PRIVACY POLICY DEFINITIONS

The terms ‘We’, ‘Our’ and ‘Us’ refers to 1st Alliance Solutions Pte. Ltd. and its related companies. ‘You’ and ‘Your’ refers to our customers, prospective customers and to users of our websites in general.

When using the term ‘Personal Information’ we refer to any ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable’:

  • whether the information or opinion is true or not; and
  • whether the information or opinion is recorded in a material form or not

‘Credit Information’, as well as ‘Sensitive Information’ are subsets of personal information and are therefore included in the term personal information when applied.

When using the term ‘Credit Information’ we refer to data which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history regarding these loans or any non-compliance. Usually the credit information is exchanged between the credit reporting bodies and the credit and finance providers.

‘Sensitive Information’ refers to information or an opinion about an individual’s:

  • gender
  • nationality, racial or ethnic origin
  • religious, political and/or philosophical beliefs or affiliations
  • sexual orientation or practices
  • membership of a professional or trade association, a political association or a trade union
  • criminal record
  • health information
  • genetic information that is not otherwise health information
  • biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates

OUR COMMITMENT

We understand that the privacy of your personal information is very important and we are committed to ensure it. The Personal Data Protection Act sets minimum standards for how private sector organisations such as ours have to collect, use, disclose, store, correct and provide access to personal information.

CURRENCY AND STATUS OF OUR PRIVACY POLICY

Our privacy policy is current as of and from 1st Jan 2020. Please read it thoroughly and visit our website regularly for any changes in our privacy policy. All privacy policy changes will be updated and posted on our websites.

By visiting our website, providing us with your personal information, applying for, renewing or using any of our products or services, you agree to your personal information being collected, stored, used and disclosed as stated in this privacy policy.

During the progression of our relationship with you, we may update or provide you with further information about how we handle your personal information. If you receive further information, please consider it carefully.

TYPES OF PERSONAL INFORMATION WE COLLECT

General information we require and store include your name, identification numbers such as nric, fin, work permit and birth certificate, date of birth, gender, contact details (address, phone and fax number, e-mail) and payment details.

Depending on the products and services we offer or you use or apply for, we may require different and/or additional personal information and details from you. Additional information we typically require refers to information that is specific to a particular product. Such personal information can include information about other people such as co-borrowers, your spouse, partner or children.

WHY WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information to provide and manage our products and services, or otherwise as permitted by law. In order to being able to respond to your enquiries, process your survey or questionnaire responses, provide you with assistance, maintain and manage our products and services (e.g. applications for a home loan, process requests for information, undertake pre-qualifications and preliminary credit assessments, collection of supporting materials, communicate approvals, other directions from the lender and send you reminder before expiry of lock-in period of your existing loan), quality assurance and training purposes, market research and the collection of general statistical information using common technologies such as cookies, provide you with marketing information regarding other products and services (of ours or a third party), perform administrative operations (including accounting and risk management) and any other purpose identified at the time of the collection of your personal information.

Sensitive information will only be collected when it is relevant for the approval of an application for a home loan. We may use or disclose it by giving it to related companies or your lender. Your sensitive information will not be used or disclosed for any other purpose unless you have granted your permission.

We, as well as third party marketing service providers, may combine and link the personal information we collect to other previously collected information about you, in order to provide you with more relevant and tailored advertising about our or their products and services. Third parties are prohibited from using your personal information for purposes other than those for which it is supplied.

If you do not consent to us collecting, using or disclosing all or some of the personal information we request, we may not be able to offer our products or services to you, such as attending to your application for a home loan. It may also prevent the provision of information regarding our products or services or those of any third party.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We may collect your personal information in different ways and at various stages via telephone (including any form of mobile phone text messaging), our website, hard copy forms or e-mail.

We collect your personal information directly from you. There may however be occasions where we collect your personal information from other sources. These other sources may include:

  • our authorised representatives
  • our legal or other advisers
  • our service providers
  • our business partners and affiliates, related companies, agents, distributors or referrers
  • joint-applicants or others who are authorised or noted on the home loan application as having a legal interest in it
  • family members or anyone you have authorised to deal with us on your behalf
  • third parties for the purposes of assessing your application for a home loan or other services including identity verification providers, credit reporting bodies, insolvency checking authorities and criminal history
  • publicly available sources of information
  • social media and other virtual networks and communities where people create, exchange or share information
  • clubs, associations, member loyalty or rewards program providers and other relevant organisations
  • analytic consultants, data partners and other similar organisations
  • any other person or organisation that you have consented to them providing your personal information to us or consented to us obtaining personal information from them

If you provide personal information to us about any other person, we confide in you to have made or make them aware that you will, or may, provide their information to us and the types of third parties we may provide it to, the relevant purposes we and any of the third parties will use it for and how they can access it. Regarding the provision of sensitive information, we confide in you to have obtained the consent on these matters of the persons in question. If you have not done, or will not do, either of these things, you are obliged to tell us before providing said personal information.

A number of interactive tools or functions may be available on our websites. If you use any of these tools or functions, we generally do not collect your personal information unless the tool permits you to save or suspend your information and recover this information again at a later time. In this case your personal information may be retained in our systems but will not processed or used by us except that it may be used for the purposes of a subsequent follow up or online quoting.

During the progression of our relationship with you, we may ask you for personal information through competitions or surveys. Participating in these competitions or surveys is completely voluntary and you therefore have the choice of whether or not you disclose the personal information being asked. The personal information we may collect through competitions is used to determine, notify and award prize winners. Personal information that may be collected through surveys or questionnaires is used to evaluate your satisfaction with our products and services and to determine how we may be able to improve.

ANONYMITY AND PSEUDONYMS

Provided the employment of our products and services do not require otherwise, you have the possibility to interact with us anonymously or by the use of a pseudonym. The usage of our websites and some other online facilities may under these circumstances not require the revelation of your personal information.

COOKIES AND COLLECTION OF INFORMATION THROUGH OUR WEBSITE

Cookies are messages by a web server to a web browser. The information is stored in a text file by the browser. Each time the browser requests a page from the server the identification of the user’s computer address (IP address) is enabled through the message. We may use such cookies that collect anonymous traffic data.

The information provided by these cookies and the computer address may be used to manage our website, analyse trends, or for research and marketing purposes to help us improve our products and services. No information which personally identifies you will be collected as part of these cookies or the comprised information. You can set your browser settings to notify you before you receive a cookie as to manually accept it and set your browser to turn off cookies.

We may also collect your personal information through the use of online forms. Some forms are provided by third parties that may have access to your personal information but will only disclose that information to us in accordance with their privacy policy, or as they are lawfully required.

DIRECT MARKETING

We may use your personal information to supply you with information about our products and services or those of our business partners, distributors, affiliates, referrers, agents and any proposed new or incoming insurer may offer. If you do not wish to receive any of this information you can contact us at any time.

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We may collect personal information from or share this information with our related companies and other third parties who provide services to us or on our behalf.

We may collect or share your personal information with other third parties or any unrelated party under the following circumstances:

  • in agreement with our privacy policy
  • if we are authorised, required or permitted by law to use or disclose information
  • as supplied in any collection notice we give you
  • if a product or a service you apply for is provided or supplied by or through a third party
  • if a third party, such as a mailing house, carries out activities on our behalf
  • if a third party is interested in our products or services, for example an insurer, a business partner, a distributor, a mortgagee, a referral agent, a third-party beneficiary, an insurance intermediary or an affiliate
  • if a third party acquires, or considers acquiring, an interest in us
  • if a disclosure is required for the purpose of conducting business analysis in order to improve our products and services
  • if a disclosure is otherwise required in order to supply you with a particular product or service
  • in order to assure our ability to continue supplying products and services
  • if a disclosure is required by law or requested by statutory, regulatory or ombudsman authorities or law enforcement agency
  • if you have given your consent (which may be provided expressly or may reasonably be implicated by your conduct or our existing business relationship)
  • to our professional advisors including our accountants, auditors and lawyers, contracted advisors and service providers
  • if it is necessary for a third party to assist us in providing our services, for example, credit reporting bodies, identity verification providers, criminal history and insolvency checking authorities, and others involved in the providing of services relating to your application for a home loan
  • for purposes related to planning, research (including market research), security, service development, testing and risk management

It is improbable that your personal information is to be disclosed to any entity located overseas. Related or unrelated third parties to whom your personal information is disclosed are required to keep the information confidential and are only to use it for the same purposes as we are permitted to use it.

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 collecting, 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 to our Data Protection Officer at the contact details provided below.

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. In general, we shall seek to process your request within ten (10) business days of receiving it.

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 in writing in the manner described in clause above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

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 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

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS 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.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Name of DPO Alvin Neo
Contact No. 62815778
Email Address info@1st-alliance.com

SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate our service (‘Service Providers’), to provide the service on our behalf, to perform service-related services or to assist us in analysing how our services are used.

These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

ANALYTICS

We may use third party service providers to monitor and analyse the use of our services.

  • Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our services. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt out of having made your activity on the service available to Google Analytics by installing the Google Analytics opt out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

LINKS TO OTHER SITES

Our services may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

CHILDREN PRIVACY       

Our services do not address anyone under the age of 18 (‘children’).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your children have provided us with personal data, please contact us. If we become aware of that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

WARRANTY

We provide the services ‘as is’, ‘with all faults’ and ‘as available’, and the entire risk as to satisfactory quality, performance, accuracy, and effort is with you. To the maximum extent permitted by applicable law, we and any of our employees, agents and suppliers make no representations, warranties or conditions, express or implied. We and any of our employees, agents and suppliers expressly disclaim any and all warranties or conditions, express, statutory and implied, including without limitation (a) warranties or conditions of merchantability, fitness for a particular purpose, workmanlike effort, accuracy, title, quiet enjoyment, no encumbrances, no liens and non-infringement, (b) warranties or conditions arising through course of dealing or usage of trade, and (c) warranties or conditions of uninterrupted or error free access or use.

LIABILITY LIMITATTION, EXCLUSIVE REMEDY

To the fullest extent permitted by law in no event will we or any of our employees, agents or suppliers be liable to any party or person for any damages or costs, including without limitation any indirect, consequential, special, incidental, or punitive damages arising out of, based on, or resulting from these terms of use or your use of the site or services, even if such party or person has been advised of the possibility of such damages. These limitations and exclusions apply without regard to whether any damages or costs arise from (a) breach of contract, (b) breach of warranty, (c) negligence, (d) tort, or (e) any other cause of action, to the extent such exclusion and limitations are not prohibited by applicable law. If you do not agree with any part of these terms of use, or you have any dispute or claim against us or any of our employees, agents or suppliers with respect to these terms of use or the services, then your sole and exclusive remedy is to discontinue using the services.

INDEMNITY

You agree to indemnify and hold us and each of our directors, officers, agents, contractors, partners and employees, harmless from and against any loss, liability, claim, demand, damages, costs and expenses, including reasonable attorney’s fees, arising out of or in connection with any user content, any third party applications, software or submission you post or share on or through the site, your use of the service or the site, your conduct in connection with the service or the site or with other users of the service or the site, or any violation of these terms of use or of any law or the rights of any third party, including without limitation any action(s) or claims(s) against us on account of any user content or submission being or containing material that infringes the intellectual property of a third party.

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    :               01/01/2020

Last updated      :               20/07/2020