Privacy Policy
Privacy Policy
Last Updated: 27th July, 2022
Tribe Fintech Fintech Pte. Ltd. (“Tribe Fintech”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. The purpose of this Privacy Notice is to provide a clear explanation of when, why and how we collect and use your personal data.
If you interact with us, or use our website: www.tribefintech.com (“Website”) or our applications or APIs (collectively, the “Apps”) or any site operated by us in partnership with a commercial partner offering our services, we may collect and process certain personal data about you.
The processing of your personal data complies with Applicable Data Protection Laws, including Personal Data Protection Act 2012 (Singapore), the General Data Protection Regulation (EU Regulation 2016/679) and their respective implementing regulations (collectively, “Applicable Data Protection Law”). This Privacy Notice should be read together with our related policies and procedures, including our Cookies Policy, we maintain regarding our compliance with Applicable Data Protection Law.
It is important that you read this Privacy Notice together with any other fair processing notice we may provide on specific occasions so that you are fully aware of how and why we are using your data. This Privacy Policy is not intended to override the terms of any contract that you may have with us (for example, the terms and conditions you agreed when you apply to use our Tribe Fintech Platform or any rights you might have under Applicable Data Protection Law.
Controller of personal information
Tribe Fintech Pte. Ltd. will be the data controller and as such is responsible for looking after your personal information. Our Data Protection Officer may be contacted by emailing legal@tribefintech.com.
What types of personal information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Tribe Fintech provides services to businesses, and our Website, Apps and our services are not intended for consumers. However in order to provide these services, and to communicate with our business customers we will need information about employees, directors and other officers of those companies. We also process data of individuals who interact with Tribe Fintech, whether through direct contact with us, through our Website, Apps or on social media.
Depending on the types and nature of services you use (or continue to use), we may collect different types of personal information from you. This includes:
personal particulars (e.g. name, email address, telephone number, country of residence, residential address, date of birth and/or identity card/passport details);
voice recordings of our conversations with you;
employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
tax information;
banking information (e.g. account numbers and banking transactions);
background checks information (e.g. credit history);
information you provide to us when you contact our support team to help us answer your queries. We also gather information about any suggestions or complaints you make in order to help address your queries and improve the products and services we offer you;
information obtained from mobile device with your consent (e.g. device location and information);
your email and marketing preferences including interests and market list assignments, marketing objections, preferred language, Website and Apps data; and
your device data and log information through the use of technologies, cookies and web beacons and advertising IDs (more information about use of cookies can be found in our Cookies Policy) including IP addresses, device ID and type, and details about your use of our Website and Apps, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information.
How do we collect personal information?
Your personal information is collected by us either directly (for example, when you use our Website and Apps, register for our services, enter into our promotional events, download our Apps, or when you interact with us by contacting us for enquiries or providing feedback), or indirectly from our commercial partners (for example, if you register for our commercial and content partners’ services through our Website or Apps and have authorised our commercial partners to transfer to us your usage of their services). You are under no obligation to provide the personal information when we seek to directly or indirectly collect it from you. However, if you do not provide us with certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your enquiries.
For what purposes are personal information collected and used?
We may use your personal information for our core business purposes, such as:
create customer profiles, maintain customer records and to communicate with you (including providing you with updates on changes to services), fulfil your requests and respond to your queries or feedback, addressing or investigating any complaints, claims or dispute;
send you important notices or personalised messages in relation to your use of our services;
administer the operation of our Website and Apps, to allow you to use the services and functions of our Website, to conduct website maintenance, to troubleshoot problems, and to continually improve your experience when using our services;
provide you with services in accordance with the terms and conditions that govern our relationship with you;
to identify and send you marketing materials, news and information which we think will be of interest to you such as our latest promotional offers and upcoming services;
conducting screening, due diligence checks and verify your identity for the purposes of providing our services as may be required under applicable laws, regulations or directives;
detect, investigate and prevent fraud and other illegal activities;
use your personal information for purposes associated with our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes and for the purposes of seeking professional advice, including legal advice;
keep internal records, decision making and facilitate internal purposes such as data analysis, and research to improve our services, service security and quality;
to maintain opt-out and opt-in lists (including responding to customer requests to opt-out of direct marketing); and
to develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of Websites, Apps or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data regarding our services to calculate the percentage of users accessing our Websites, Apps or service feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
We may collect special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
When will you use personal information for direct marketing purposes?
We may use your personal information to send you direct marketing communications about our products and services or our related services including our upcoming services and offers. This may be in the form of in-app notifications. We limit direct marketing to a reasonable and proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.
From the effective date of this Privacy Policy onwards, where you register for our services or offers and have elected to receive direct marketing information by in-app notifications, then for the purposes of Applicable Data Protection Law, we will ask you for your consent for our processing of your personal information for direct marketing purposes.
The above statement does not apply if you have previously provided us with your personal information and opted-in to direct marketing in accordance with Applicable Data Protection Law. In these cases our continued processing of your personal information is based on our legitimate interests as further detailed in Appendix 1.
You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out links in electronic communications (such as emails), or by contacting us (please see the “How to contact us” section below).
What is our legal basis for using your personal information?
We will only process your personal information where we have a legal basis to do so. We are required to establish a legal basis in order to use your personal information for the purposes set out above. We will make sure that we only use your personal information for the purposes set out above and in Appendix 1 where we are satisfied that:
our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to fulfil obligations under the contract signed between you and us);
you have provided your consent;
it is necessary to comply with a legal obligation; or
our use of your personal information is necessary to support the “legitimate interests” that we have as a business (for example, to improve our products and services, to provide help or support in connection with our Website and Apps, to ensure that they operate efficiently and securely, and to carry out analytics across our datasets), provided it is always carried out in a way that is proportionate, and that respects your data privacy rights.
Who do we share your personal information with?
Your personal information may be shared with companies within our group to assist us in providing our services to you. We may also disclose your personal information to the following third parties for the purposes described below:
Service providers and partners we engage in order to provide our services to you, such as bank partners, digital business tools operators, etc.
In response to a valid legal request from government, regulatory authorities, law enforcement agencies and courts.
Professional advisors such as law firms to enforce or apply any contract with you or including subpoenas, court orders, legal process, and our auditors in connection with our audit requirements.
Service providers to carry out due diligence identity verification, transactions monitoring, fraud-screening and for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public, or as necessary to serve our legitimate business interests.
In order to improve our business services, we may share your personal information, as well as non-personally identifiable information, with our advertising and analytics providers and with related service providers.
We may share your personal data with any subsidiaries, joint ventures, or other companies under common control. If another company acquires our company, business, or our assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Privacy Notice.
Our Website and Apps may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our Website or Apps, we encourage you to read the privacy notice of every website you visit.
What countries will your personal information be sent to?
Your personal information may be sent to and stored by us, our affiliates and third parties in countries outside Singapore or the European Economic Area. When we do this, we will use appropriate safeguards, where necessary, to protect any personal data being transferred. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and is undertaken in accordance with the Applicable Data Protection Law governing such transfers.
You have the right to ask us for more information about the safeguards we have put in place (please see the “How to contact us” section below if you would like further information).
How can we keep your personal information secure?
We make every effort to protect us and you (including your data and personal information that we hold) from unauthorised access, alteration, disclosure or destruction. We have implemented technical and organisational security measures to safeguard your personal information and data.
In particular:
we regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems;
we use encrypted password protection where appropriate; and
we restrict access to personal information to only those employees and contractors who need access to the relevant personal information in order for them to process it for us and who are subject to strict contractual confidentiality obligations.
We work hard to protect your personal information, but cannot guarantee the security of the data you disclose online due to the inherent security risks of providing information over the Internet.
How long will we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law, we are required to retain your personal data for 10 years after your ceasing to be our customers or use our services.
When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it. In some circumstances we may retain your personal information for longer periods of time. Such circumstances may include but are not limited to where we are required to do so to meet legal, regulatory, tax or accounting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
What are your other rights?
Under certain circumstances, you have rights under Applicable Data Protection Law in relation to your personal data. Specifically, these rights may include:
Access: you can ask us to provide details of what personal information (if any) we process about you, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, how you can make a complaint, where we got your data from, you can also ask us to provide a copy of it;
Rectification: you can ask us to rectify inaccurate personal information;
Erasure: you can ask us to erase your personal information in certain circumstances (for example if it is no longer needed for the purposes for which it was collected or you have withdrawn your consent if the data processing was based on consent) absent an overriding legitimate interest;
Restriction: you can ask us to restrict (i.e. keep but not use) your personal information in certain circumstances (for example where its accuracy is contested or where it ceases to be useful for the purposes we are using it for);
Portability: in certain circumstances you can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller;
Objection: you can object to any processing of your personal information which has our 'legitimate interests' as its lawful basis if you believe your fundamental rights and freedoms outweigh our legitimate interests; and
Automated Decision Making: you can ask for certain automated decisions to be reconsidered by us using human intervention.
Withdrawal of Consent: if you have consented to our processing of your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages you receive from us.
Lodging a Complaint: you have a right to lodge a complaint with your national data protection supervisory authority at any time if you believe that we have not complied with Applicable Data Protection Law. We would, however appreciate the chance to deal with your concerns before your approach the data protection authorities so please contact us in the first instance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please contact us as set out in the section headed “How to contact us?” if you do wish to exercise these rights.
How to contact us?
If you have any questions or concerns about our use of your personal information, please contact us by email legal@tribefintech.com, or by post at: 160 Robinson Road, #14-04 Singapore (068914).
Changes to this Privacy Notice
We reserve the right to change our Privacy Notice at any time. If we make changes, we will indicate on this page the Privacy Notice’s new effective date. Please check this page from time to time to take notice of any changes we make, as they are binding on you.
Effective Date 27th July 2022
APPENDIX 1 – LAWFUL BASES FOR PROCESSING
Purpose: Create customer profiles, maintain customer records and to communicate with you (including providing you with updates on changes to services), fulfil your requests and respond to your queries or feedback, addressing or investigating any complaints, claims or dispute.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring your requests and feedback are attended to and to maintain an accurate record of your data.
Purpose: Send you important notices or personalised messages in relation to your use of our services.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring that all customers receive the best possible experience, helping us to preserve our business operations, and ensuring that you are provided with information relevant to you.
Purpose: Administer the operation of our Website and Apps, to allow you to use the services and functions of our Website, to conduct website maintenance, to troubleshoot problems, and to continually improve your experience when using our services.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring that all customers receive the best possible experience and improving our products and services offering in order to preserve our business operations.
Purpose: Provide you with services in accordance with the terms and conditions that govern our relationship with you.
Lawful basis: This processing is necessary to perform the contract between you and Tribe Fintech.
Purpose: To identify and send you marketing materials, news and information which we think will be of interest to you such as our latest promotional offers and upcoming services.
Lawful basis: This processing is necessary to perform the contract between you and Tribe Fintech. Tribe Fintech may also in certain situations have a legitimate interest to ensure that we are providing our customers with the opportunity to engage with us and participate in our promotional offers and be made aware of our upcoming products and services.
Purpose: Conducting screening, due diligence checks and verify your identity for the purposes of providing services as may be required under applicable laws, regulations or directives.
Lawful basis: Tribe Fintech considers that it has a legal obligation to ensure its business operates in accordance with applicable laws, regulations and directives.
Purpose: To detect, investigate and prevent fraud and other illegal activities.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring its business is not used for any fraudulent or illegal activities, and to protect our legal rights and interests.
Purpose: Use your personal information for purposes associated with our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes and for the purposes of seeking professional advice, including legal advice.
Lawful basis: Tribe Fintech considers that it has a legal obligation to ensure its business operates in accordance with applicable laws, regulations and directives.
Purpose: To keep internal records, decision making and facilitate internal purposes such as data analysis, and research to improve our services, service security and quality.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in continually improving our services in order to preserve and grow our business operations, and ensuring that you are provided with information relevant to you.
Purpose: To maintain opt-out and opt-in lists (including responding to customer requests to opt-out of direct marketing).
Lawful basis: This processing is necessary for the purpose of a legal obligation to which Tribe Fintech is subject in order to not provide direct marketing materials to individuals which have opted-out of, or opted-in to, receiving such communications.
Purpose: To develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them.
Lawful basis: Tribe Fintech considers that it has a legitimate interest in ensuring that you receive information about our products and services which may be of interest to you, this also helps us to preserve and grow our business operations.
Privacy Policy
Last Updated: 27th July, 2022
Tribe Fintech Fintech Pte. Ltd. (“Tribe Fintech”, “we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. The purpose of this Privacy Notice is to provide a clear explanation of when, why and how we collect and use your personal data.
If you interact with us, or use our website: www.tribefintech.com (“Website”) or our applications or APIs (collectively, the “Apps”) or any site operated by us in partnership with a commercial partner offering our services, we may collect and process certain personal data about you.
The processing of your personal data complies with Applicable Data Protection Laws, including Personal Data Protection Act 2012 (Singapore), the General Data Protection Regulation (EU Regulation 2016/679) and their respective implementing regulations (collectively, “Applicable Data Protection Law”). This Privacy Notice should be read together with our related policies and procedures, including our Cookies Policy, we maintain regarding our compliance with Applicable Data Protection Law.
It is important that you read this Privacy Notice together with any other fair processing notice we may provide on specific occasions so that you are fully aware of how and why we are using your data. This Privacy Policy is not intended to override the terms of any contract that you may have with us (for example, the terms and conditions you agreed when you apply to use our Tribe Fintech Platform or any rights you might have under Applicable Data Protection Law.
Controller of personal information
Tribe Fintech Pte. Ltd. will be the data controller and as such is responsible for looking after your personal information. Our Data Protection Officer may be contacted by emailing legal@tribefintech.com.
What types of personal information do we collect?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Tribe Fintech provides services to businesses, and our Website, Apps and our services are not intended for consumers. However in order to provide these services, and to communicate with our business customers we will need information about employees, directors and other officers of those companies. We also process data of individuals who interact with Tribe Fintech, whether through direct contact with us, through our Website, Apps or on social media.
Depending on the types and nature of services you use (or continue to use), we may collect different types of personal information from you. This includes:
personal particulars (e.g. name, email address, telephone number, country of residence, residential address, date of birth and/or identity card/passport details);
voice recordings of our conversations with you;
employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
tax information;
banking information (e.g. account numbers and banking transactions);
background checks information (e.g. credit history);
information you provide to us when you contact our support team to help us answer your queries. We also gather information about any suggestions or complaints you make in order to help address your queries and improve the products and services we offer you;
information obtained from mobile device with your consent (e.g. device location and information);
your email and marketing preferences including interests and market list assignments, marketing objections, preferred language, Website and Apps data; and
your device data and log information through the use of technologies, cookies and web beacons and advertising IDs (more information about use of cookies can be found in our Cookies Policy) including IP addresses, device ID and type, and details about your use of our Website and Apps, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information.
How do we collect personal information?
Your personal information is collected by us either directly (for example, when you use our Website and Apps, register for our services, enter into our promotional events, download our Apps, or when you interact with us by contacting us for enquiries or providing feedback), or indirectly from our commercial partners (for example, if you register for our commercial and content partners’ services through our Website or Apps and have authorised our commercial partners to transfer to us your usage of their services). You are under no obligation to provide the personal information when we seek to directly or indirectly collect it from you. However, if you do not provide us with certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your enquiries.
For what purposes are personal information collected and used?
We may use your personal information for our core business purposes, such as:
create customer profiles, maintain customer records and to communicate with you (including providing you with updates on changes to services), fulfil your requests and respond to your queries or feedback, addressing or investigating any complaints, claims or dispute;
send you important notices or personalised messages in relation to your use of our services;
administer the operation of our Website and Apps, to allow you to use the services and functions of our Website, to conduct website maintenance, to troubleshoot problems, and to continually improve your experience when using our services;
provide you with services in accordance with the terms and conditions that govern our relationship with you;
to identify and send you marketing materials, news and information which we think will be of interest to you such as our latest promotional offers and upcoming services;
conducting screening, due diligence checks and verify your identity for the purposes of providing our services as may be required under applicable laws, regulations or directives;
detect, investigate and prevent fraud and other illegal activities;
use your personal information for purposes associated with our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes and for the purposes of seeking professional advice, including legal advice;
keep internal records, decision making and facilitate internal purposes such as data analysis, and research to improve our services, service security and quality;
to maintain opt-out and opt-in lists (including responding to customer requests to opt-out of direct marketing); and
to develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of Websites, Apps or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data regarding our services to calculate the percentage of users accessing our Websites, Apps or service feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
We may collect special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
When will you use personal information for direct marketing purposes?
We may use your personal information to send you direct marketing communications about our products and services or our related services including our upcoming services and offers. This may be in the form of in-app notifications. We limit direct marketing to a reasonable and proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.
From the effective date of this Privacy Policy onwards, where you register for our services or offers and have elected to receive direct marketing information by in-app notifications, then for the purposes of Applicable Data Protection Law, we will ask you for your consent for our processing of your personal information for direct marketing purposes.
The above statement does not apply if you have previously provided us with your personal information and opted-in to direct marketing in accordance with Applicable Data Protection Law. In these cases our continued processing of your personal information is based on our legitimate interests as further detailed in Appendix 1.
You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out links in electronic communications (such as emails), or by contacting us (please see the “How to contact us” section below).
What is our legal basis for using your personal information?
We will only process your personal information where we have a legal basis to do so. We are required to establish a legal basis in order to use your personal information for the purposes set out above. We will make sure that we only use your personal information for the purposes set out above and in Appendix 1 where we are satisfied that:
our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to fulfil obligations under the contract signed between you and us);
you have provided your consent;
it is necessary to comply with a legal obligation; or
our use of your personal information is necessary to support the “legitimate interests” that we have as a business (for example, to improve our products and services, to provide help or support in connection with our Website and Apps, to ensure that they operate efficiently and securely, and to carry out analytics across our datasets), provided it is always carried out in a way that is proportionate, and that respects your data privacy rights.
Who do we share your personal information with?
Your personal information may be shared with companies within our group to assist us in providing our services to you. We may also disclose your personal information to the following third parties for the purposes described below:
Service providers and partners we engage in order to provide our services to you, such as bank partners, digital business tools operators, etc.
In response to a valid legal request from government, regulatory authorities, law enforcement agencies and courts.
Professional advisors such as law firms to enforce or apply any contract with you or including subpoenas, court orders, legal process, and our auditors in connection with our audit requirements.
Service providers to carry out due diligence identity verification, transactions monitoring, fraud-screening and for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public, or as necessary to serve our legitimate business interests.
In order to improve our business services, we may share your personal information, as well as non-personally identifiable information, with our advertising and analytics providers and with related service providers.
We may share your personal data with any subsidiaries, joint ventures, or other companies under common control. If another company acquires our company, business, or our assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Privacy Notice.
Our Website and Apps may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our Website or Apps, we encourage you to read the privacy notice of every website you visit.
What countries will your personal information be sent to?
Your personal information may be sent to and stored by us, our affiliates and third parties in countries outside Singapore or the European Economic Area. When we do this, we will use appropriate safeguards, where necessary, to protect any personal data being transferred. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and is undertaken in accordance with the Applicable Data Protection Law governing such transfers.
You have the right to ask us for more information about the safeguards we have put in place (please see the “How to contact us” section below if you would like further information).
How can we keep your personal information secure?
We make every effort to protect us and you (including your data and personal information that we hold) from unauthorised access, alteration, disclosure or destruction. We have implemented technical and organisational security measures to safeguard your personal information and data.
In particular:
we regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems;
we use encrypted password protection where appropriate; and
we restrict access to personal information to only those employees and contractors who need access to the relevant personal information in order for them to process it for us and who are subject to strict contractual confidentiality obligations.
We work hard to protect your personal information, but cannot guarantee the security of the data you disclose online due to the inherent security risks of providing information over the Internet.
How long will we keep your personal information?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law, we are required to retain your personal data for 10 years after your ceasing to be our customers or use our services.
When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it. In some circumstances we may retain your personal information for longer periods of time. Such circumstances may include but are not limited to where we are required to do so to meet legal, regulatory, tax or accounting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
What are your other rights?
Under certain circumstances, you have rights under Applicable Data Protection Law in relation to your personal data. Specifically, these rights may include:
Access: you can ask us to provide details of what personal information (if any) we process about you, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, how you can make a complaint, where we got your data from, you can also ask us to provide a copy of it;
Rectification: you can ask us to rectify inaccurate personal information;
Erasure: you can ask us to erase your personal information in certain circumstances (for example if it is no longer needed for the purposes for which it was collected or you have withdrawn your consent if the data processing was based on consent) absent an overriding legitimate interest;
Restriction: you can ask us to restrict (i.e. keep but not use) your personal information in certain circumstances (for example where its accuracy is contested or where it ceases to be useful for the purposes we are using it for);
Portability: in certain circumstances you can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller;
Objection: you can object to any processing of your personal information which has our 'legitimate interests' as its lawful basis if you believe your fundamental rights and freedoms outweigh our legitimate interests; and
Automated Decision Making: you can ask for certain automated decisions to be reconsidered by us using human intervention.
Withdrawal of Consent: if you have consented to our processing of your personal information, you have the right to withdraw your consent at any time. This includes cases where you wish to opt out from marketing messages you receive from us.
Lodging a Complaint: you have a right to lodge a complaint with your national data protection supervisory authority at any time if you believe that we have not complied with Applicable Data Protection Law. We would, however appreciate the chance to deal with your concerns before your approach the data protection authorities so please contact us in the first instance.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please contact us as set out in the section headed “How to contact us?” if you do wish to exercise these rights.
How to contact us?
If you have any questions or concerns about our use of your personal information, please contact us by email legal@tribefintech.com, or by post at: 160 Robinson Road, #14-04 Singapore (068914).
Changes to this Privacy Notice
We reserve the right to change our Privacy Notice at any time. If we make changes, we will indicate on this page the Privacy Notice’s new effective date. Please check this page from time to time to take notice of any changes we make, as they are binding on you.
Effective Date 27th July 2022
APPENDIX 1 – LAWFUL BASES FOR PROCESSING
Purpose: Create customer profiles, maintain customer records and to communicate with you (including providing you with updates on changes to services), fulfil your requests and respond to your queries or feedback, addressing or investigating any complaints, claims or dispute.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring your requests and feedback are attended to and to maintain an accurate record of your data.
Purpose: Send you important notices or personalised messages in relation to your use of our services.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring that all customers receive the best possible experience, helping us to preserve our business operations, and ensuring that you are provided with information relevant to you.
Purpose: Administer the operation of our Website and Apps, to allow you to use the services and functions of our Website, to conduct website maintenance, to troubleshoot problems, and to continually improve your experience when using our services.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring that all customers receive the best possible experience and improving our products and services offering in order to preserve our business operations.
Purpose: Provide you with services in accordance with the terms and conditions that govern our relationship with you.
Lawful basis: This processing is necessary to perform the contract between you and Tribe Fintech.
Purpose: To identify and send you marketing materials, news and information which we think will be of interest to you such as our latest promotional offers and upcoming services.
Lawful basis: This processing is necessary to perform the contract between you and Tribe Fintech. Tribe Fintech may also in certain situations have a legitimate interest to ensure that we are providing our customers with the opportunity to engage with us and participate in our promotional offers and be made aware of our upcoming products and services.
Purpose: Conducting screening, due diligence checks and verify your identity for the purposes of providing services as may be required under applicable laws, regulations or directives.
Lawful basis: Tribe Fintech considers that it has a legal obligation to ensure its business operates in accordance with applicable laws, regulations and directives.
Purpose: To detect, investigate and prevent fraud and other illegal activities.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in ensuring its business is not used for any fraudulent or illegal activities, and to protect our legal rights and interests.
Purpose: Use your personal information for purposes associated with our legal or regulatory rights and obligations, including financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes and for the purposes of seeking professional advice, including legal advice.
Lawful basis: Tribe Fintech considers that it has a legal obligation to ensure its business operates in accordance with applicable laws, regulations and directives.
Purpose: To keep internal records, decision making and facilitate internal purposes such as data analysis, and research to improve our services, service security and quality.
Lawful basis: This processing is necessary for the purpose of the legitimate interests pursued by Tribe Fintech. Tribe Fintech considers that it has a legitimate interest in continually improving our services in order to preserve and grow our business operations, and ensuring that you are provided with information relevant to you.
Purpose: To maintain opt-out and opt-in lists (including responding to customer requests to opt-out of direct marketing).
Lawful basis: This processing is necessary for the purpose of a legal obligation to which Tribe Fintech is subject in order to not provide direct marketing materials to individuals which have opted-out of, or opted-in to, receiving such communications.
Purpose: To develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them.
Lawful basis: Tribe Fintech considers that it has a legitimate interest in ensuring that you receive information about our products and services which may be of interest to you, this also helps us to preserve and grow our business operations.