By signing up, logging in and accessing the Website, you represent that you are at least eighteen (18) years old, and duly authorised to create an account with Aspire and obtain the Services. You are deemed to have read, understood and accepted the terms and conditions of this Policy as may be amended from time to time. Where acting on behalf of an organisation, you represent and warrant that you have the right to consent to the terms of this Policy on behalf of the organisation and any other user who might access the Website or the Services on behalf of the organisation.
Aspire has in place measures to protect your privacy and personal data. This Policy describes how we may collect, use, disclose and process data which is provided to us and applies to any individual's personal data which is in our possession and over which we have control.
For the purpose of this Policy:
“Aspire DPO” shall mean the Aspire data protection officer, being the Chief Technology Officer and Co-founder of Aspire. He can be reached at the following address:
Aspire FT Pte. Ltd.
1 Syed Alwi Road, #04-04
“PDPA” means the Personal Data Protection Act 2012.
a. From time to time, Aspire may collect data which enables an individual to be identified ("Personal Data") in connection with the use of the Website or the Services. This includes information such as names, contact details, addresses and other identification details of individuals who access or use the Website and the Services. Furthermore, Aspire is statutorily required to comply with all applicable laws, regulations, notices and guidelines issued by the relevant governmental and regulatory authorities, including but not limited to the Payment Services Act (No. 2 of 2019), which require the collection of Personal Data.
b. Aspire may also collect information ("Collected Data") from or about the devices which are used to access the Platform. Such information includes, but is not limited to:
i. attributes such as the operating system of the device, hardware version, settings, file and software names and types and device identifiers;
ii. device locations; and
iii. connection information such as the name of the ISP or mobile operator through the Platform is accessed, browser type and IP address.
c. Aspire may also collect other information ("Additional Data") directly from you in the following ways:
i. Through your activity on or through the Platform and sites you exit to (automatically collected); and
ii. Through any other data and information you provide us by whatever means of communication.
The Personal Data, Collected Data and Additional Data collectively referred to as “Customer Data”.
2. INFORMATION PROVIDED TO ASPIRE
a. Where Customer Data is provided as required by, pursuant to, or in connection with the use of the Website or any Services, you represent and warrant to Aspire that (i) the relevant individual has been notified of the purposes for which data will be collected, processed, used or disclosed; and (ii) you have obtained any such individual's consent for the collection, processing, use and disclosure of such personal data by Aspire, and have been duly authorised to do so.
b. You acknowledge to Aspire that the Customer Data is reasonably required for the purpose of operating the Website and providing the Services, and that the Customer has understood the purpose for which the Customer Data has been obtained by Aspire. In case of any doubt as to the purpose for collecting the Customer Data, please approach the Aspire DPO for clarification.
c. Aspire must be promptly informed upon becoming aware of the withdrawal by the relevant individual of his/her consent to the collection, processing, use and/or disclosure by Aspire of the Customer Data provided to Aspire. The withdrawal of such consent may affect the Services which Aspire is able to provide to you.
d. Any consent given in relation to the Customer Data shall, subject to all applicable laws and regulations, survive death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of any account in connection with the use of the Platform.
e. Your continued use of the Platform, and providing any Personal Data, shall be construed as your deemed consent to the terms of this Policy and for Aspire to collect, store and use the Customer Data in accordance with this Policy.
f. Aspire and the Customer acknowledge that to the best of our respective knowledge, there is no material adverse effect to the Customer or any individual acting on the Customer’s behalf on account of the collection, storage and use of the Customer Data.
g. Where the Customer or any individual acting on its behalf chooses not to accede to the Policy and the use of the Customer Data as specified herein, you shall expressly communicate the opt-out to Aspire in writing by way of a notice to the Aspire DPO.
h. To the extent any data is collected which is not expressly mentioned in this Policy, or used in a manner not specifically provided herein, the Customer acknowledges that such Data was collected or used by Aspire either in order to protect Aspire’s legitimate business interests or in public interest.
3. COLLECTION, STORAGE AND USE OF CUSTOMER DATA
a. Aspire may collect, store, process, disclose, access, review, transfer, share and/or use the Customer Data in accordance with PDPA and any other applicable laws.
b. Without prejudice to the foregoing, Aspire may use the Customer Data for any of its business purposes, which include, and is not limited to, the following purposes:
i. to operate, administer any account and/or offer the Services available on the Platform;
ii. to verify the identity or authority of representatives of registered clients of the Platform, and to complete statutorily mandated “Know-your-customer” due diligence;
iii. to carry out or respond to requests, questions or instructions from verified or authorised representatives or other individuals pursuant to the current security procedures;
iv. to facilitate or execute transactions on the Platform;
v. to carry out, monitor and analyse Aspire's business;
vi. for the marketing of products and services ancillary or related to the use of the Platform;
vii. in connection with any sale, merger, or similar change of Aspire's business;
viii. to comply with any applicable laws, rules, or regulations in any country;
ix. to detect, prevent and investigate fraud, and/ or managing disputes; and
x. to address Customer complaints and to rectify any problems faced by the Customer in accessing the Website or any Services.
c. Aspire may also retain the Customer Data for so long as it may deem necessary for the purposes of record retention and for its own business purposes in connection with the operation of the Platform.
4. DISCLOSURE OF DATA
a. Aspire may from time to time also disclose the Customer Data to the following (whether inside or outside of Singapore) for the purposes specified below:
i. any agent, affiliate, business partner, supplier and subcontractor which provides operation, administrative or other services to Aspire in connection with Aspire’s business operations and/or the Platform;
ii. with regulatory authorities, courts, and governmental agencies to comply with legal orders, legal or regulatory requirements, and government requests;
iii. any person or entity employed by or on behalf of Aspire or is a part of or related to any group of companies of which Aspire forms part;
iv. any actual or proposed assignee of Aspire or transferee of Aspire's rights in respect of all or any part of the assets or business of Aspire;
v. any credit bureau as well as the members of such credit bureau and other relevant third parties in connection with the use of the Platform (e.g.; banks, financial intermediaries, insurers, reinsurers, escrow agents and other P2P platforms);
vi. advertisers and advertising networks solely to select and serve relevant adverts to you and others;
vii. with our service providers, regulatory authorities, and governmental agencies to detect and prevent fraud or criminal activity, and to protect the rights of Aspire or others;
viii. with financial institutions or partners with whom Aspire jointly offers or develops the Services (but they may not use your Personal Data - in particular your email address - to independently market their own products or services to you unless you consent that they can do so); and
ix. analytics and search engine providers that assist us in the improvement and optimisation of the Platform.
b. Without prejudice to the foregoing, Aspire may disclose the Customer Data to any person or entity to whom Aspire is under an obligation or otherwise required to make disclosure pursuant to any applicable laws, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities.
c. In transferring the Customer Data to any third party, Aspire has conducted reasonable due diligence to ascertain that the third party has in place policies to collect, store and use the Customer Data in a manner consistent with the PDPA.
d. In transferring the Customer Data to any entity located in a jurisdiction outside of Singapore, Aspire shall ensure that the entity provides a standard of protection to transferred Customer Data that is comparable to the protection under the PDPA. Aspire shall ensure that the overseas recipient is bound by legally enforceable obligations or specified certifications to provide the transferred Customer Data a standard of protection that is comparable to that under the PDPA.
5. MARKETING COMMUNICATIONS
a. If you should consent, you may, from time to time, receive a variety of communications, including but not limited to newsletters, emails and text messages (the "Marketing Communications"), that may include service updates, product advertising and offers related to the Services which we believe you may be interested in.
b. At any time, you may change your Marketing Communications preferences, by contacting Aspire.
c. Apart from Marketing Communications, please note that from time to time, you may receive important service information that we believe is critical to your use of our services. In such exceptional circumstances, such information will be sent to you regardless of your preferences.
6. USE OF COOKIE
7. ACCESS AND CORRECTION; AMENDMENTS AND UPDATES
a. You may access or make corrections to the Personal Data held by Aspire. To do so, please contact the Aspire DPO.
b. Aspire reserves the right to charge such fees as it made, in its sole and absolute discretion, deemed appropriate for the grant of such access and to correct any of the Personal Data.
a. Aspire may retain the Customer Data so long as necessary and relevant for maintaining the Customer’s right to access the Platform or for providing the Services. Where the Customer ceases to use the Platform for a continuous period of 2 years, or where either the Customer or Aspire terminates the business relationship between them, Aspire shall take all reasonable steps to destroy the Customer Data or anonymise it such that no individual can be identified using such data.
b. In the event of a breach of security in respect of any Customer Data, Aspire shall promptly (but as soon as practical from a security perspective) provide notice of such breach to the Customer and any individuals acting on behalf of such Customer, setting out the extent of the breach, the affected Customer Data and any steps taken by Aspire to remedy and limit the consequences of the breach. Notwithstanding the foregoing, where Aspire determines that the PDPA allows Aspire not to provide notification in respect of a breach, Aspire may choose not to inform the Customer of such breach immediately or at all.
c. This Policy may be amended and updated by Aspire from time to time at our sole discretion. Any such amendment or update will be made available on the Platform and shall be applicable to all users of the Platform. All communications, transactions and dealings with Aspire will be subject to the latest version of this policy in force at the relevant time.
d. This Policy shall be construed in accordance with the PDPA and any subsidiary legislations thereunder. For the avoidance of doubt, the Policy is governed by the laws of Singapore. Any disputes arising from or in connection with this Policy or Aspire’s collection, storage or use of the Collected Data shall be subject to the jurisdiction of Personal Data Protection Commission of Singapore or the courts of Singapore, as applicable to the specific dispute.
e. If any provision of this Policy shall be held to be illegal, void, invalid or unenforceable under the laws of any jurisdiction, the legality, validity and enforceability of the remainder of this Policy in that jurisdiction shall not be affected, and the legality, validity and enforceability of the whole of this Policy in any other jurisdiction shall not be affected.
f. Nothing in this Policy shall be construed as Aspire providing an indemnity to any Customer in relation to any Customer Data or use thereof. Aspire expressly excludes liability or any losses which the Customer may suffer on account of Aspire’s collection, storage or use of Customer Data in accordance with this Policy. In any event, Aspire expressly excludes any liability to the Customer which are in the nature of indirect or consequential losses, special losses, loss of profits, loss of contracts, loss of reputation or goodwill, or other tangential or intangible losses that a Customer may suffer on account of a breach of this Policy by Aspire or any of its agents or service providers.