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Privacy Policy

At BetterTradeOff Pte Ltd (“BTO”), we are committed to maintaining the privacy and security of any Personal Data that you provide to us.

Our Privacy Policy describes how we protect your Personal Data when you use our Website, and it is subject to the Personal Data Protection Act 2012 (“PDPA”) of Singapore, any regulations enacted thereunder, and any guidelines that may be issued from time to time by the Personal Data Protection Commission of Singapore.

We will review and update this Privacy Policy from time to time or as required by law.

  1. Purposes for the Collection, Use, and Disclosure of Personal Data
    1. You authorize and give your consent to collect and use your Personal Data for purposes including allowing BTO to:
      1. improve our services to you, enhance service information provided to you, and give guided and relevant updates;
      2. enable your access to privileged areas of our Website;
      3. customize relevant products, services, special offers, and rewards that we think will be of interest to you;
      4. diagnose possible problems with our servers;
      5. optimize our Website delivery;
      6. plan, provision, and bill Advisers for services;
      7. complete market research;
      8. comply with all applicable legal and regulatory requirements;
      9. establish, exercise, or defend any legal or equitable claim; and
      10. conduct any other purpose necessary, ancillary, or consequential to the above specified purposes.
    2. When the need arises for your Personal Data to be collected, used, or disclosed for purposes other than the ones originally consented for, we will obtain your fresh consent in that regard, where necessary, in accordance with the PDPA.
  2. Collection and Use of Personal Data
    1. Generally, BTO collects and/or uses your Personal Data for any of the purposes 1.1(a) to 1.1(i) as listed above.
    2. Personal Data refers to data about an individual who can be identified from that data, including: name(s), mailing address(es), phone number(s), email address(es), service detail(s), payment detail(s), income(s), expense(s), asset(s), debt(s), etc.
    3. We securely partition Personal Data that can identify you as an individual separately from general information records (customer-identifying data vs. non-identifying metadata).
    4. We use “cookies” (a small text file that your browser stores on your device) to develop, optimize, and improve our website; including but not limited to: details of your domain name, Internet Protocol address, operating system, browser version, how long you stayed on a page, the route you took to navigate through the pages, simulation data on our site, and possibly other session-based elements related to your usage of our website.
    5. If Personal Data relating to a third party is provided by you, by submitting such information to us, you represent to us that the consent of that third party has been obtained for the collection, use, and disclosure of the Personal Data for any of the purposes 1.1(a) to 1.1(i) as listed above.
    6. As BTO relies on your Personal Data to provide accurate services to you, you shall ensure that at all times the Personal Data submitted to us is true, accurate, and complete.
  3. Disclosure of Personal Data
    1. BTO may disclose Personal Data to:
      1. carefully-selected third-party service providers who provide operational and administrative support under strict PDPA and non-disclosure agreements;
      2. any relevant authorities;
      3. the extent necessary to comply with any applicable legal and regulatory requirement;
      4. in relation to professional indemnity policies; and
      5. any other party where authorized by you.
  4. Opt-out and External Parties
    1. You may prevent BTO from collecting your Personal Data by discontinuing your access to our Website. You may opt-out and withdraw your consent for BTO to retain your Personal Data by requesting your data to be expunged from our cryptographically-secure records.
    2. To request data removal, please provide written notice and allow reasonable completion time to our Data Protection Officers at Privacy@BetterTradeOff.com to purge your information from our online live-system (data backups are required to be retained, but your Personal Data will be flagged as “Do Not Restore”).
    3. If you no longer wish to receive information about special offers, promotions, or rewards, please let us know by emailing us at Contact@BetterTradeOff.com.
    4. BTO makes a best-effort attempt to screen and approve of any external website link that we include into our Website; however, BTO is not responsible for any external company’s privacy practices or the content of any external web site.
    5. BTO uses external parties to provide secure website access to data, which is also stored on external-party cloud-based servers within the Microsoft Azure security platform (see their website for details). BTO follows best-practices guidelines for provisioning of world-class, high-security services that you would typically access when you use an online banking service. All data records are encrypted in storage as well as being encrypted during transmission according to industry-standards.
    6. You may, if you wish, communicate with BTO on certain general information topics anonymously (where practical), and BTO will make best efforts to be of assistance if you prefer to transact with anonymity.