Personal Data Protection Policy

Your privacy matters, and we at Jewel Paymentech Pte Ltd ("Jewel", "we", "us" or "our", as the case may be) respect that. "You” may be a visitor to one of our websites, a user of one or more of our products and services, or a customer of our user. We treat your personal data with the utmost care and adopt strict practices to protect your privacy. This personal data protection policy (this "Policy") shall define the way we carry out our commitment to your privacy. This Policy defines "personal data" as any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access. Should you have any enquiry relating to your personal data, you can write to us at [email protected].

General Information
1. This Policy aims to explain how we collect, use, disclose and/or process personal data.
2. Jewel is dedicated to properly managing, protecting and processing your personal data in accordance with our responsibilities under the Personal Data Protection Act 2012 ("PDPA").
3. By interacting with us, submitting information to us and/or subscribing to or otherwise using any products and services offered by us, you agree and consent to us collecting, using, disclosing and sharing with our authorised service providers and relevant third parties your personal data in accordance with this Policy and the PDPA.
4. Please note that different or separate data protection policies may apply to specific products and services provided by us.
Collection of Personal Data
1. Depending on the service or product being provided, we may collect data in relation to, without limitation
  1. Your identity, including contact information such as names, identification numbers, telephone numbers, passport numbers, IP addresses and email addresses;
  2. Your interactions with us via our products or services or otherwise, including payment details, credit history, credit card numbers, the date, time and duration of activities made through our products or services, and any other records you have had with us;
  3. Information from other organisations which we believe you have authorised to provide your personal details on your behalf, including fraud protection agencies, credit reference agencies, business directories or other individuals; and
  4. Any other data reasonably related to the above.
2. In relation to your personal data, you warrant and represent that the personal data you disclose is accurate and complete.
3. Consent for the collection, use or disclosure of personal data can be given by any person validly acting on behalf of the individual whose personal data is concerned. If you provide us with personal data relating to a third party by submitting such personal data to us, you warrant and represent to us that you have obtained the consent of the third party and are authorised by the third party to do so. You also warrant and represent that such personal data is accurate and complete.
4. You may withdraw your consent at any time after giving reasonable notice by submitting your request to [email protected]. Following the withdrawal of your consent, we shall no longer collect, use or disclose your personal data unless consent is again obtained or as authorised under the PDPA. The withdrawal of your consent may however result in certain consequences. In certain cases, we may not be able to provide you with our products or services, or a part thereof.
Purposes of Collection, Use and Disclosure of Personal Data
1. The purpose of personal data being collected, used and disclosed by us may vary according to the products or services you subscribe to. This includes:
  1. To provide the relevant products and services;
  2. To manage subscription to products and services;
  3. To manage, develop and improve the products and services provided, including to respond and deal with enquiries or complaints;
  4. To carry out market research and customer surveys;
  5. To conduct investigations or take action, including in relation to any violation of our terms and conditions for products and services;
  6. To provide to third parties who perform services on our behalf, but only to the extent necessary for the services to be performed;
  7. To meet legal and regulatory requirements imposed by the applicable public authorities, laws or regulations; and
  8. For any other purposes which are necessary, ancillary or consequential to the above.
2. Your personal data may be disclosed for the purposes indicated above to our customers as may be necessary to benefit from the products and services, officers and employees, third parties, service providers, advisors, any data intermediaries, and any other party to whom you authorise us to disclose your personal data to.
3. Except as otherwise provide for in this Policy or such other agreement entered between you and us, we will not share your personal data with other parties without your consent, unless required by law.
Deemed Consent
1. You are deemed to have given your consent for the collection, use and disclosure of your personal data in the following circumstances:
  1. When you voluntarily provide your personal data to us;
  2. When you are aware of the purpose for which you provide your personal data to us;
  3. It is reasonable for you to have provided your personal data to us in the circumstances; and
  4. In any other circumstances where consent is deemed under the PDPA.
Limitations to Collection, Use or Disclosure of Personal Data
1. We shall only collect, use or disclose your personal data to the extent necessary for the purposes described under this Policy and to the extent allowed under the PDPA.
Third Party Products and Services
1. Products and services offered by us may include third party products, services and links to third party websites.
2. Such third party products, services and websites are not covered by this Policy, and may collect your personal data. You are strongly encouraged to read such third party’s privacy policy.
3. We are not responsible for how such third parties use any collected personal data.
Complaints Procedure
1. We welcome any feedback or complaints as to our compliance with the PDPA, or how your personal data is being handled. Please contact [email protected] with any complaints or feedback you may have. Indicating that your correspondence is in relation to the PDPA would enable us to respond promptly.
Accessing and/or Correcting Personal Data
1. To the extent required by the PDPA, we will use reasonable efforts to ensure that the personal data we retain is sufficiently accurate and complete. We, however, are entitled in our absolute discretion to assume the accuracy and completeness of the personal data we retain to the extent allowed under the PDPA.
2. We encourage you to inform us when there are any changes to personal data which you have provided to us so as to ensure that we have the most current, accurate and complete personal data relating to you. You may request access and/or corrections to the personal data currently in our possession or control by [email protected]. We may require sufficient information to ascertain your identity and the nature of your request.
3. If your request for correction is accepted, subject to your consent, we may send the corrected personal data to other organisations to which the personal data was disclosed by us within a year before the date the correction was made, unless, in our opinion and in our absolute discretion, that other organisation does not need the corrected personal data for any legal or business purpose.
4. Please note that we reserve the right not to accept any requests for access and/or correction of personal data to the extent allowed under the PDPA.
Protecting Your Information
1. We aim to treat your personal data with the utmost care and diligence. For this reason, to the extent required by the PDPA, we have implemented measures to secure and protect your information, including:
  1. Reasonable security arrangements preventing unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks to personal data.
  2. Security precautions safeguarding all electronic storage and ransmission of personal data
Retention of Personal Data
1. We shall collect and retain personal data in accordance with this Policy for as long as it is necessary, required, or relevant for business or legal purposes.
Transfer of Personal Data outside Singapore
1. If necessary, we shall only transfer personal data outside Singapore in accordance with the requirements under the PDPA.
2. Due to the nature of the services we provide, personal data may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer personal data outside Singapore which may have data protection rules that are different from those of Singapore. However, we will take measures to ensure that any such transfers comply with the PDPA and the personal data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access the personal data.
Jewel as Data Intermediary
1. We may collect, use and disclose your personal data when acting as our customer's data intermediary (as defined under the PDPA). Our customers are responsible for making sure that the requirements under the PDPA are complied with, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as our customer's data intermediary, we will process personal data in accordance with the terms of our agreement with our customer and our customer's lawful instructions.
Updates to this Policy
1. We strive to ensure compliance with relevant laws and regulations, as well as maintaining up-to-date-practices regarding the management, protection and processing of your personal data. As such, we reserve the right to amend the terms of this Policy at our absolute discretion. To the fullest extent permissible under the law, you agree to be bound by the prevailing terms of this Policy.
2. Any amended Policy will be posted on our website. You are encouraged to visit our website regularly to ensure you are familiar with our latest personal data policies.
3. Except as specified under the relevant laws and regulations, we cannot be held responsible for the acts, omissions, data policies or use of cookies by a third party, nor the content or security of any third party websites (even if linked to our websites). Any such liability is expressly disclaimed and excluded to the extent permitted under the law.
Governing Law
1. This Policy is governed by the laws of Singapore.