The website https://aspireapp.com (and together with the mobile application version thereof, hereinafter referred to as the "Platform") is maintained and operated by Aspire FT Pte. Ltd. ("Aspire", “we” or “us”).
By accessing the Platform or using our Services (as defined below), you represent and warrant to us that you have read, understood and agree to the terms of this Policy.
If you do not agree to the terms of this Policy, you must not access the Platform or provide any Personal Data (as defined below) to us. In addition, if you are a customer of Aspire (“Customer”) or representative of the Customer, you must notify the Aspire DPO (as defined below) in writing of your decision to reject this Policy. Your rejection of this Policy or withdrawal of your consent to the collection, processing, use and/or disclosure of your Personal Data (as defined below) may affect the Services which Aspire is able to provide to you.
For the purpose of this Policy:
“Aspire DPO” shall mean the Aspire data protection officer, being the Head of Compliance. She can be reached at the following address:
Aspire FT Pte. Ltd.
1 Syed Alwi Road, #04-04
“Aspire Group” means Aspire and its related corporations, including any of Aspire’s subsidiaries, Aspire’s holding company and its subsidiaries (in each case wheresoever situate).
“PDPA” means the Personal Data Protection Act 2012 (as amended from time to time).
“Services” means the services that we, our related entities, partners and/or vendors may provide to you on the Platform.
From time to time, Aspire may collect data which enables a natural person to be identified ("Personal Data"). Some examples of Personal Data are:
a) personal particulars (e.g. name, contact details, address, date of birth, identity card/passport details)
b) images and biometrics (e.g. voice and video recordings of you, including our conversations with you for verification or other purposes)
c) employment details (e.g. occupation, directorship, share ownership)
d) your personal opinions made known to us (for example, through feedback or surveys).
e) information relating to your activities, habits, preferences and interests arising from your use of the Platform and the products and services of Aspire Group, our partners or vendors; and/or
f) other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.
2. PERSONAL DATA PROVIDED TO ASPIRE
a) Where you provide Personal Data to us, you represent and warrant to us that (i) the relevant individual has been notified of the purposes for which the data will be collected, processed, used and disclosed; and (ii) you have obtained the relevant individual's consent for the collection, processing, use and disclosure of such Personal Data by Aspire, and have been duly authorised by the relevant individual to provide the Personal Data to us.
b) You must promptly inform us upon you 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 Personal Data provided to Aspire. The withdrawal of such consent may affect the Services which Aspire is able to provide to you.
c) Any consent given in relation to Personal Data provided to us shall, subject to applicable laws and regulations, survive the 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.
3. USE OF PERSONAL DATA
a) We may use your Personal Data for our business purposes, such as:
i. to develop, improve and provide payments facilities, products or services (whether made available by us or through us), including but not limited to
1. executing payments, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions;
2. carrying out research, planning and statistical analysis; and
3. analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customisation strategies;
ii. assessing and processing applications, instructions or requests from you;
iii. communicating with you, including providing you with updates on changes to products, services and payments facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and payments facilities and their terms and conditions;
iv. managing our infrastructure, business operations and complying with internal policies and procedures;
v. responding to queries, complaints or feedback;
vi. addressing or investigating any complaints, claims or disputes;
vii. verifying your identity for the purposes of providing payments facilities, products or services;
viii. conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
ix. complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
x. monitoring products and services provided by or made available through us;
xi. complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
xii. creating and maintaining credit and risk related models;
xiii. financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
xiv. enabling any actual or proposed assignee or transferee, participant or sub-participant of Aspire’s rights or obligations to evaluate any proposed transaction;
xv. in connection with any sale, acquisition, merger or restructuring of Aspire's business;
xvi. for the marketing of products and services ancillary or related to the use of the Platform;
xvii. to detect, prevent and investigate fraud;
xviii. enforcing obligations owed to us;
xix. in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or
xx. administering benefits or entitlements in connection with our relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. This will include the administration of loyalty, rewards programmes, lucky draws, and/or sending gifts and awards.
b) In addition to the above purposes, we may also use Personal Data for purposes set out in the terms and conditions that govern our relationship with you.
4. DISCLOSURE AND SHARING OF PERSONAL DATA
a. Aspire may from time to time also disclose Personal Data to other members of the Aspire Group and third parties such as the following (whether inside or outside of Singapore) in order to carry out the purposes set out above:
i. regulatory authorities, courts, dispute resolution tribunals, and governmental agencies;
ii. any agent, affiliate, business partner, supplier, vendor and sub-contractor which provides products and services to Aspire in connection with the Platform and Services (for example, vendors who we engage to perform fraud detection and monitoring, payment intermediaries who we work with to provide payments services, and card issuers who we work with to offer you debit cards);
iii. any actual or proposed assignee of Aspire or transferee of Aspire's rights in respect of all or any part of the assets, properties or business of Aspire;
iv. any credit bureau as well as the members of such credit bureau (for example, banks, financial intermediaries, payment intermediaries, card network members and insurers);
v. financial institutions and other business partners with whom Aspire jointly offers or develops Services (but they may not use your Personal Data to independently market their own products or services to you unless you consent that they can do so); and
vi. analytics and search engine providers that assist us in the improvement and optimisation of the Platform.
b. We wish to emphasise that Aspire does not sell Personal Data to any third parties.
c. We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and any other applicable data protection laws.
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, you may receive important service information that we believe is critical to your use of the Platform and the Services. In such exceptional circumstances, such information will be sent to you regardless of your preferences.
6. OTHER WEBSITES
b. If you wish to deny the use and saving of cookies from the Platform on to your computers and/or other electronic devices, you should take the necessary steps within your internet browsers’ security settings to block all cookies from the Platform. You can choose to delete the cookies at any time. However, do note that when you enable blocking of cookies, it may limit certain features and functions in your use of our websites or mobile application.
8. RETENTION OF PERSONAL DATA
a. Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.
b. Without prejudice to the foregoing, in the event the Customer terminates its relationship with us, we may retain the Personal Data provided to us for so long as we may deem reasonably necessary for our business or audit purposes or to comply with applicable regulations, guidelines and directives.
9. ACCESS AND CORRECTION
a. You may access or, where applicable, 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 may, in its sole and absolute discretion, deem appropriate for the grant of such access and to correct any such Personal Data.
10. AMENDMENTS AND UPDATES
We may amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way Aspire uses your personal data or any changes to the laws and regulations applicable to Aspire. We will make available the updated policy on our website (https://aspireapp.com/privacy-policy). All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.
a. In the event of a breach of security in respect of Personal Data and to the extent required by the PDPA, we will as soon as reasonably practicable provide notice of such breach to the relevant individual, setting out the extent of the breach, the affected Personal Data and any steps taken by Aspire to remedy and limit the consequences of the breach.
b. Nothing in this Policy shall be construed as Aspire providing an indemnity to any Customer in relation to any Personal Data or use thereof. To the extent permitted by applicable law, Aspire expressly excludes liability or any losses which the Customer may suffer on account of Aspire’s collection, storage, use, transfer or retention of Personal 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, partners, vendors or service providers.
12. CONTACT US
To contact us on any aspect of this Policy or your Personal Data or to provide any feedback that you may have, please contact the Aspire DPO at the address mentioned above.