Privacy Policy

As outlined in this Privacy Policy, Smartkarma and its group companies are committed to maintaining your privacy and the security of personal data provided or collected in the course of User access to and engagement with the Site and any related mobile application (“Mobile App”).

This Privacy Policy has been developed in line with the Personal Data Protection Act 2012 (Singapore) (“PDPA”) and other data protection laws from relevant jurisdictions, including the General Data Protection Regulation (“GDPR”) which comes into effect in the European Union on 25 May 2018.

This Privacy Policy describes in detail how Smartkarma and its group companies may collect, use, disclose, process and manage your personal data. By visiting or using the Site or Mobile App, or by engaging with Smartkarma or its group companies, you are hereby accepting the terms of this Privacy Policy.

This version of the Privacy Policy is current as of 16 May 2018

“Personal data” is any data that can be used to identify a natural person or individual. Examples of personal data that we may collect from you, either directly when you engage with Smartkarma or its group companies, or otherwise through your use of the Site or Mobile App, include:

• professional and personal details such as your name, gender, contact details, contact preferences and IP address;
• details of transactions or interactions you carry out through our Site and/or Mobile App;
• details of your visits to our site (including, but not limited to, traffic data, location data, weblogs and other communication data) and the resources and links that you access; and
• records in connection with service provision to Users including records of correspondence and records of use of the Site and other related services, account details, records of agreements and other transactions, notes from interactions and information used for monitoring and regulatory compliance.

We collect, process and retain personal information from you when you enter into a User Agreement or register for an account with us, and each time you navigate to the Site or Mobile App and interact or transact with us.

To capture user and usage data, individual preferences and browsing behaviour, we use cookies, web beacons and similar technologies to collect information about your visit to the Site or Mobile App, such as the pages you view, content you read, links you click and other actions you take on the Site or Mobile App.

You may set up your web browser to block or disable cookies which will in turn disable the monitoring of your visit. You may also remove cookies stored from your computer or mobile device. However, if you do block or disable cookies, you may not be able to use or receive certain personalised features and functions of the Site or Mobile App.

Please also note that the Site may contain links to other websites which are not operated or maintained by Smartkarma. When visiting these third party websites, you should read their privacy and data protection policies which will solely apply to your use of those third party websites.

Smartkarma will always process your personal data for a specific purpose, and process only the personal data that is relevant for achieving that purpose. Depending on our relationship with you and the products and services that we provide to you, we may process your personal data for the following business purposes and associated compatible purposes:

• Account opening and on-boarding;
• Understanding client needs and offering products and services;
• Providing products and services;
• Managing our relationships with Users and connected parties;
• Communicating with Users;
• Carrying out operational and administrative functions;
• Helping us to improve our products and services;
• Managing and conducting our business;
• Monitoring and assessing risk, conducting audits and enforcing our rights;
• Marketing our products and services to Users; and
• Meeting our regulatory and compliance obligations.

To support or enhance the delivery and performance of the above business purposes, Smartkarma uses the services of selected, authorised third party processors with whom Smartkarma has data processing agreements in place to ensure that all such disclosure and use is in compliance with relevant privacy laws, including where applicable the GDPR.

Smartkarma does not sell personal data to any third parties under any circumstances. Smartkarma shall also remain fully compliant with any contractual duty or obligation of confidentiality imposed on it under the applicable User Agreements or Terms of Use that govern our relationship with our Users and/or any applicable law.

The data sharing outlined in this Privacy Policy may involve the transfer of personal data to any country in which Smartkarma or a group company conducts business or has a service provider, or to other countries for law enforcement purposes. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws, including where applicable the GDPR and ensure that appropriate safeguards are in place to protect your personal data.

Smartkarma will retain your personal data for the period of time required for the business purposes for which it was collected or to comply with legal, regulatory and internal compliance requirements.

You may request access to or corrections in respect of your personal data held by Smartkarma. If you are a User based in Europe, the GDPR provides for more specific rights of access, modification, usage restriction and deletion of your personal information.

Please contact us for details on how you may request such access, corrections or other actions.

The above information may change from time to time resulting in an update to this Privacy Policy – for example, the categories of personal data that Smartkarma collects, the purposes for which it is used and the ways in which it is shared may change. We will make the updated policy available here and notify our Users of material updates in writing. All communications, transactions and dealings with Smartkarma will be subject to the latest version of this Privacy Policy in force from time to time.

To contact us regarding your personal data or any aspect of this Privacy Policy, please contact us at [email protected].