1. INTRODUCTION

This Privacy Policy sets out the policy of Asia Focus Group Pte. Ltd.(“Consentium”) regarding the collection, use, and disclosure of any information you may provide when you access and use its [mobile application/website] (the “Consentium Platform”), or the services Asia Focus Group Pte.Ltd. offers in relation thereto (each, a “Service”, collectively, the “Services”). It is intended to be read together with Asia Focus Group Pte. Ltd.’s Terms of Service.

BY ACCESSING AND USING THE CONSENTIUM PLATFORM, YOU ARE DEEMED TO HAVE READ, ACCEPTED, AND AGREED TO BE LEGALLY BOUND BY THE TERMS OF THIS PRIVACY POLICY AND ASIA FOCUS GROUP PTE. LTD.’S TERMS OF SERVICE. IF YOU DO NOT ACCEPT ANY PART OF THIS PRIVACY POLICY, PLEASE IMMEDIATELY DISCONTINUE YOUR ACCESS TO AND USE OF THE CONSENTIUM PLATFORM AND ALL SERVICES.

We may amend this Privacy Policy from time to time at our sole discretion without being obliged to notify you in advance. It is your responsibility to check this page periodically for changes to this Privacy Policy. By continuing to use the Services following such amendments to this Privacy Policy, you agree to be bound by such amendments.

This Privacy Policy does not apply to third party websites you may access through, or in the course of your use of the Consentium Platform. Your rights in relation to those third parties will be governed entirely by the privacy statements and/or terms and conditions of those third-party websites.

This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of Singapore. You agree to submit all disputes arising out of or in connection with these Terms of Service to the exclusive jurisdiction of the Singapore courts.

2. COLLECTION OF INFORMATION

When you access or use the Consentium Platform or any part thereof, or communicate with Consentium or any of its officers, employees, or agents, whether through written, published or electronic means, the telephone or otherwise, Consentium may collect or receive personal or non-personal information or data about, in connection with, or from you, including, without limitation, through cookies, pixel tags, website and data analytics, and other technologies, in accordance with the Personal Data Protection Act 2012 (“PDPA”).

Personal information or data may include, without limitation, your name, contact information, user profile, national identity information, and information about your financial status. Non-personal information or data may include, without limitation, your browser information, internet protocol (IP) address, how you use the Consentium Platform or any part thereof, and aggregated information. Consentium will, as far as possible, inform you at each collection point as to what information is required and what information is optional.

3. USE OF INFORMATION

Consentium uses the collected information set out above:

• for the specific purpose for which the information was provided;
• to confirm your identity and ensure that you are eligible to access and use the Services provided on the Consentium Platform;
• to process and, where necessary, respond to your application(s), enquiry(s), or request(s);
• for the purposes of accessing any Services provided by Consentium, including transmission to third party agents;
• to conduct due diligence checks on you in accordance with all applicable laws and Consentium ’s internal ‘know your client’ and Anti-Money Laundering/Countering the Financing of Terrorism policies;
• to enable Consentium to comply with all of its legal and regulatory obligations under the applicable law;
• to inform or update you about Services that you request from Consentium or that may interest you, where you have consented to be contacted for such purposes;
• to update you on changes to the Consentium Platform or Consentium’s operations;
• to monitor, improve, and administer the Consentium Platform and the Services provided through it;
• to conduct statistical or other forms of analysis for purposes of maintaining or improving the Consentium Platform and Consentium’s services in general; or
• to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency.

4. DISCLOSURE OF INFORMATION

Consentium will not sell or rent your personal information to any third party. Information you provide to Consentium will only be disclosed to third parties where:

• you have expressly or implicitly consented to such disclosure, or may be deemed to have consented to such disclosure;
• necessary to provide you with the Services you have requested for, or to respond to your queries;
• necessary for the operation of Consentium or Consentium’s internal processes;
• required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
• Consentium believes, in good faith, that doing so will be appropriate or necessary for it to investigate and defend against any third-party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Consentium Platform, Consentium’s interests, or any Consentium’s employee or affiliate;
• Consentium is the subject of a takeover and your personal information forms part of Consentium’s assets to be transferred to the acquiring entity; or
• you disclose such information to third parties in the course of participating in any promotional program on the Consentium Platform.

5. SECURITY

Consentium has implemented, and will continue to maintain, security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of your information. Nevertheless, you acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to Consentium is done so at your own risk. Consentium does not warrant or guarantee that the information you provide will not be accessed, copied, used, or disposed of in breach of Consentium’s security measures, and you agree not to hold Consentium liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, Consentium will, as far as reasonably possible, promptly notify all affected persons. You accept that you are responsible for keeping any sensitive information confidential, including, without limitation, your username and password to your account with Consentium.

6. WEB-RELATED INFORMATION

Consentium may collect certain information from you without you actively providing the information when you navigate the Consentium Platform via cookies. Cookies are small data text files stored in your local browser cache that send information about your previous visits to and activities on the Consentium Platform. These cookies will not give Consentium any personal information about you. Consentium reserves the right to use the cookies to recognize your browser and thereby customise and optimize the Consentium Platform to your preferences.

You can accept or delete cookies. For security reasons, you may wish to deactivate the storing of cookies or adjust your browser to inform you before the cookies are stored on your computer. However, please note that if you do erase or block the cookies, you may not be able to utilize some features on the Consentium Platform. In such situations, Consentium shall not be held liable for any loss or damage resulting from your inability to use those features

Consentium may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). Consentium collects your IP address in order to facilitate its administration and improvement of the Consentium Platform.

The information derived from your IP address can help Consentium diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Consentium Platform.

We use the following cookies in the course of providing our Services.

• Strictly necessary cookies. These are cookies that are required for the operation of the Consentium Platform. They include, for example, cookies that enable you to log into secure areas of the Consentium Platform.
• Analytical/performance cookies. They allow Consentium to recognise and count the number of visitors and to see how visitors move around the Consentium Platform when they are using it. This helps Consentium to improve the way the Consentium Platform works, for example, by ensuring that users are able to use custom features.
• Functionality cookies. These are used to recognise you when you return to the Consentium Platform. This enables Consentium to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to the Consentium Platform, the pages you have visited and the links you have followed. Consentium will use this information to make the Consentium Platform more relevant to your interests. Consentium may also share this information with third parties for this purpose.

7. NOTIFICATIONS & COMMUNICATIONS

Consentium may send you email notifications from time to time. You may not opt out of receiving certain service-related notifications that are:

• necessary elements of your transactions on the Consentium Platform and any Service of Consentium, such as confirmations of particular actions you have taken;
• are required for legal or security purposes; or
• meant to inform you of changes to Consentium Platform policies or Consentium ’s operations or Services.

You may, through written notice to Consentium, opt out of other service-related notifications at any time, including:

• information updates issued by Consentium;
• user surveys or other requests for user feedback; or
• marketing offers from Consentium or that sent by Consentium on behalf of third parties in the course of providing the Services to you.

Consentium may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and Consentium, including for purposes of resolving queries in the future or of ensuring security, staff training, and compliance with its legal and regulatory responsibilities.

8. TRANSFER, STORAGE, AND RETENTION OF INFORMATION

Information collected in accordance with this Privacy Policy may be transferred, stored, or processed outside of Singapore. Consentium will comply with its obligations under the PDPA and Personal Data Protection Regulations 2014 in relation to personal data transferred, stored, or processed outside Singapore for as long as the data remains in Consentium’s possession or control during the transfer. Consentium will take all reasonable steps to ascertain that the recipient of the personal data who is located outside Singapore is legally obliged to provide to the personal data a comparable a standard of protection

However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore, in order to provide you with the Services, you are deemed to consent to such transfer, storage, or processing in providing your personal data to Consentium during your use of the Consentium Platform. You may, at any time, inform Consentium that you wish to withdraw your consent to such transfer, storage, or processing of your personal data.

Consentium will retain all information collected for as long as you continue to use the Consentium Platform or the Services. If you are a member and terminate your Consentium account, Consentium will retain the information, including personal data, collected during your membership for as long as reasonably necessary for any business or legal purposes.

9. YOUR RIGHTS

You have the right to ask Consentium not to process your personal data for marketing purposes. Consentium will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing through written notice to Consentium at [email protected] net.

The Consentium Platform may, from time to time, contain links to and from the websites of its partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Consentium does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

You may choose to stop receiving or change the frequency of email, direct mail, phone, and mobile marketing communications. You can update and correct your personal information anytime using by sending Consentium a message via the Consentium Platform or by contacting Consentium at [email protected] net.