For the purposes of this Privacy Notice, “Funding Societies”, “we”, “us”, or “our” refers to Funding Societies Pte Ltd., FS Capital Pte Ltd., FS Capital Singapore Pte. Ltd., CardUp Pte. Ltd. and its related corporations and affiliates operating in the capacity of a data principal or a data intermediary and “you”, “your” or “yours” means the natural persons to whom this Privacy Notice apply.
At Funding Societies, we respect your personal data, and we strive to ensure that your personal data is protected. The security of your personal data is important to us, and we shall maintain appropriate physical, technical, and organisational measures needed to ensure the security and confidentiality of your personal data. This Privacy Notice outlines how Funding Societies collects, uses, maintains, and discloses your personal data in respect of our services and how Funding Societies safeguards the personal data.
1.Collection of Personal Data
1.1Types of Personal Data We Collect: you may be asked to provide, and may continue from time to time to provide, information relating to yourself, including but not limited to:
(a)identification information, such as your name, identification number, nationality, date of birth, photographs and other information required to verify your identity;
(b)contact information, such as your residential or business address, telephone number and email address;
(c)financial and business information, including bank account details, income information, financial statements, creditworthiness information, transaction records and other information required for the provision of our products and services;
(d)technical and usage information, such as IP addresses, device identifiers, operating systems, browser types, website usage information, application usage information and other digital interaction data;
(e)audio, visual and communication records, including call recordings, CCTV recordings and correspondence with us; and
(f)any other information that you provide to us, or which is generated through your use of our products, services, websites, applications or platforms,
(collectively, "Personal Data").
1.2Sources of Personal Data: We may collect Personal Data directly from you or obtain it from a variety of sources, including:
(a)information provided by you during onboarding, account registration, financing applications or use of our products and services;
(b)your ongoing relationship and interactions with us;
(c)publicly available sources, public registries and databases;
(d)government agencies, regulators, law enforcement agencies and other authorities;
(e)credit bureaus, credit reporting agencies, identity verification providers and other third-party service providers;
(f)business partners, agents, intermediaries and referral partners;
(g)meetings, events, seminars, surveys, conferences and promotional activities organised or sponsored by us;
(h)CCTV systems installed at our premises; and
(i)our websites, applications and digital platforms, including information collected through cookies and similar technologies.
For the avoidance of doubt, product interaction data and crash data collected through our applications are not linked to your identity and are not used for tracking purposes.
1.3AI-Assisted Processing: To support onboarding, identity verification, credit assessment, fraud prevention, compliance monitoring, and operational efficiency, we may use artificial intelligence ("AI"), machine learning, and automated processing technologies. Such technologies may be used to:
(a)verify information and extract data from documents submitted by you, including identity documents, bank statements, and supporting documents;
(b)support credit, underwriting, fraud, risk, and compliance assessments;
(c)facilitate operational processing and workflow automation; and
(d)assist our personnel in making business, operational, and compliance-related decisions.
1.4Failure to Provide Personal Data: You may choose not to provide Personal Data to us. However, where the Personal Data is necessary for us to verify your identity, assess your application, comply with legal or regulatory obligations, or provide our products and services, failure to provide such Personal Data may result in us being unable to establish or maintain a relationship with you or provide you with our products and services.
2.Use of Personal Data
1.5We may collect, use, process, store, analyse, transfer, and disclose your Personal Data for the following purposes (collectively, the "Permitted Purposes") in Singapore and/or any other jurisdiction where we, our affiliates, or service providers operate:
(a)to assess, verify, and process your applications for our products and services;
(b)to establish, manage, administer, and maintain your accounts, facilities, and relationship with us;
(c)to communicate with you regarding your applications, accounts, transactions, enquiries, complaints, requests, and instructions;
(d)to provide customer support and operational assistance;
(e)to conduct credit, affordability, underwriting, financial risk, and suitability assessments;
(f)to conduct identity verification, know-your-customer (KYC), anti-money laundering (AML), sanctions screening, politically exposed person (PEP) screening, fraud detection, fraud prevention, and other compliance checks;
(g)to evaluate, monitor, and manage credit, operational, legal, regulatory, and reputational risks;
(h)to maintain and verify your credit history and related records;
(i)to use AI, machine learning, automated processing tools, and similar technologies to support:
(i)document verification and extraction of information from documents submitted by you, including identity documents, bank statements, and supporting documents;
(ii)credit assessment, underwriting, fraud detection, compliance monitoring, and risk assessment;
(iii)operational processing, workflow automation, quality assurance and internal business processes; and
(iv)the generation of recommendations, predictions, insights or risk indicators to assist our personnel in decision-making processes;
(j)to process Personal Data using AI-assisted systems and third-party technology providers engaged by us solely for the purposes described in this Privacy Notice;
(k)to conduct analytics, business intelligence, statistical analysis, market research, surveys and product development activities;
(l)to improve, enhance, develop, test and maintain our products, services, systems, platforms and operational processes;
(m)to support business planning, reporting, auditing, governance, compliance, monitoring, and decision-making;
(n)to verify information provided by you and maintain accurate and up-to-date records;
(o)to provide information about our products, services, promotions, events, and campaigns, products and services offered by our affiliates or business partners which may be of interest to the customers;
(p)to conduct strategic alliances, cross-selling activities, and business collaborations;
(q)to utilise the Personal Data for strategic alliances, cross-selling activities, marketing and promotions, which includes promoting and advertising products or services to the customer that are related to or complementary with the products and services of the Funding Societies group;
(r)to communicate with you through telephone calls, email, SMS, mobile applications, messaging platforms (including WhatsApp) and other communication channels;
(s)where you elect to receive authentication, security, or service-related communications through WhatsApp, to facilitate the delivery of one-time passwords (OTPs), verification codes, and notifications through WhatsApp and its affiliated service providers, including Meta Platforms, Inc. and its affiliates;
(t)to investigate, detect, prevent, or prosecute unlawful, fraudulent, suspicious, or prohibited activities;
(u)to enforce our contractual rights and obligations and to collect monies owed to us;
(v)to comply with any applicable law, regulation, regulatory requirement, court order, governmental request, industry guideline, or lawful request from any authority;
(w)to establish, exercise, or defend legal rights, claims, or proceedings;
(x)to ensure the security and integrity of our systems, networks, products, services, and premises;
(y)to facilitate any merger, acquisition, restructuring, financing, business transfer, assignment, or disposal involving us or our business;
(z)to outsource, delegate or subcontract any of our business functions, operations or services to service providers, affiliates or business partners; and
(aa)for any other purpose that is reasonably related to the foregoing or otherwise permitted or required by applicable law.
3.Artificial Intelligence, Automated Processing, and Third-Party Technology Providers
1.6To enhance the efficiency, security, and quality of our products and services, we may use AI, machine learning, automated data processing tools, and other technology solutions in connection with the Permitted Purposes. Such processing may include:
(a)document verification, identity verification, and extraction of information from documents submitted by you, including identity documents, bank statements, financial records, and supporting documents provided during onboarding, account maintenance, or credit assessment processes;
(b)credit assessment, underwriting, risk assessment, fraud detection, anti-money laundering screening, know-your-customer (KYC) verification, politically exposed person (PEP) screening and compliance monitoring;
(c)operational processing, workflow automation, data classification, quality assurance, customer support, internal business administration and process optimisation;
(d)generating recommendations, predictions, insights or risk indicators to assist our personnel in making business, operational, compliance or credit-related decisions.
1.7Where AI-assisted tools are used, decisions that may significantly affect you may be subject to appropriate human review, oversight or validation, where applicable.
1.8We may disclose or transfer Personal Data to third-party technology, cloud, analytics, software, AI, and automation service providers for the purposes described above. Such providers may process Personal Data on our behalf solely for the purposes authorised by us and subject to contractual, security, and confidentiality obligations.
1.9Unless otherwise notified to you or where required by law, we do not permit third-party AI service providers to use your Personal Data for the purpose of training their general AI models.
4.Disclosure of Personal Data
1.10We treat your Personal Data as confidential. However, for the Permitted Purposes and subject to applicable laws, regulations, and regulatory requirements, we may disclose, transfer, or make available your Personal Data to the following categories of recipients:
(a)Funding Societies Group: our holding companies, subsidiaries, related corporations, affiliates, associates and other companies within the Funding Societies group;
(b)Service Providers and Professional Advisers: our professional advisers, including legal advisers, auditors, accountants, consultants and other professional service providers, contractors, agents, vendors and service providers engaged by us to support our business operations, including technology providers, cloud service providers, data hosting providers, payment service providers, customer support providers, identity verification providers, document processing providers, communications providers, analytics providers, artificial intelligence service providers, debt collection agencies and other outsourced service providers;
(c)Credit, Risk and Financial Service Providers: credit bureaus, credit reporting agencies, credit reference agencies, rating agencies, insurers, insurance brokers, and other providers of credit, risk, compliance, or financial information services, financial institutions, payment service providers, and other financial service providers involved in the provision, administration, or servicing of products and services provided to you;
(d)Business Partners and Transaction Parties: our strategic partners, business partners and referral partners in connection with products, services, campaigns or collaborations involving us, any actual or proposed investor, funder, participant, assignee, transferee, purchaser or successor in relation to our rights, obligations, assets or business, any guarantor, security provider or other person providing support in relation to products or services granted to you;
(e)Regulators and Authorities: governmental authorities, regulatory bodies, law enforcement agencies, courts, tribunals, and other public authorities (whether in Singapore or elsewhere) where disclosure is required or permitted by law, regulation, court order, regulatory requirement, or lawful request;
(f)Enforcement and Protection of Rights: any person involved in the establishment, exercise, enforcement, protection, or defence of our legal rights, remedies, interests or claims;
(g)Other Authorised Parties: any person, organisation, or entity to whom you have provided your consent, authorisation, or instruction for such disclosure.
1.11Where we engage third-party technology providers, including artificial intelligence, automation, cloud computing, analytics, communication, or identity verification providers, such providers may process Personal Data on our behalf solely for the purposes authorised by us and subject to appropriate contractual, confidentiality, and security safeguards.
5.Access and Correction of Personal Data
1.12Subject to applicable law, you may request access to the Personal Data that we hold about you and request corrections to any Personal Data that is inaccurate or incomplete.
1.13If you wish to request access to or correction of your Personal Data, please contact our Data Protection Officer using the contact details set out below. We may require you to provide information or documentation to verify your identity and the authenticity of your request before processing the request.
1.14We reserve the right to charge a reasonable administrative fee where permitted by applicable law. We will respond to your request within a reasonable period and in accordance with applicable legal and regulatory requirements.
6.Withdrawal of Consent
1.15Where we rely on your consent to collect, use or disclose your Personal Data, you may withdraw such consent at any time by contacting our Data Protection Officer in writing.
1.16Upon receiving your request, we may require a reasonable period of time to process the withdrawal and inform you of the consequences of withdrawing your consent.
1.17Please note that depending on the nature and scope of the withdrawal, we may no longer be able to provide certain products, services, functionalities or support to you, and we reserve the right to terminate or restrict our relationship with you where necessary to comply with our legal, regulatory or contractual obligations.
1.18Notwithstanding any withdrawal of consent, we may continue to retain, use, process or disclose Personal Data where required or permitted by applicable law, regulatory requirements, legal proceedings, risk management, fraud prevention, record retention obligations or the establishment, exercise or defence of legal claims.
7.Security of Personal Data
1.19We implement reasonable administrative, physical, organisational and technical safeguards designed to protect Personal Data under our possession or control against unauthorised access, collection, use, disclosure, copying, modification, loss, misuse or similar risks.
1.20Where we engage third-party service providers, including cloud, technology, communication, analytics, identity verification, automation, and artificial intelligence service providers, we take reasonable steps to require such providers to implement appropriate security and confidentiality measures to protect Personal Data processed on our behalf.
1.21While we endeavour to protect Personal Data, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.
8.Contacting Us
If you have any questions, concerns, complaints or requests relating to this Privacy Notice or our handling of your Personal Data, please contact our Data Protection Officer:
Telephone: +65 6221 0958
Email: dpo@fundingsocieties.com
9.Changes to this Privacy Notice
1.22We may amend, update or revise this Privacy Notice from time to time. Any updated version will be made available through our website or other appropriate channels.
1.23Your continued use of our products or services following the publication of any revised Privacy Notice constitutes your acknowledgement of the updated Privacy Notice to the extent permitted by applicable law.
10.Acknowledgement and Third-Party Personal Data
1.24By providing Personal Data to us, you acknowledge that your Personal Data may be collected, used, processed, disclosed, and transferred in accordance with this Privacy Notice.
1.25Where you provide us with Personal Data relating to another individual, including directors, shareholders, beneficial owners, employees, authorised signatories, representatives, guarantors or other related persons, you represent and warrant that you have obtained all necessary consents, authorisations and permissions, or otherwise have lawful authority, to provide such Personal Data to us and to permit us to collect, use, process and disclose such Personal Data in accordance with this Privacy Notice.
11.Cookies and Similar Technologies
We may use cookies, web beacons, software development kits (SDKs), pixels and similar technologies ("Cookies") when you visit or use our websites, mobile applications, platforms and other digital services (collectively, the "Site"). Cookies help us operate the Site, improve functionality, understand how users interact with the Site, enhance security and provide a more personalised user experience.
1.26What are Cookies?
Cookies are small text files that are stored on your device when you visit a website or use an application. Cookies enable websites and applications to recognise your device, remember your preferences and improve your user experience.
1.27Types of Cookies We Use
We may use the following categories of Cookies:
(a)Essential Cookies: These Cookies are necessary for the operation of the Site and enable core functionality such as account authentication, security, fraud prevention, session management, and accessibility. Without these Cookies, certain features of the Site may not function properly.
(b)Performance and Analytics Cookies: These Cookies help us understand how visitors interact with the Site by collecting information such as pages visited, traffic sources, user journeys, and system performance. This information is generally aggregated and used to improve the performance, functionality, and user experience of the Site.
(c)Functional Cookies: These Cookies allow the Site to remember your preferences and settings, such as language preferences, login information, and other customised features, to provide a more personalised experience.
(d)Advertising and Marketing Cookies: These Cookies may be used to deliver relevant advertisements, measure the effectiveness of advertising campaigns, and understand your interests based on your interactions with our Site and services.
(e)Security Cookies: These Cookies help detect and prevent security risks, fraudulent activity, unauthorised access, and misuse of our products and services.
1.28Third-Party Cookies
We may use third-party service providers, including analytics, advertising, social media, communication and technology providers, which may place Cookies or similar technologies on your device. Examples may include providers such as Google, Meta (Facebook and Instagram), LinkedIn, TikTok and other analytics, advertising or technology partners. These third parties may collect information directly from your device in accordance with their own privacy policies. We do not control the collection or use of information by third-party providers and encourage you to review their respective privacy notices and cookie policies.
1.29Managing Your Cookie Preferences
Most web browsers and mobile devices allow you to manage, block or delete Cookies through your browser or device settings. If you disable certain Cookies, some features, functionality or services on the Site may become unavailable or may not function properly.
1.30Links to Third-Party Websites
The Site may contain links to third-party websites, applications or platforms. We are not responsible for the privacy practices, content or policies of such third parties. We encourage you to review the privacy notices and cookie policies of any third-party websites you visit.
1.31Personal Data Collected Through Cookies
Where information collected through Cookies constitutes Personal Data under applicable law, such information will be collected, used, disclosed, and protected in accordance with this Privacy Notice.
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