The Mobile Application is a platform for financial consultants, who are part of Professional Investment Advisory Services (PIAS) network, or Infinity Wealth Management Group Pte Ltd, to upload and manage their client data. i-NITIATE Pte. Ltd. and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as “we”, “us” or “ours”) pledge to meet fully with the requirements of the Personal Data Protection Act 2012 (the “PDPA”). In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via https://iwm.com.sg/i-nitiate/account/login, its sub-domains, and any other websites, media platforms, or applications including the Mobile Application operated by us (hereinafter collectively referred to as “our Channels”) and we will not release such information to anyone without the consent of the relevant user(s) of our Channels (whether registered or not) (the “User” or the “Users”), except to the authorised persons listed in Paragraph 3 below.
1. Purpose of Collection of Personal Data
- In the course of using our Channels, you may disclose or be asked to provide personal information and/or data. In order to benefit from and enjoy the various services offered by our Channels, it may be necessary for you to provide us with your personal information and/or data. Although you are not obliged to provide the information and/or data as requested on our Channels, we will not be able to render certain services on our Channels in the event that you fail to do so.
- Our purposes for collection of information and data on our Channels include but are not limited to the following
- to ensure that content from our Channels is presented in the most effect manner for the User and his or her mobile and / or computer;
- to provide the User with information, product or services that the User may request from us or which we feel may interest the User, where such User has consented to being contacted for such purposes;
- to carry out our obligations arising from any contracts entered into between the User and us;
- to notify Users about any changes to our services;
- to perform the daily operation of the services provided to Users, including the implementation of a loyalty program;
- to provide Users with marketing and promotional materials of any events or seminars organised by us;
- to identify Users who have enjoyed their benefits as members of our Channels by receiving and using marketing and promotional materials;
- to allow Users to participate in interactive features of our services on our Channels, where such Users choose to do so;
- to enable us to select and present information that matches the needs of Users or to create personalised content;
- to design and provide products and services to Users in relation to the above purposes;
- to facilitate our use of Users’ personal data for purposes relating to the provision of services offered by us and marketing services, special events, and/or our promotions; and
- to provide measurement, analytics and other business services in relation to the provision of products and services offered by us.
- We strive to collect only personal data which is necessary and adequate but not excessive in relation to the purposes set out above.
- If you are under the age of 18, we strongly recommend that you seek prior consent from a parent or guardian, who may contact us at email@example.com to assist with your registration as a member of our Channels.
- If we require your personal data for a purpose other than those set out above, we may request your prescribed consent to the same. If you are a minor, the prescribed consent should be given by his or her parent or guardian.
2. Collection of Personal Data
- We may collect and process the following data about you:
- Information submitted by you when filling in forms on our Channels. This includes information provided at the time of registering to use our Channels, subscribing to our service, posting material or requesting further services. We may also ask you for information when you report a problem with our Channels.
- If you contact us, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of the products or services you have purchased from us through our Channels or otherwise.
- Details of transactions you carry out through our Channels or when purchasing our products or services, including your policy details, credit card and banking details for the purchase of any of our products or services.
- Details of your visits to our Channels and the resources that you access.
- Only our duly authorised staff will be permitted to access your personal information and data, and we will not release such personal information and data to any third party, save and except for the circumstances listed out under the Paragraph 3 entitled “Disclosure or Transfer of Data”.
- You are required to seek consent from a third party prior to submitting information or data on our Channels relating to such persons. You hereby agree to indemnify us from and against any and all claims, losses, liabilities, costs and expenses (including but not limited to legal costs and expenses on a full indemnity basis) made against or suffered or incurred by us arising directly or indirectly out of your failure to seek consent from a third party prior to submitting their information onto our Channels.
3. Disclose or Transfer of Data
- We will take all practicable steps to keep all your personal information and data confidential and/or undisclosed, subject to the following conditions.Generally speaking, we will only disclose and/or transfer your personal information and/or data to our personnel and staff, and any member of our group, which includes our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap 50), for the purpose of providing services through our Channels to you. However, we may disclose and/or transfer such information and/or data to third parties under the following circumstances:
- where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorised by us to use such information and/or data and who will facilitate the services on our Channels, under a duty of confidentiality;
- where the information and/or data is disclosed and/or transferred to any agents or our associates who have been duly authorised by us to use such information and/or data;
- where we need to protect and defend our rights and property;
- where we consider necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on our Channels and/or us;
- where we deem necessary in order to maintain and improve the services on our Channels;
- 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; and
- if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our clients will be one of the transferred assets.
- Personal data collected via our Channels may be transferred, stored, and processed in any country in which we operate. By using our Channels, you are deemed to have agreed to, consented to, and authorised us to disclose and/or transfer his or her personal information and data under the circumstances stated above, as well as to any transfer of information outside of your country.
- You are entitled to request access to or make amendments to your own personal information and data kept with us by contacting our Customer Service Representative at firstname.lastname@example.org.
- In the event that you wish to access or amend your personal information and data, we may request you to provide personal details in order to verify and confirm your identity. An identity card number or passport number or company registration number cannot be amended unless such data is proved to be inaccurate. Any access request you make may be subject to a fee of S$10.00 to meet our costs in providing you with details of the information we hold about you.
5. Cookies and Log Files
- We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our portal. They include, for example, cookies that enable you to log into secure areas of our portal, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our portal when they are using it. This helps us to improve the way our portal works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our portal. This enables us to personalise our 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 our portal, the pages you have visited and the links you have followed. We will use this information to make our portal and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- You may choose to block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our portal.
- Except for essential cookies, all cookies will expire after 60 days.
- The security of your personal information and data is important to us. We will always strive to ensure that your personal information and data is protected against unauthorised access. We have implemented appropriate electronic and managerial measures in order to safeguard, protect, and secure your personal information and data.
- Once have received your personal information and data, we will use strict procedures and security features, both during transmission and once we receive it, to prevent unauthorised access. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to protect your personal information and data against unauthorised access, we cannot guarantee its absolute security.
7. Retention of Personal Data
Once we have obtained your personal information and/or data, it will be maintained securely in our system. Subject to legal requirements, your personal information and/or data will be retained by us after deactivation of the relevant service until you provide us a request in writing to erase your personal information and/or data from our database or to terminate your membership of our Channels.
8. User Rights
You also have the right, by notice in writing, to inform us on your withdrawal (in full or in part) of your consent given previously to us subject to any applicable legal restrictions, contractual conditions and a reasonable duration of time for the withdrawal of consent to be effected. However, please note that your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us or the contract that you have with us may be terminated.
9. Partner websites
Our Channels may, from time to time, contain links to and from the websites of our 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 we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information or data to these websites.
11. Governing Law and Jurisdiction
For any query, please contact our Customer Service Representative at email@example.com.