Last updated 23 February 2024
The purpose of this Privacy Policy is to inform you of how Poss Capital and its subsidiaries (collectively referred to herein as, “Poss Group”, “us”, “we” or “our”) manage your personal data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“Act”) insofar as your personal data is collected, used or disclosed.
This Privacy Policy applies to any individual whose personal data is in our possession or under our control (collectively “you”, “your” or “yours”).
By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Poss Group, as well as our respective representatives and/or agents collecting, using and disclosing your personal data in the manner set forth in this Privacy Policy.
Poss Group may update this Privacy Policy from time to time to ensure that it is in line with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Subject to your legal rights, you hereby agree and acknowledge to be bound by the prevailing terms of the Privacy Policy, as updated from time to time on our website.
Please check back frequently for up-to-date information on how your Personal Data is handled.
The personal data we collect and hold
In this Privacy Policy, “personal data” refers to any data, whether true or false, concerning an individual 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, including data in our records that may be updated from time to time.
We may obtain your Personal Data directly or indirectly from you whenever it is reasonable and practical to do so. We occasionally obtain personal information from other sources, such as public sources, related companies, referrers, brokers, agents, your adviser(s), and our service providers, which include credit reporting agencies and data service providers.
The Personal Data we collect and hold about you include but is not limited to the following:
- personal particulars (e.g. name, government-issued identification numbers, contact details, residential address, date of birth, gender, nationality, race, marital status);
- biometric data (e.g. facial image, fingerprint, voice);
- employment information (e.g. occupation, employment history, salary);
- financial, tax, insurance, investments, business interests or banking information (e.g. bank account numbers and transactions); or
- information relating to your preferences, activities, habits, interests or feedback relating to the use of our products or services and/or that of our business partners, including electronic data such as IP addresses, cookies, activity logs, cellular network and location data.
Some of the Personal Data that we collect may be sensitive in nature. This includes your government-issued identification number, financial information or bank account information. We collect this information in strict compliance with applicable laws.
We also collect Personal Data from individuals who submit applications or register interest for employment with Poss Group.
If you submit any Personal Data related to a third party to us, such as the contact details of your clients, spouse, kids, parents, and/or staff, you are acknowledging to us that you have obtain their consent to use their information for the indicated purposes.
You should ensure that all Personal Data you provide to us is complete, accurate, true, and correct. Failure to do so may prevent us from providing you with the products and services that you have requested.
Purposes for the collection, use and disclosure of your personal data
We may collect, use, process or disclose Personal Data for business or legal purposes, including as permitted under the Act and other applicable laws for the following purposes (“Purposes”):
- verifying your identity and conducting screenings, credit or due diligence checks in order to provide you with our products or services;
- ensuring that the information we have about you is up-to-date;
- assessing and processing applications, instructions, transactions or requests, including your registration of interest, and assessing your eligibility for our products or services;
- providing you with information and updates relating to the products, services and banking facilities you have signed up for, their terms and conditions, and our Privacy Policy;
- administering benefits or entitlements in connection with our relationship with you or arising from your interaction or participation in events, marketing campaigns and promotions by us or in conjunction with our partners (e.g. loyalty, rewards, lucky draws, gifts and awards);
- responding to queries, feedback or requests;
- addressing, investigating or resolving any complaints, claims, disputes, breaches of law or contract;
- developing our customer acquisition strategies;
- monitoring how well we are meeting our performance and service delivery;
- complying with our internal policies and procedures;
- conducting research and analysis to understand customer needs and preferences, for developing or improving our products or services, security, and marketing strategies;
- requesting feedback or participation in surveys or conducting research and/or analysis for statistical or profiling to understand market trends, customer behaviour and preferences;
- managing the safety and security of our staff, premises and services;
- responding to an emergency that threatens the life, health or safety of a person;
- where it is necessary in the public interest (e.g. for contact tracing purposes, managing a public health crisis);
- preventing, detecting, investigating and prosecuting crime (including fraud, money-laundering and terrorist financing);
- monitoring compliance with our terms and conditions, policies and code of conduct;
- recovery or payment of debt owed;
- financial or regulatory reporting, management reporting, risk management (including monitoring credit exposures, audit and record keeping purposes);
- facilitating mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company;
- exercising our rights to defend ourselves from any claims, actions, investigation or proceedings and/or protecting and enforcing our contractual and legal rights and obligations;
- complying with any applicable laws, regulations, rules, directives, codes of practice or guidelines, orders, instructions and requests from any local or foreign authorities, including regulatory, government, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations;
- such purposes as you may agree to from time to time; and
- purposes related directly to the Purposes set out in this Policy.
We may collect, use, process or disclose your Personal Data without consent where required or authorised under the Act and other applicable laws, in accordance with their requirements.
Disclosure of personal data
We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the Purposes (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
- related bodies corporate of Poss Group;
- service providers who provide services including but not limited to archival, auditing, finance, customer contact, legal, risk management, business consulting, banking, payment, delivery, data collection and processing, data analysis, information broking, mailing, marketing, research, investigation, insurance, identity verification, brokerage, maintenance, trustee, securitisation, website and technology services;
- your nominated financial adviser with your permission;
- our professional advisers such as our auditors and lawyers;
- credit reporting agencies;
- relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, and the Insolvency and Public Trustee Office, to comply with any directions, laws, rules, guidelines, regulations.
Use of Cookies and Related Technologies
When you visit Poss Group websites you will browse anonymously unless you have logged into a client portal or accessed the website from a personalised communication from Poss Group.
For all visitors to our web site, we use cookies to collect anonymous information such as the server your computer is logged on to, your browser type (for example, Internet Explorer, Chrome or Firefox), and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address.
Once you have logged into a Poss Group websites, accessed our websites from an e-mail or other personalised communication sent to you or provided us with Personal Data by completing a form online, we may be able to identify you. If we have identified you, we may be able to link your identity to your previous anonymous browsing history and collect information about your possible future use of our websites, irrespective of how you access our sites (eg by clicking a link in an advertisement or from a third party website).
In addition, we may combine that information about your use of Poss Group websites with certain other online and offline information we have about you in order to tailor your online experience and provide you with further information.
If you would prefer not to be identified you can delete the cookies and reconfigure the cookie preferences on your internet browser.
If you disable the use of cookies on your web browser or remove or reject specific cookies from Poss Group websites or linked sites then you may not be able to gain access to all of the content and facilities on those websites.
Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
If you:
- have any questions or feedback relating to your Personal Data or our Privacy Policy;
- would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
- would like to obtain access and make corrections to your Personal Data records.
Please direct your enquiry to contact@poss.sg.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Poss Group may not be in a position to continue to provide its products or services to you, administer any contractual relationship in place, may also result in the termination of any agreements you have entered into with Poss Group, and your being in breach of your contractual obligations or undertakings, and Poss Group’s legal rights and remedies in such event are expressly reserved.
Governing Law
This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.
