Privacy Policy

The “MVGX Group” is committed to protecting and respecting your privacy.

For the purposes of this Policy and the Personal Data Protection Act 2012 (“the Act” ), “Personal Data” as defined in section 2 of the Act means 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 the organization has or is likely to have access.

The MVGX Group consists of the following entities:-

References in this Policy to the “MVGX Group”, “company”, “we”, “us” or “our” shall refer to any one of the aforesaid entities as the case may be while references to “you” shall mean any person subject to any persons.

This Policy (together with any published terms of use or terms of services together with and any other documents referred to on it) shall set out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it. By visiting, accessing or using any MVGX Group website and associated application program interfaces or mobile applications (the “MVGX Group Platform”), you (a) acknowledge that you have the right, capacity and authority to accept this Policy; (b) acknowledge that you have read and understood this Policy and (c) consent to the policies and practices outlined in this Policy.

A. COLLECTION OF DATA

1. Information We May Collect from You

(a) Information you give us. You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website and when you report a problem with our website. The information you give us may include your name, address, e-mail address and phone number.

(b) Information we collect about you. Regarding each of your visits to our website we may automatically collect the following information:

(i) technical information, including the Internet protocol address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(ii) information about your visit, including the full Uniform Resource Locators clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

(c) Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that Personal Data that it may be shared internally and combined with Personal Data collected on this website. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

2. Cookies

(a) Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. For detailed information on the cookies we use and the purposes for which we use them for, please visit our Cookies Policy published on our websites.

B. USE OF DATA

3. We use information held about you in the following ways:

(a) Information you give to us. We will use this information:

(i) to carry out our obligations arising from any contracts entered between you and us and to provide you with the information, products and services that you request from us;

(ii) to provide you with information about other services that we offer that are similar to those that you have already used or enquired about;

(iii) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or phone) with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your Personal Data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your Personal Data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your Personal Data (the [order form OR registration form]);

(iv) to notify you about changes to our services;

(v) to ensure that content from our website is presented in the most effective manner for you and for your computer;

(vi) Other uses include but are not limited to, the following:-

(1) to help us identify you and any accounts you hold with us;

(2) administration;

(3) research, statistical analysis and behavioural analysis;

(4) customer profiling and analysing your consumer preferences;

(5) marketing;

(6) fraud prevention and detection;

(7) billing and order fulfilment;

(8) credit scoring and credit checking;

(9) customising our website and its content to your particular preferences;

(10) to notify you of any changes to our website or to our services that may affect you;

(11) security vetting;

(12) improving our services.

(b) Information we collect about you. We will use this information:

(i) to administer our website and for internal operations, including troubleshooting, data analysis, testing, research and statistical purposes;

(ii) to improve our website to ensure that content is presented in the most effective manner for you and for your computer;

(iii) to allow you to participate in interactive features for our service, when you choose to do so;

(iv) as part of our efforts to keep our website safe and secure;

(c) Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

C. DISCLOSURE OF YOUR INFORMATION

4. We may share your personal information with any member of the MVGX Group, which includes our subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives, as it may be necessary for the provision of any products and/or services to you.

5. We may share your information with selected third parties including but not limited to:

(a) business partners and vendors for the performance of any contract we enter into with them or you or permitted by law or professional standards including, for example, payment processing, customer support, information technology, data analytics, data processing, network infrastructure, storage and tax reporting;

(b) entities in connection with corporate transactions involving MVGX Group, including any financing, acquisition or dissolution proceedings which involve disclosing a certain portion or all of our business or website;

(c) should there be a need, credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;

(d) in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; or

(e) if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our any of our terms and conditions relating to any products or services that we are providing to you or any terms under any agreements we have entered into; to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies for the purpose of our anti-money laundering and counter-terrorism financing obligations.

6. Sending Information to Other Countries

(a) MVGX Group operates a global business and Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may disclose information to third party storage providers or affiliates that are located outside your country of residence or disclose to third-party storage providers or affiliates that are located outside your country or residence.

(b) We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. By communicating electronically with us, you acknowledge and agree to your Personal Data being processed in this way.

D. STORAGE OF YOUR INFORMATION

7. How We Store Your Personal Data

(a) We recognise the importance of securing the Personal Data of our users. We take steps to ensure that your Personal Data is protected from misuse, interference or loss, and unauthorised access, modification or disclosure. Your Personal Data is generally stored in our or our affiliates’ computer databases and/or with third party storage providers.

8. Where We Store Your Personal Data

(a) The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by an employee operating outside Singapore who work for us or for one of our affiliates. Such employee may be engaged in, among other things, the provision of support services. By submitting your Personal data, you agree to this transfer, storing or processing. We will generally take appropriate steps to ensure that the recipient of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA (“Comparable Standard”). To this end, we will ensure that at least one of the following measures is implemented:

(i) you consent to such transfer after you have been given a reasonable summary in writing of the extent to which your Personal Data to be transferred will be protected to a Comparable Standard (including but not limited to this Policy);

(ii) the overseas recipient of such Personal Data is bound by law, contract, binding corporate rules or any other legally binding instrument to protect the transferred Personal Data to a Comparable Standard; and/or

(iii) the overseas recipient of such Personal Data holds a valid certification under the Asia Pacific Economic Cooperation Cross Border Privacy Rules (“APEC CBPR”) System or the Asia Pacific Economic Cooperations Privacy Recognition for Processors (“APEC PRP”) System.

(b) Where the above measures are not feasible, we may still proceed with the transfer of your Personal Data from Singapore to a recipient outside of Singapore if:

(i) the transfer is necessary for a use or disclosure that is in your vital interests or in the national interest and we have taken reasonable steps to ensure that the Personal Data will not be used or disclosed by the recipient for any other purpose; and/or

(ii) the transfer is reasonable necessary for the conclusion or performance of a contractual obligation between you and us.

(c) Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. You should not share your password with anyone.

(d) We cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

(e) If we have credible grounds to believe that a data breach has occurred, we will take steps to assess if the data breach is notifiable under the PDPA. Once we assess that a data breach is a notifiable data breach, we will notify the Personal Data Protection Commission of Singapore and you as soon as it is practicable. If we share your Personal Data with our third party service providers, we will require them to process it strictly in accordance with our instructions or as otherwise required by the PDPA.

9. Retention of Personal Data

(a) We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as requested or permitted by applicable laws.

(b) We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes. For example, we are subject to certain anti-money laundering laws and/or regulations which require us to retain records we used to comply with our client identification and due diligence obligations for an additional period after our business relationship with you has ended.

10. Information Security

(a) We have put in place appropriate information security measures to prevent your Personal Data from being accidentally lost, accessed, altered, disclosed, used or destroyed in an unauthorized way (or other similar risks). We take various measures to ensure information security, including encryption of the MVGX Group Platform communications; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.

E. YOUR RIGHTS

11. Access to Your Information and Accuracy of Your Information

(a) The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act.

(b) If you would like to request for a copy of some or all of your Personal Data, please send an email to us. We will require identity verification and specification of what information is required before providing you with access. Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service. We will provide access within thirty (30) calendar days of your request. In exceptional circumstances, we reserve the right to deny you access to your information and may provide you with an explanation as required by applicable laws.

(c) We may also request you to update your Personal Data. We want to ensure that your Personal Data is accurate and up to date and seek your assistance to ensure that such information is current, complete and accurate. If any of the information that you have provided to us changes, please let us know the correct details by sending an email to us.

(d) You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.

12. Marketing and Opting Out

(a) MVGX Group may also wish to provide you with information about special features of our website or any other service or product we think may be of interest to you. If you prefer not to receive any further direct marketing communications from us or our business partners, please contact us any time to opt-out.

(b) We may also want to provide you with related information from third parties we think may be of interest to you. If you would rather not receive this information, please contact us to inform us otherwise.

(c) We may also provide your information to carefully selected third parties whose products or services we believe may be of interest to you. If you do not wish us to disclose your information in this way, please contact us to inform us otherwise.

If you would like to withdraw your consent to the above, please contact us at the contact details stated above.

F. CHANGES TO OUR PRIVACY POLICY

13. You shall be deemed to have agreed to the terms under this Policy unless you specifically notify us by email.

(a) We may revise this Policy from time to time without any prior notice. Any changes we may make to our privacy policy in the future will be posted on this page and you shall be deemed to have agreed to any such changes should you continue to use any of the MVGX Group’s products and services.

(b) It is your responsibility to check back this page frequently to see any updates or changes to our Policy.

G. EXTERNAL WEBSITES

14. The MVGX Group Platform contains links to external websites. We make no representations as to the quality, suitability, functionality or legality of the material on external websites that are linked to, or to any goods and services available from, such websites. The material is only provided for your interest and convenience. We do not monitor or investigate such external websites and we accept no responsibility or liability for any loss arising from the content or accuracy of the material and any opinion expressed in the material should not be taken as our endorsement, recommendation or opinion. This Policy does not extend to your use of such external websites. You are advised to read the privacy policy or statement of such external websites before using them.