At Refind, we take online privacy very seriously and we respect the concerns and privacy of our online community of users. In this policy, we describe our privacy practices with regard to information we collect through Refind .today (the “Site”), to help you make informed decisions about how you share information when you visit or use the site and its app platform (the “App”), as well as your rights in determining what we do with the information that we collect or hold about you.

 
This Privacy Policy (the “Policy”) was updated on 22 February 2022. Please review this Policy to note the changes.

 This Policy applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from services offered by Refind and Refind Pte. Ltd (collectively referred to as “Refind ”).

1. General

1.1 This Policy statement provides information on the obligations and policies of Refind  in respect of a user’s Personal Data, whereby the user may be browsing the Refind website without registering for an account, as a registered user, customer or as a service provider. Refind  undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

 

1.2 Refind’s officers, management, and members of staff shall use reasonable endeavors to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, Refind . Refind  shall use reasonable endeavors to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by Refind  shall be done in an appropriate manner and in accordance with the Act and this Policy.

 

1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Refind  as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “Refind “, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Refind’s authorized service providers and relevant third parties in the manner set forth in this Policy.

 

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

 

1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Refind  or that which shall be collected by Refind  in the future.

 

2. Contacting the Data Protection Officer

2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Refind , Refind  shall provide and/or correct that data within thirty (30) days and in a manner in accordance with its standard procedures as stated hereinafter.

 

2.2 In accordance with the Act, Refind  has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Refind  receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of Refind  at the following email address: Refindsg@gmail.com

 

2.3 Please note that if your Personal Data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to Refind  on your behalf.

 

2.4 Should you not wish Refind  to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from Refind , you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within thirty (30) days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.

 

3. Statement of Practices

 

Types of Personal Data Collected

3.1 As part of its day-to-day activity, Refind  may collect from you, through various means, including via our websites, and any other forms used by Refind  from time to time, some or all of the following Personal Data:-

  • First and last name;

  • Postal Address;

  • Phone number (mobile and/or home number);

  • Office number;

  • Fax number;

  • Email address;

  • Bank account/credit card details;

  • Gender;

  • Personal Data of your emergency contacts;

  • Previous and present employment;

  • Education;

  • IP addresses; and

  • Photographs and images;

Cookies

We use cookies on our websites to track website visitorship and experience. Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse it.

 

How Refind May Use Information We Collect 

3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of:-

 

  • Tracking and monitoring the usage of the site; 

  • Provide products and services you request (such as when you sign up to receive our email newsletters);

  • Respond to requests, questions, and comments, and provide other types of user support;

  • Offer you products and services via marketing communications, or direct you to portions of this Site or other websites, that we believe may interest you;

  • To serve advertising, content and offers to you based on your interests and online activities, from us or third parties;

  • Communicate about, and administer your participation in, events, programs, contests, and other offers or promotions;

  • Carry out, evaluate, and improve our business (which may include developing new features for the Site; analyzing and enhancing the user experience on the Site; assessing the effectiveness of our marketing and advertising; and managing our communications);

  • Perform data analytics regarding usage of the Site (including market and customer research, trend analysis, and financial analysis;

  • Guard against, identify, and prevent fraud and other criminal activity, claims, and other liabilities; and

  • Comply with applicable legal requirements, law enforcement requests, and our company policies.

  • Generating user information which will help to improve the features and functionality of our website, or creating new features, functionalities and services available on our website;

  • Providing notices and/or contacting you via email or your user account in relation to your user account, regarding updates to our Terms and Conditions, this Policy, changes to your user account, or for other customer service purposes;

  • Informing you of new developments and services of other third parties which we are associated with;

  • Connecting you to other users and/or service providers on our website which may be of relevance and/or interest to you;

  • Generating user information which will help to improve the design and quality of our website;

  • Investigating illegal activities, if any, being carried out on our website that violates our Terms and Conditions;

  • Detecting, addressing and/or preventing technical issues which may arise on our website;

  • Customizing advertising which you may see when using our website and/or third party websites;

  • Identification purposes;

  • Conducting market research and client surveys to enhance the provision of our services; and

  • Measuring the performance of marketing campaigns carried out by us and providing you with marketing from third parties, if any.

How Refind May Share Information 

3.3 In order to carry out the functions described above, Refind may, from time to time, disclose your Personal Data between Refind’s companies.

 

3.4 Without derogating from any of the above, Refind  may also disclose your Personal Data to the following third parties:-

 

  • Regulators and law enforcement officials;

  • Lawyers;

  • Auditors;

  • Third party service providers and consultants;

  • Credit, debit and charge card companies, banks and other entities processing payment;

  • Potential buyers or investors of Refind  or any of Refind ’s companies; and

  • Any agent or sub-contractor acting on Refind ’s behalf for the provision of Refind ’s services.

3.5 Refind may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:-

 

  • To the extent that Refind is required to do so by the law;

  • In connection with any legal proceedings or prospective legal proceedings;

  • To establish, exercise or defend Refind’s legal rights;

  • To the purchaser (or prospective purchaser) of any business or asset which Refind is (or is contemplating) selling;

  • To any person and/or entity for the purpose of processing such information on Refind’s behalf;

  • To third parties who provide services to Refind  or on its behalf;

  • To third parties who Refind provides services to;

  • To any third party that purchases Refind or Refind ’s business or any part of Refind  or Refind’s business;

  • With your consent; and

  • For the purposes of disaster recovery.

Optional Provision of Personal Data

3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve Refind ’s services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalized service dependent on your providing all requested data, failure to provide the requested data may prevent Refind from providing the service to you. This type of data includes, but is not limited to:-

 

  • Your first and last name;

  • Your age;

  • Your gender;

  • Your race;

  • Your geographic location;

  • Your telephone number;

  • Your email address;

  • Particulars of next of kin;

  • Employment details;

  • Present/ past employment history;

  • Hobbies and leisure activities; and

  • Other related products and services subscribed to.

3.7 Under certain circumstances, telephone calls made to any of Refind’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or transaction, and for quality control and training purposes.

 

4. Transfer of Personal Data Overseas

Your Personal Data may be processed by Refind, its affiliates, agents and third parties providing services to Refind , in jurisdictions outside of Singapore. In this event, Refind will comply with the terms of the Act.

 

5. Accuracy of Personal Data

Where possible, Refind will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Refind is able to validate the data provided against pre-existing data held by Refind . In some cases, Refind is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Refind, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.

 

6. Protection of Personal Data

Refind uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Refind, other than to you or as described in this Policy. However, Refind  cannot ensure or warrant the security of any information you transmit to Refind  and you do so entirely at your own risk. In particular, Refind does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Refind ’s physical, technical, or managerial safeguards.

 

7. Access and Correction of Personal Data

7.1 In accordance with Clause 2.1 of this Policy, you have the right to:-

a. check whether Refind  holds any Personal Data relating to you and, if so, obtain copies of such data; and

b. require Refind  to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.

 

7.2 Refind  reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within thirty (30) days.

 

7.3 If you wish to verify the details you have submitted to Refind  or if you wish to check on the manner in which Refind  uses and processes your data, Refind ’s security procedures means that Refind  may request for proof of identity before we reveal information. This proof of identity will take the form of full details of your name, the last 4 characters of your NRIC or Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which Refind  takes in response to a request from someone using the aforementioned details.

 

8. Storage and Retention of Personal Data

Refind will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Refind, and where the Personal Data is deleted from Refind ’s electronic, manual, and other filing systems in accordance with Refind ’s internal procedures and/or other agreements.

 

9. Contacting you

To the extent that any of the communication means which you have provided Refind  with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by checking the applicable box, or by any other means of indication, you hereby grant Refind  your clear and unambiguous consent to contact you using all of your communication means you have provided Refind, including using via voice calls, SMS, WhatsApp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of Refind ’s services.

10. Change Policy

Refind reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Refind. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

11. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.

12. Miscellaneous

12.1 This Policy only applies to the collection and use of Personal Data by Refind  and its app. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Refind does not share your Personal Data with third party websites. Refind  is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.

 

12.2 Refind  will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to Refind ’s website.

 

12.3 Refind ’s websites do not target and are not intended to attract children under the age of 18 years old. Refind  does not knowingly solicit, collect or maintain personal information from children under the age of 18 years old or send them requests for personal data. If you are under the age of 18 years old, please cease your access and usage of our website at any time or man