Privacy & Data Protection Policy

This Policy applies to all personal data collected by Ascan Payment Solutions Pte. Ltd. and its subsidiaries (referred to herein as “ASCAN”, “us”, “we”, or “our”). The purpose of this Policy is to inform you of how ASCAN manages Personal Data, which is subject to the Personal Data Protection Act 2012 of Singapore and its subsidiary legislation. Please take a moment to read this Policy so that you know and understand the purposes for which we collect, use, and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to ASCAN, as well as our respective representatives and/or agents collecting, using, disclosing, and sharing amongst themselves your Personal Data, and disclosing such Personal Data to ASCAN’s authorized service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Policy supplements but does not supersede nor replace any other consent you may have previously provided to ASCAN in respect of your Personal Data, and your consent herein are additional to any rights which ASCAN may have at law to collect, use, or disclose your Personal Data.

ASCAN may from time to time update this Policy to ensure that it is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on our websites, applications, and digital services. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

1.1. In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about 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 as may be updated from time to time.

1.2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone numbers, mailing address, email address, and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2. Collection of Personal Data

2.1. Generally, we collect Personal Data in the following ways:

  1. when you submit an application form or other forms relating to any of our products and services;
  2. when you interact with our customer service officers, via telephone calls, letters, face-to-face meetings, and emails;
  3. when you use our electronic services, or interact with us via any of our websites or use services on any of our websites;
  4. when you request that we contact you, or request that you be included in an email or other mailing list;
  5. when you respond to our promotions, initiatives, or to any request for additional Personal Data;
  6. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
  7. when you are contacted by, and respond to, our marketing representatives and customer service officers;
  8. when we receive references from business partners and third parties, for example, where you have been referred by them.

2.2. If you provide us with any Personal Data relating to a third party (e.g., information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

2.3. You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

2.4. We will make reasonable efforts to ensure that Personal Data is accurate and complete if it is likely to be used to make a decision that affects you or to be disclosed to another organisation.

3. Purposes for the Collection, Use, and Disclosure of Your Personal Data

3.1. Generally, ASCAN collects, uses, and discloses your Personal Data for the following purposes:

  1. responding to your queries, feedback, complaints, and requests;
  2. verifying your identity;
  3. managing the administrative and business operations of ASCAN and complying with internal policies and procedures;
  4. facilitating business asset transactions (which may extend to any mergers, acquisitions, or asset sales) involving ASCAN;
  5. matching any Personal Data held which relates to you for any of the purposes listed herein;
  6. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling, or other purposes for us to review, develop and improve the quality of our products and services;
  7. preventing, detecting, and investigating crime and analyzing and managing commercial risks;
  8. facilities management (including but not limited to maintaining the security of our premises);
  9. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
  10. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training, and performance evaluation and identity verification purposes;
  11. in connection with any claims, actions, or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
  12. conducting investigations relating to disputes, billing, or fraud;
  13. meeting or complying with any applicable rules, laws, regulations, codes of practice, or guidelines issued by any legal or regulatory bodies which are binding on ASCAN (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence, and investigations);
  14. creating and maintaining your profile in our system database for internal records and reference;
  15. providing customer service and support;
  16. administering debt recovery and debt management;
  17. facilitating your use of our online portals;
  18. any other purpose reasonably related to the aforesaid.

3.2. In addition to the purposes listed at paragraph 3.1 above, if you are an employee, business partner, sole proprietor, director, agent, representative, or authorized signatory of an organization that is a merchant of ASCAN:

  1. processing your application for ASCAN’s products and services;
  2. facilitating the daily operation of our products and services and providing customer service and support (including but not limited to processing payments, transactions, and refunds, resolving any technical difficulties, disputes or problems that you may encounter in connection with the use of our products and services, suspected fraudulent transactions, and attending to your requests for any other products and services);
  3. facilitating your appointment as an authorized signatory;
  4. facilitating user access to portals;
  5. creating and maintaining our merchants’ profiles in our system database;
  6. facilitating operations with regards to ASCAN terminals (including but not limited to arranging for terminal deployment and installation, return of terminals, and self-collection of terminals by the merchant);
  7. facilitating back-end operations (including but not limited to disclosing to banks certain information relating to administration and service requests);
  8. administering debt recovery and debt management;
  9. performing data analytics;
  10. processing any interactions which is linked to establishment and facilitation of merchant services;
  11. conducting audit checks (including but not limited to reviewing and evaluating the adequacy and effectiveness of company’s risk management, control, and governance process, reliability and integrity of financial and operating information, and ensuring compliance with policies, plans, procedures, laws, and regulations);
  12. resolving merchant disputes; and/or
  13. purposes which are reasonably related to the aforesaid.

3.3. If you are an officer, employee, or owner of an external service provider or vendor outsourced or prospected by ASCAN:

  1. assessing your suitability as an external service provider or vendor for ASCAN;
  2. managing project tenders and quotations, processing orders or managing the supply of goods and services;
  3. processing and payment of vendor invoices and bills;
  4. conducting vendor onboarding and performance evaluations;
  5. managing business operations and product development;
  6. facilities management (including but not limited to maintaining the security of our premises); and/or
  7. purposes which are reasonably related to the aforesaid.

3.4. If you apply to us as a candidate for employment, or an employee of ASCAN:

  1. conducting interviews;
  2. processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
  3. obtaining employee references and for background screening (including but not limited to reviewing your details for security purposes);
  4. assessing your suitability for the position applied for;
  5. onboarding and facilitating your appointment as an employee;
  6. payroll processing;
  7. facilitate enrollment of any employee benefits (e.g., medical or insurance benefits) and other benefits that may be entitled;
  8. facilitating the execution of duties and administrative matters;
  9. organizing training and development programs;
  10. registering you for courses;
  11. assessing your performance;
  12. communicating with you as required by ASCAN to comply with its policies and processes, including for business continuity purposes; and
  13. any other purposes relating to the aforesaid.

3.5. Furthermore, where permitted under the Act and/or where you have provided your consent to ASCAN separately, ASCAN may also collect, use, and disclose your Personal Data for the following additional purposes:

  1. providing or marketing services, products, and benefits to you, including but not limited to special events and promotions from ASCAN;
  2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by ASCAN;
  3. administering and organizing contests, lucky draws, promotional events, competitions, and marketing campaigns, and personalizing your experience at ASCAN’s touchpoints;
  4. conducting market research, analytics, and surveys to enable ASCAN to understand and determine customer preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
  5. any other purpose reasonably related to the aforesaid.

3.6. If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, ASCAN may continue to contact you using such Singapore telephone number(s) (including via voice calls, text, fax, or other means) with information about our products and services, unless you have withdrawn your consent.

3.7. In relation to particular products and services or in your interactions with ASCAN, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use, and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.8. For marketing messages to Singapore telephone numbers, we comply with the Do Not Call provisions under the Personal Data Protection Act 2012, including checking the relevant DNC Registers unless an exemption applies or we have obtained clear and unambiguous consent that has not been withdrawn.

4. Disclosure of Personal Data

4.1. ASCAN will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed by ASCAN, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

  1. Ascan Payment Solutions Pte. Ltd. (“ASCAN”);
  2. companies providing services relating to medical screening, insurance, marketing, and consultancy to ASCAN;
  3. agents, contractors or third party service providers who provide operational services to ASCAN, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, employee recognition, or other services to ASCAN;
  4. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition, or asset sale) involving ASCAN;
  5. external banks, credit card companies, and their respective service providers;
  6. our professional advisers such as consultants, auditors, and lawyers;
  7. relevant government ministries, regulators, statutory boards or authorities, or law enforcement agencies to comply with any laws, rules, guidelines, and regulations or schemes imposed by any governmental authority;
  8. any other party whom you authorize us to disclose your Personal Data to.

4.2. Where Personal Data is transferred outside Singapore, we will ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to the protection under the Personal Data Protection Act 2012.

5. Use of Cookies

5.1. A cookie is a small piece of information that is placed on your computer when you visit certain websites. The cookies placed by the servers hosting our websites are readable only by us, and are used to improve user experience, track website usage, and manage and enhance our services. Cookies cannot access, read, or modify any other data on an electronic device, nor do they capture any data that allows us to identify you individually.

5.2. Should you wish to disable the cookies associated with these technologies, you may do so by changing the settings on your browser. However, you may not be able to enter certain part(s) of our websites.

6. Data Security

6.1. ASCAN will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites, applications, and digital services (for example, viruses, bugs, Trojan horses, spyware, or adware). You should be aware of the risks associated with using websites, applications, and digital services.

6.2. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, when you browse our websites, or use our applications and/or digital services, and the method of electronic storage. We urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

6.3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen, or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, or unauthorized and/or fraudulent use of your username and password.

6.4. We will cease retention of Personal Data, or remove the means by which the Personal Data can be associated with particular individuals, when retention no longer serves the purposes for which it was collected and is not required for legal or business purposes.

6.5. We maintain retention schedules for key categories of records.

6.6. Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised.

6.7. We will assess suspected data incidents promptly to determine if a notifiable data breach has occurred.

6.8. Where a notifiable data breach occurs, we will notify the Personal Data Protection Commission and, where applicable, affected individuals in accordance with applicable law and regulatory timelines.

6.9. We will document data breaches and the remedial actions taken.

7. Contacting Us – Feedback, Withdrawal of Consent, Access, and Correction of your Personal Data

7.1. You can contact our customer service officer and/or our data protection officer at:
Email: customerservice@eftpos.com.sg and dpo@eftpos.com.sg
Phone: +65 6483 2373, if you:

  1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
  2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
  3. would like to obtain more information on or access to and make corrections to your Personal Data records.

7.2. If you withdraw your consent to any or all uses of your Personal Data, depending on the nature of your request, ASCAN may not be in a position to administer any contractual relationship in place, which in turn may also result in the termination of any agreements with ASCAN, and your being in breach of your contractual obligations or undertakings. ASCAN’s legal rights and remedies in such event are expressly reserved.

7.3. For access or correction requests, we may need to verify your identity and may request information reasonably required to process your request.

7.4. We will respond as soon as reasonably practicable. If more time is needed, we will inform you of the expected timeframe.

7.5. We may charge a reasonable fee for processing an access request and will provide a written estimate of the fee.

7.6. We may refuse access or provide a redacted copy in accordance with the Personal Data Protection Act 2012 and its regulations, and will provide reasons where permitted.

8. Governing Law

8.1. This Data Protection Policy, your browsing of our websites, and use of our applications and/or digital services shall be governed in all respects by the laws of Singapore.