Privacy Policy

1.1 What is BankGuru?

Your privacy is important to us. The domain name www.BankGuru.com.sg (the “Website”), is an internet based portal, owned and operated by Acquest Marketing Services Pte Ltd company duly incorporated in Singapore on January 14, 2015 under Companies Act 1956. (hereinafter referred to as “BankGuru” or “Company” or “we” or “our” or “us”).

1.2 What is this Privacy Policy?

This Privacy Policy describes the Company’s policies and procedures on the collection, use and disclosure of the information provided by the end users and the visitors of the Website. The Company shall not use the User’s information in any manner except as provided under this Privacy Policy. Every User who accesses or uses the Website agrees to be bound by the terms of this Privacy Policy and terms of service.

Interpretation: In this Privacy Policy, references to “you”, “your”, “user” shall mean the end user accessing the Website and or the Services.

1.3 Why this Privacy Policy?

The purpose of this privacy policy (the “Privacy Policy”) is to inform you of how the Company manages personal data in accordance with the Personal Data Protection Act 2012, as described under Singaporean law, (“the Act”) on its Website. Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to the Company, as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Company’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to the Company nor does it affect any rights which the Company may have at law in connection with the collection, use or disclosure of your Personal Data. The Company may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Website. Please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the Website Terms and Conditions (“Website Conditions”). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, the Privacy Policy shall prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

2.1 In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us:

• your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
• information about your use of the Website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that the Company may identify you from such information;
• your employment history, education background, and income levels;
• your payment related information, such as your bank account or credit card information, and your credit history; and
• information about your usage of and interaction with the Website and/ or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

2.2 Personal Data may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may use the collected log information about you to improve services offered to you, to improve marketing, analytics, or Website functionality.

3.1 Generally, the Company collects your Personal Data in the following ways:

• when you submit forms relating to any of our products or services;
• when you register for or use any of our services on the Website or when you register as a member of the Website, or use services on the Website;
• when you interact with our customer service officers;
• when you establish any online accounts with us;
• when you request that we contact you;
• when you are contacted by, and respond to, our marketing representatives and agents;
• when you respond to our request for additional Personal Data;
• when you ask to be included in an email or other mailing list;
• when you respond to our promotions and other initiatives;
• when you submit a job application;
• when we receive references from business partners and third parties, for example, where you have been referred by them; and
• when you submit your Personal Data to us for any other reason.

3.2 Communications with you - You, while providing the details over the Website, including but not limited to your Personal Data as mentioned hereinabove, expressly consent to BankGuru (its affiliates and business partners) to contact you, to make follow up calls in relation to the services provided through the Website, for imparting product knowledge, offering promotional offers running on Website & various other offers offered by its partners on the Sites.

3.3 The usage of the Website may also require you to provide consent for keying in your Sensitive data (including but not limited to user ids and passwords), as may be necessary to process your application through the Website. Sensitive data keyed in shall be required for enabling hassle free, faster and paperless (to the extent possible) processing of applications for financial products so opted / availed by you.

3.4 In furtherance to your usage of the Website, you expressly waive the Do Not Call (DNC) registrations on your phone/mobile numbers for contacting you for this purpose. Hence, there is no DNC check required for the number you have left on our Website. Such modes of contacting you may include sending SMSs, email alerts and / or telephonic calls.

3.5 When you browse the Website, you generally do so anonymously but please see the section below on cookies.

3.6 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/ or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

3.7 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

4.1 Generally, the Company collects, uses and discloses your Personal Data for the following purposes:

• responding to your queries and requests and responding to complaints;
• managing the infrastructure and business operations of the Company and complying with internal policies and procedures;
• facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
• matching any Personal Data held which relates to you for any of the purposes listed herein;
• verifying your identity;
• preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
• protecting and enforcing our contractual and legal rights and obligations;
• conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
• preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances;
• compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/ or
• any other purpose relating to any of the above.

4.2 In addition, the Company may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

• If you have a subscription or membership account with us
• to process your application for Online Subscription Services;
• to maintain your account with us;
• to verify and process your personal particulars and payments in relation to provision of Online Subscription Service to you;
• to provide you with the services which you have signed up for;
• communicating with you to inform you of changes and development to the Company policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
• resolving complaints and handling requests and enquiries;
• conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
• the processing of your Personal Data in relation to any of the purposes stated above.
• If you use download or use our web/mobile based application (the “App”):
• where the App includes App Subscription Services, to process your application for the related services;
• to maintain your account with us and to ensure your access of the App is within the scope of your subscription;
• to provide you with the services which you have signed up for and to push articles to you which may be relevant to you;
• communicating with you to inform you of changes and development to the Company policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
• resolving complaints and handling requests and enquiries; conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
• the processing of your Personal Data in relation to any of the purposes stated above.
• If you submit an application to us as a candidate for employment or an internship:
• processing your application including pre-recruitment checks;
• providing or obtaining employee references or other references where relevant for background screening/ vetting;
• collecting information about your suitability for the position applied for;
• organising training and staff development programs;
• assessing your performance;
• administrating benefits and payroll processing;
• providing you with tools to facilitate or as required for you to do your job;
• communicating with you as required by the Company to comply with its policies and processes, including for business continuity purposes; and
• any other purposes relating to the aforesaid.

4.3 In addition, where permitted under the Act, the Company may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

• providing services, products and benefits to you, including promotions, loyalty and reward programmes;
• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by the Company or other third parties;
• administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;
• sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and
• conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.

If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, the Company may contact you using such Singapore telephone number(s) (including via voice calls, sms, fax or any other means) with information about our products and services (including discounts and special offers).

In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

You hereby agree and understand that collection of your Personal Data by BankGuru is not limited to facilitate the purchase of a single financial product. The purpose of such collection and retention of Personal Data is towards BankGuru partnering/ assisting you in your financial portfolio throughout your lifespan. In order to assist you with other financial products in future we need to retain your data even after completion of the transaction. By filling in your Personal Data on our website, you expressly consent for the retention of the same. You may notify us anytime expressly asking to remove your Personal Data from our database to which we will duly honour such request.

5.1 The Company will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions the Act, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

• the Company affiliates;
• agents, contractors or third party service providers who provide operational services to the Company, such as telecommunications, information technology, payment, payroll processing, training, market research, storage, archival or other services to the Company;
• vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on the Company’s sites, whether in conjunction with us or not;
• external business and charity partners in relation to corporate promotional events;
• the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
• any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
• anyone to whom we transfer or may transfer our rights and duties;
• banks, credit card companies and their respective service providers;
• our professional advisors such as our auditors and lawyers;
• relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
• any other party to whom you authorise us to disclose your personal data

6.1 When you interact with us on the Website, we may collect or analyse anonymised information from which individuals cannot be identified (the “Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the Website and common entry and exit points into Website.

6.2 the Company uses “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter the Website. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

6.3 the Company may use an independent company (the “Third Party Market Research Company”) to measure and analyse the internet usage across the Website. The Company uses the Third Party Market Research Company’s services to collect the following core information on the usage of the Website, including:

• The number of page views (or page impressions) that occur on the Website;
• The number of unique visitors to the Website;
• How long these unique visitors (on average) spend on the Website when they do visit; and
• Common entry and exit points into the Website.

6.4 This information is aggregated by the Third Party Market Research Company and provided to the Company to assist in analysing the usage of the Website. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other internet portals.

6.5 Pages on the Website may be coded with software which enables the Third Party Market Research Company to track visitors to the Website.

6.6 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of the Website.

6.7 Interest based Ads/communication: By filling in your data on Website you expressly agree for behavioural targeting/ re-targeting by the Company or any third party. Company may partner with a third party service provider to either display advertising on our Website or to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on the Website and other Sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by notifying us. Your opting out under this provision shall not affect in any manner BankGuru’s right to send you generic ads not based on behavioural targeting / re-targeting.

The Website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to the Website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left the Website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

8.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in the Personal Data Protection Statement or elsewhere on the Website.

8.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to the Company on your behalf.

8.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, the Company may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with the Company and your being in breach of your contractual obligations or undertakings, and the Company’s legal rights and remedies in such event are expressly reserved.

8.4 You can contact at the below address in case of any query, concern or request:

Acquest Marketing Services Pte Ltd

61 Kaki Bukit Avenue 1, #02-22

Shun Li Industrial Park, Singapore 417943

Email id: [email protected]

This Privacy Policy is intended to cover collection of information on Website from residents of Singapore. If you are visiting Website from outside Singapore, please be aware that your information may be transferred to, stored and processed where our servers are located and our central database is operated. The data protection and other laws of Singapore might not be as comprehensive as those in your country. Please be assured that we take reasonable measures to ensure that your privacy is protected.

10.1 We follow generally accepted standards to protect the Personal Data submitted to us. Since no method of transmission over the Internet, or method of electronic storage, is 100% secure, therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can contact us at [email protected].

10.2 We use a combination of firewalls, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect BankGuru online accounts and systems from unauthorized access.

10.3 When you register for the Service, BankGuru requires a password from you for your privacy and security. BankGuru transmits information such as your Registration Information for Website or Account Credentials securely.

10.4 Our servers are in secure facilities where access requires multiple levels of authentication, including an identity card and biometrics recognition procedures.

10.5 Our databases are protected from general employee access. We encrypt your Service password so that your password cannot be recovered by anyone including us. All backup drives and tapes also are encrypted.

This Privacy Policy shall be governed in all respects by the laws of Republic of Singapore.