INCOMLEND CAPITAL PTE LTD (“We” or “ICPL”) are committed to protecting and respecting your privacy.
This policy is based on the following data principles:
The processing of Personal Data shall take place in a lawful, fair, and transparent way;
The collection of Personal Data shall only be performed for necessary legitimate purposes and not further processed in a manner that is incompatible with those purposes;
The collection of Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purpose for which they are processed;
The personal data shall be accurate as far as possible and where necessary, kept up to date;
Every reasonable step shall be taken to ensure that personal data that are inaccurate having regard to the purposes for which they are processed are erased or rectified without delay;
Personal Data shall be kept in a form which permits identification of the data subject for no longer than it is necessary for the purpose for which the personal data are processed;
All Personal Data shall be kept confidential and stored in a manner that ensures appropriate security;
Personal Data shall not be shared with third parties except when necessary in order for them to provide services upon agreement and such consent has been obtained;
Data subjects shall have the right to request access to and rectification or erasure of personal data, or restriction of processing, or to object to processing as well as the right of data portability.
- THE INFORMATION WE COLLECT
For the purposes outlined in this clause, we may collect and process the following information about you:
2.1 We collect your personal data upon the submission of any information by you – Information that you provide by filling in forms in order to use the services of ICPL (including names, identification particulars, date of birth, contact details, and other relevant personal information). This includes information provided at the time of registering to use the Platform, subscribing to our service, posting material, or requesting further services. We may also ask you for information at other times, for example, in connection with a promotion or when you report a problem with the Platform;
2.2 We collect your personal data about you – information automatically collected when you visit our website, for example:
- Technical information, including the Internet protocol (IP) address used to connectyour computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.The information is collected anonymously;
- Information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs);
- The record of the correspondence obtained from you;
- Details of transactions you carry out through our site and of the fulfilment of your orders;
- Details of your visits to our site and the resources that you access;
- Answers to questions intended for security verification;
- Emergency contact numbers or call back contact details; and
- Other Personal Data in the meaning given in the PDPA.
2.3 Not all the Personal Data we hold about you will come always directly from you. We may also collect information from third parties:
- Other parties related to the financing transaction (including the Buyer/Supplier to the account receivable uploaded onto the Platform for funding);
- Third parties, including relevant individuals (as defined below); and/or
- Publicly available sources including credit bureaus personal data about you and other related parties, including but not limited to beneficial owners, partners, directors, officers or authorized signatories, employees, customers, payers, payees, guarantors, other security providers and other natural persons related to you (collectively, “Relevant Individuals”). ICPL will be free to use, collect and disclose information that is available in the public domain without your consent.
2.4 Information and data may also be generated in the ordinary course of the relationship with ICPL for example, through the use of an account on the Platform.
- HOW WE WILL USE YOUR PERSONAL INFORMATION
3.1 We will process your Personal Information in accordance with the PDPA to provide you with the Services. Information and data may be used and disclosed inside or outside Singapore for the following purposes:
- To confirm your identity and ensure your eligibility as a user of ICPL’s services, as well as to conduct due diligence checks in accordance with all applicable laws and internal policies;
- To administer your account with ICPL and provide services to you including but not limited to the facilitating of funds for you, maintaining accurate “know your customer” information, to verify the identities or authorities of you and/or your representatives who contact ICPL or may be contacted by ICPL, and to carry out or respond to requests, questions or instructions from you and/or your representatives;
- To comply with this Terms and any other terms and conditions as may be stipulated by ICPL from time to time and at any time;
- To carry out our obligations arising from any agreements entered into between you and us;
- Facilitate your participation in our services when you choose to do so;
- In legal proceedings, including collecting overdue amounts and seeking professional advices;
- To send you marketing material that you have agreed to receive, including but not limited to newsletters sent by us via email, information sent by us about ICPL’s products and Services, including updates on our latest promotions and new products and Services, via fax, email, direct mail, telephone and other means of communication;
- To comply with the applicable laws and regulations in or outside Singapore;
- To detect, prevent and investigate fraud;
- Other purposes directly related or incidental to the above; and
- Purposes that a reasonable person would consider appropriate in the circumstances.
3.2 If at any time you wish for us to stop processing your Personal Data for the above purposes, to update your information with us, or to unsubscribe from any promotional material, kindly contact our Data Protection Officer at email@example.com and we will take the appropriate steps to stop doing so. Please note that this may mean that your Account will be closed and/or ICPL may not be able to continue providing its Services to you. 3.3 To ensure a good quality of service we may monitor any communication you have with us whether in writing or by electronic mail (“recordings”) or any inbound and outbound calls done by any member of the ICPL team. Any recordings remain the property of ICPL and will be used only for the purposes listed above. 3.4 In the event that the purposes for processing change, then we will notify you as soon as practicable and seek any additional consent that may be required.
- DISCLOSING YOUR PERSONAL INFORMATION
4.1 Except as described in this Policy, we will not intentionally disclose the Personal Data that we collect or store on the Service to third parties without your prior explicit consent. We may disclose information to third parties in the following circumstances:
- Any agent, contractor, or third party services provider who provides services to ICPL in connection with the business operations of ICPL;
- Any person or entity working for us or is a part of ICPL’s group companies and is under a duty of confidentiality to the disclosing ICPL entity;
- Any person or entity to whom ICPL 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;
- Any actual or proposed assignee of ICPL or transferee of ICPL’s rights in respect of you, or all or any part of the assets or business of ICPL;
- Any credit bureau as well as the members of such credit bureau for the purpose of preparing credit reports, or in a credit report provided by a credit bureau to a member of the credit bureau in relation to a transaction that you wish to undertake.
4.2 We will disclose your personal information if we are under a duty to disclose or share your personal data and transaction data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of ICPL, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- YOUR RIGHTS
5.1 We respect your privacy rights and provide you with reasonable access to the Personal Data that you may have provided through your use of the Services. Your principal rights are as follows:
- the right for information whether we hold personal data about you
- the right to access any personal data You have the right to request Incomlend for copies of your personal data. We may charge you a small fee for this service
- the right to request correction of the personal data This enables you to have any incomplete or inaccurate information we hold about you corrected;
- the right to request erasure of your personal data If you are within the EU, this enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it and where you have exercised your right to object to processing (see below).
- the right to object processing If you are within the EU, you have the right to object to ICPL’s processing of your personal data, under certain conditions. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
- the right to restrict processing If you are within the EU, you have the right to request that ICPL restricts the processing of your personal data, under certain conditions.
- the right to request data portability This If you are within the EU, you have the right to request that ICPL transfers the data that we have collected to another organization, or directly to you, under certain conditions;
- the right to complain to a supervisory authority; and
- the right to withdraw your consent
5.3 You may update, correct, or delete your Account information and preferences at any time by accessing your Account. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
5.4 You may decline to share certain Personal Data with us, in which case we may not be able to provide to you some or all of the features and functionality of the Service.
5.5 At any time, you may object to the processing or retention of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.
5.6 In accordance with Applicable Law, we reserve the right to withhold personal data if disclosing it would adversely affect the rights and freedoms of others. Moreover, we reserve the right to charge a fee for complying with such requests if they are deemed manifestly unfounded or excessive. ICPL may charge a reasonable administrative-cost fee if further copies are requested.
5.7 Please allow ICPL the processing time of up to one month if any requests in relation to your Personal Data are made.
- TIME LIMIT FOR KEEPING PERSONAL DATA
We will keep your personal data for as long as it is necessary for the purposes mentioned in Clause 5 or according to the applicable laws and regulations.
7.1 All information you provide to us is stored on our secure servers.
7.2 Any payment transactions or transmission of personal information will be encrypted using Secure Sockets Layer (SSL) software. We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.
7.3 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.4 We restrict access to personal information to our employees, service providers, and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
7.5 We review our information collection, storage, and processing practices from time to time to guard against unauthorised access, processing, or use.
7.6 We take appropriate security measures to protect against loss, misuse, and unauthorized access, alteration, disclosure, or destruction of your information. ICPL has taken steps to ensure the ongoing confidentiality, integrity, availability, and resilience of systems and services processing personal information, and will restore the availability and access to information in a timely manner in the event of a physical or technical incident.
7.7 No method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organisational safeguards. If you believe your Personal Data has been compromised, please contact firstname.lastname@example.org.
7.8 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
- DATA TRANSFERS
- CONTACTING US
Company Registration Number: UEN. 201930137Z
CMS Licence No: CMS101137
Incomlend Capital Pte Ltd
160 Robinson Road