Last updated: March 3rd, 2020

Privacy Policy

This Privacy Policy (the “Policy“), as may be amended, modified and supplemented from time to time, applies to all users or visitors (“you“) accessing or using the FLEXM WALLET mobile app and website comprising all webpages located at www.flexm.com (collectively, the “Site”). It describes how FLEXM PTE. LTD.  (thereafter referred to as “FLEXM“), and its subsidiaries (“we”, “us”, “our”) collect, use, disclose, transfer and store your personal information. All capitalized terms used in this Policy has the same meaning as those ascribed in the Terms & Conditions unless otherwise stated or defined herein. By accessing the Site, sharing your information or registering as a user of our Services, you are accepting this Policy and consenting to the collection, use and disclosure of your information disclosed to us in the manner as described in this Policy. 

COLLECTION OF PERSONAL DATA

As part of accessing and using the Site and the Services, we may ask you to provide us with certain personally identifiable information (“Personal Data”). You must ensure that all the Personal Data you provide to us is accurate and complete. You may request access to your Personal Data within our possession or under our control at any time. Where there is any change to or inaccuracies in your Personal Data, you must promptly update us or correct your Personal Data in your User Account.

COOKIES

By accessing and using the Site and our Services, you consent to our use of cookies. For details please refer to our Cookie Policy.

USES OF PERSONAL DATA

FLEXM uses the collected Personal Data for various purposes, including, but not limited to:

  • fulfill the specific purpose for which the Personal Data was provided such as but not limited to: account registration; employment; vendor/ supplier/ other partnerships; merchant acquiring, etc.
  • provide, maintain, and improve the Site and the Services;
  • notify you about changes to the Site and the Services via short message service, e-mail, in-app notifications, or push notifications/pop-ups;
  • provide customer care and support;
  • monitor the usage of the Site and the Services;
  • detect, prevent, and address technical issues;
  • detect and protect users against illegal activity on the Site;
  • enforce these T&Cs; and
  • carry out any other purposes that are related or incidental to any of the foregoing purposes
MARKETING AND PROMOTIONS

We may use your Personal Data to send you marketing and promotional materials in relation to products and services offered by us by notifications such as short message service, electronic mail, in-app notifications, or push notifications/pop-ups. If you wish to unsubscribe to such notifications, you may click on the “unsubscribe” link in the relevant notification.For contracted partners/ vendors/ merchants, we may at our discretion display your name, logo, acronyms and other insignia in any material or medium for the advertisement, publicity and promotion of the Site and Services.

DISCLOSURE OF PERSONAL DATA

FLEXM works with third party companies and individuals to facilitate the provision of the Site and Services, provide the Services on our behalf, perform related services, and assist us in analyzing how the Site or Services are used (“Service Providers”).While we may disclose your Personal Data to our Service Providers, such disclosure will be limited to the extent reasonably necessary for the above purposes and will be done in compliance with the Personal Data Protection Act 2012 (“PDPA“). We have also taken reasonable measures to ensure that our Service Providers do not disclose or use your Personal Data for any other purpose.FLEXM may also disclose your Personal Data in good faith where it believes that such action is necessary to:

  • comply with its legal obligations
  • protect and defend the rights or property of FLEXM or users of the Site or Services
  • prevent or investigate possible wrongdoing in connection with the Site or Services
  • protect the personal safety of users of the Site or Services or the public
  • protect FLEXM against legal liability
TRANSFER OF PERSONAL DATA

Your Personal Data may need to be transferred out of Singapore, whether in the course of providing you with any Service or when storing your Personal Data on servers located outside Singapore. In creating a User Account and accessing and using the Site or Services, you are deemed to agree to the transfer of your Personal Data outside Singapore.FLEXM has taken reasonable steps to ensure that your Personal Data is processed, held, or otherwise handled in accordance with the PDPA and your Personal Data will not be transferred to another organization or country unless there are adequate controls in place, including controls relating to the security of your Personal Data. However, if your Personal Data needs to be transferred to countries that have less stringent personal data protection laws than Singapore in order to provide you with the Services, you are deemed to consent to such transfer in providing your Personal Data to us during your use of the Site or the Services.

RETENTION OF PERSONAL DATA

We will retain your Personal Data until the purpose for which that Personal Data was collected is no longer served by the retention of the Personal Data and the Personal Data does not need to be retained any longer for any legal or business purpose.

SECURITY OF PERSONAL DATA

The security of your Personal Data is important to us. We take reasonable security measures to keep your Personal Data safe and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or other similar risks. However, no method of electronic transmission or electronic storage is fully secure. You hereby acknowledge and accept that while we strive to protect your Personal Data, we cannot guarantee its absolute security.

YOUR RIGHTS

You may contact our Data Protection Officer at dpo@flexm.com to (i) request to access or correct your Personal Data or (ii) request information on how your Personal Data may have been used or disclosed in the past year (subject to payment to any reasonable fee we may charge). However, please note that Singapore law allows us to refuse such requests under certain circumstances.You may also withdraw your consent to our collection, use, disclosure, storage, transfer, or processing of your Personal Data at any time, upon which we will cease all such activities relating to your Personal Data and procure that our data intermediaries and agents also cease collecting, using, or disclosing your Personal Data. Please note that this may affect our ability to provide, or prevent us from providing, you with any or all of the Services.

CUSTOMER FEEDBACK

If you have any questions, feedback, or complaints, please contact FLEXM via our customer service at support@flexm.com. If you have queries related to a particular transaction, please provide identifying information such as your name, telephone number, unique identification number, and details of the Transaction.

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