Effective Date: 01 April 2022
2. Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Application means the software program provided by the Company downloaded by You on any electronic device, named Chopnow
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Chopnow Fintech Pte Ltd, 35 North Canal Road #02-01 Singapore 059291.
Country refers to: Singapore
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data means data, whether true or not, about our user 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
Service refers to the Application.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
3. Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Passport or National Digital Identity Card (including digital IC)
Personal Identification Number (IC No., FIN No., or Passport No.)
First name and last name
Address, State, Province, ZIP/Postal code, City√ Financial information including bank account information in order to pay for products and/or services within the Service
Date of birth
When You pay for a product and/or a service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity. Such information may include, without limitation:
Date of birth
Passport or National Digital Identity Card (including digital IC)
Other information linking You to an address
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Usage DataUsage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
Information Collected while Using the ApplicationWhile using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:
Information regarding your location
Information from your Device's phone book (contacts list)
Pictures and other information from your Device's camera and photo library
We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.
You can enable or disable access to this information at any time, through Your Device settings.
Use of Your Personal DataThe Company may use Personal Data for the following purposes:
To conduct Customer Due Diligence, including to verify Your identity, onboard You and do carry out our Know Your Client (“KYC”) measures.
To produce alternative credit decisions/scores. We use mobile and web device metadata and/or personal information provided by you to produce the alternative credit score via our proprietary technology. This includes highly sophisticated algorithms and predictive analytics applied to metadata accessed via our Service. We use this alternative credit score only in relation to our Service.
To provide and maintain our Service, including to monitor the usage of our Service and/or to deliver financial solutions that are of interest to our customers.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user,
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service, including processing payment or credit transactions.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us, including responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
To conduct credit checks: We may use Your information to conduct credit checks with credit bureaus including but not limited to Moneylenders Credit Bureau (MLCB), “DP Information Network Pte Ltd, DP SME credit Bureau, Credit Bureau (Singapore) Pte Ltd and Credit Association of Singapore”.
To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, whether in Singapore or abroad
For debt recovery purposes, including to engage any law firms, third party debt collection agencies or approved third party debt collectors.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience or any other incidental business purposes related to or in connection with the above.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to perform any of the functions with reference to the above mentioned purposes, and/or monitor and analyze the use of our Service, for payment processing, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.
Retention of Your Personal Data
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
Security of Your Personal Data
The security of Your Personal Data is important to Us. To safeguard Your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, We have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, and usage of one time password(OTP)/2 factor authentication (2FA)/multi-factor authentication (MFA) to secure access. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, We strive to protect the security of Your information and are constantly reviewing and enhancing our information security measures.
4. Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may use Email Marketing Service Providers to manage and send emails to You.
Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).
When You use Our Service to pay a product and/or service via bank transfer, We may ask You to provide information to facilitate this transaction and to verify Your identity.
Usage, Performance and Miscellaneous
We may use third-party Service Providers to provide better improvement of our Service.
We use an invisible captcha service named reCAPTCHA. reCAPTCHA is operated by Google.
The reCAPTCHA service may collect information from You and from Your Device for security purposes.
5. Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.
6. Links to Other Websites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
8. Withdrawing Your Consent
The consent that You provide for the collection, use and disclosure of Your personal data will remain valid until such time it is being withdrawn by You in writing.
You may withdraw consent and request Us to stop collecting, using and/or disclosing Your personal data for any or all of the purposes listed above by submitting Your request in writing or via email to Our Data Protection Officer at the contact details provided below.
Upon receipt of Your written request to withdraw your consent, We may require reasonable time (depending on the complexity of the request and its impact on Our Service to You) for Your request to be processed and for Us to notify You of the consequences of Us acceding to the same, including any legal consequences which may affect Your rights and liabilities to Us.
In general, We shall seek to process Your request within fourteen (14) business days of receiving it. Whilst We respect Your decision to withdraw Your consent, please note that depending on the nature and scope of Your request, We may not be in a position to continue providing Our Services to You and We shall, in such circumstances, notify You before completing the processing of Your request. Please note that withdrawing consent does not affect Our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
9. Contact Us
If You wish to make:
(a) an access request for access to a copy of the personal data which We hold about You or information about the ways in which We use or disclose Your personal data, or;
(b) a correction request to correct or update any of Your personal data which We hold about You, You may submit Your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, We will inform You of the fee before processing Your request. We will respond to Your request as soon as reasonably possible. In general, Our response will be within fourteen (14) business days.
Should We not be able to respond to Your request within thirty (30) days after receiving Your request, We will inform You in writing within thirty (30) days of the time by which We will be able to respond to Your request. If We are unable to provide You with any personal data or to make a correction requested by You, We shall generally inform You of the reasons why We are unable to do so (except where We are not required to do so under the PDPA).
By email: [email protected]
By mail: 35 North Canal Road #02-01 Singapore 059291
This document was last updated on April 1, 2022