This Data Protection Policy (“Policy”) sets out the basis which Lendingpot.sg and/or IFS Capital Ltd or its related corporations and/or affiliates (“we”, “us”, or “our”, “Lendingpot”) may collect, use, disclose or otherwise process personal data of our clients in accordance with the Personal Data Protection Act (“PDPA”).
“You”, “Borrower”, Small Medium Enterprises (“SMEs”) means users of our Business Loan application service, where a Business Loan Request may be posted in our Business Loan Marketplace.
“Relationship Managers (“RMs”)”, “Lenders” means third party financial institutions and/or its sales representatives, who connect to applicants of the Business Loan Request to provide them with third party Business Loan quotations.
This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
This Policy applies to Lendingpot’s website and all other forums such as digital applications and/or devices on which Lendingpot provides this business loan application service.
- As used in this Policy:
“client” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a client who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and contact information such as your address, email address or telephone number.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use & Disclosure of Personal Data
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and/or (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- sending your marketing information about our goods or services including notifying you of our marketing events and other promotions;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
- We may disclose your personal data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
- to third party service providers or agents such as RMs and other organisations we engage to perform any of the functions listed in clause 5 above for us.
- The third party service providers that we have disclosed your personal data to have been informed not to misuse your data. However, we are expressly excluding our liability as to the inappropriate usage of your data by these third party service providers and agents.
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Withdrawing Your Consent
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us
- Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us this in writing.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
Protection of Personal Data
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data.
- Where the client provides personal data to us, the client shall make reasonable effort to ensure that the personal data is accurate and complete before providing the same to us. Lendingpot shall put in place adequate measures to ensure that the personal data in its possession or control remain or is otherwise accurate and complete. In any case, Lendingpot shall take steps to correct any errors in the personal data, as soon as practicable upon the client’s written request.
Retention of Personal Data.
- Lendingpot shall not retain personal data (or any documents or records containing personal data, electronic or otherwise) for any period of time longer than is necessary.
- Lendingpot shall, upon the request of the client: (a) return to the client, all personal data; or (b) delete all personal data in its possession, and, after returning or deleting all personal data, provide the client with written confirmation that it no longer possesses any personal data. Where applicable, Lendingpot shall also instruct all third parties to whom it has disclosed personal data for the purposes of this Agreement to return to Lendingpot or delete, such personal data.
Transfer of Personal Data Outside of Singapore
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
- We may update, amend, supplement or modify this Policy from time-to-time by posting a new version on our website. We will make available the updated Policy on our Website. All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.
Your rights in respect of your personal data
- You have the right to access, update or correct the personal data we hold about you or withdraw your consent to the use, collection and disclosure of your personal data. If you have any questions about this Policy, or if you wish to access, update or correct your personal data or withdraw your consent to the use, collection and disclosure of your personal data, please email email@example.com. We have the discretion to charge a small fee for this service. Please note that if you withdraw consent, we may still be permitted to hold, use or disclose some of your information as required or permitted by law.
Effect of Notice and Changes to Notice
- This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date: 6 December 2018
Last updated: 6 December 2018