such Personal Data for any purpose other than compliance with this Notice, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.  

5. Cross-Border Transfers of Personal Data

We may transfer, store, or disclose your Personal Data to an overseas party. When we transfer your Personal Data from to any overseas party, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data) or one of the safeguards permissible by laws.

6. Cookies and other related Technologies

Seedflex, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, advertising identifiers and similar technologies (such as software development kits (SDKs), (collectively, “Cookies”) in connection with your use of the Websites and Platform, which may be persistent or stored only during an individual session on your browsers or devices.

Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may be used for various purposes such as to:

• provide the essential, basic functions of the use of our Websites and Platform;
• authenticate you, or remember your user preferences and settings;
• delivering and measuring the effectiveness of advertising campaigns, such as by measuring number of views or clickthroughs;
• analyse site traffic and trends;
• serve you relevant advertisements across other apps and websites owned by other companies (whether by us or by other advertisers); and
• enhance user interface and experience by generally understanding the online behaviors and interests of users who interact with our Website, Services or Platforms.

Seedflex may allow third parties to use Cookies on the Websites and Platforms to collect the same type of Personal Data for the same purposes Seedflex does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

7. How to contact us

If you have any queries about this Notice or would like to exercise your rights set out in this Notice , please contact support.my@seedflex.com