(updated on 01 July 2018)
Your Privacy is Important to Us
In this policy, “we”, “us”, “our” or “MAB” means Delphi Capital Pte Ltd, “you”, “your” or “yours” means the persons to whom this policy applies and “MAB Group” means MAB Pte Ltd., its related corporations, affiliates and branches.
The security of your personal data is important to us. MAB has in place safeguards to protect the personal data stored with us. This policy describes how we may collect, use, disclose, process and manage your personal data.
In the event of any inconsistency between different versions of this policy, the English version shall prevail.
Personal Data We Collect
“Personal data” is data that can be used to identify a natural person. Some examples of personal data that we may collect are:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, personal interests, expectations of you and/or education details);
- specimen signature(s);
- financial details (e.g. income, expenses, and/or credit history);
- images and voice recordings of our conversations with you;
- employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- tax and insurance information;
- information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- banking information (e.g. account numbers and banking transactions);
- personal opinions made known to us (e.g. feedback or responses to surveys); and/or
- Information obtained from mobile device with your consent (e.g. device location and information).
The provision of your Personal Data is voluntary. However, if you do not provide MAB with your Personal Data, MAB will not be able to process your Personal Data for the Purposes and Additional Purposes outlined below and may cause MAB to be unable to provide services or products to or accept payments from you.
If you are an agent, vendor, supplier or service provider, provision of your Personal Data is mandatory and failure to provide your Personal Data, may be a breach of laws or regulatory requirements, and may cause MAB to be unable to engage you to provide services or products or issue payments to you for products or services provided.
In addition to the Personal Data you provide to MAB directly, MAB may collect your Personal Data from publicly available sources or from third parties, for example:
- from filled up application or registration forms or other similar forms
- from publicly available sources such as directories;
- from MAB official social media pages, if you follow, like or are a fan of such pages;
- from building and construction authorities, credit reporting agencies, insurance providers, or financial services providers;
- when you interact and communicate with MAB at any events or activities;
- when you enter contests organized by MAB;
- from other entities who provide you with services or with whom you have a contractual relationship;
- from marketing service providers or partners; or
- from various entities or divisions under MAB;
- by using MAB apps and websites, which includes all apps and websites operated by MAB and under the names of its respective brands (respectively “Apps” and “Websites”).
Your personal data may also be collected from cookies used on the Websites.
Usage of Your Personal Data
MAB may use and process your Personal Data for business, logistics, payment and financial services activities of MAB which shall include, without limitation the following (“Purposes”):
We may use your personal data for our core business purposes, such as:
- developing and providing better products or services (whether made available by us or through us), including but not limited to:
- executing commercial, banking, financing or other transactions and clearing or reporting on these transactions;
- carrying out research, planning and statistical analysis; or
- analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
- assessing and processing applications, instructions or requests from you or our customers;
- communicating with you, including providing you with updates on changes to products, services and banking, financing facilities (whether made available through us) including any additions, expansions, suspensions and replacements of or to such products, services and their terms and conditions;
- managing our infrastructure and business operations and complying with internal policies and procedures;
- responding to queries or feedback;
- addressing or investigating any complaints, claims or disputes;
- verifying your identity for the purposes of providing products or services;
- conducting credit checks, screenings or due diligence checks;
- complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
- monitoring products and services provided by or made available through us;
- complying with obligations and requirements imposed by us from time to time by any government agencies;
- creating and maintaining credit and risk related models;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enforcing obligations owed to us; and/or
- seeking professional advice, including legal advice.
We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customer.
Purposes of Processing
MAB may use and process your Personal Data for business, delivery and logistics, payment and financial services activities of MAB which shall include, without limitation the following (“Purposes”):
Where you are a customer of the services provided by MAB:
- to perform the MAB obligations in respect of any contract entered into with you;
- to provide you with any service you have requested;
- to process your contract and to deliver the services to you;
- to process and manage your rewards and loyalty points;
- to process your participation in any events, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions;
- to process, manage or verify your application for subscription with MAB and to provide you the benefits offered to subscribers;
- to validate your requests and process payments relating to any products or services you have requested;
- to understand and analyse our sales as well as your needs and preferences;
- to develop, enhance and provide products and services to meet your needs;
- to process exchanges or product returns;
Where you are an agent, vendor, supplier, partner, contractor or service provider:
- for the purposes of engaging you to provide services or products;
- to facilitate or enable any checks as may be required by MAB in order to engage you;
- to process payments relating to any products or services you have provided;
- to provide personalised feedback to you, so that you are able to identify specific areas for improvement;
- to assess safety and quality;
- to contact you in relation to the provision of your services.
- to respond to questions, comments and feedback from you;
- to communicate with you for any of the purposes listed in this Policy;
- for internal administrative purposes, such as auditing, data analysis, database records;
- for purposes of detection, prevention and prosecution of crime;
- to maintain the safety and security of our services;
- for MAB to comply with its obligations under law;
and you agree and consent to MAB using and processing your Personal Data for the Purposes and in the manner as identified in this Policy.
Marketing and promotional purposes
MAB may also use and process your data for other purposes such as (“Additional Purposes”):
We may use your personal data to offer you products or services send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings from MAB, its partners, sponsors or advertisers, notify and invite you to events or activities organized by MAB, its partners, sponsors or advertisers, process your registration to participate in or attend an event or activity and to communicate with you regarding your attendance at the event or activity, share your Personal Data amongst its subsidiaries, associate companies and jointly controlled entities as well as with its agent, vendor, supplier, partner, contractor or service provider who may communicate with you to market their products, services, events or promotions including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the Personal Data Protection Act of Singapore (PDPA) and other applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (GDPR).
In respect of sending telemarketing messages to your Singapore telephone number via short message service, telephone calls, facsimile and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry. If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your Singapore telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
To find out more on how you can change the way we use your personal data for marketing purposes, please contact us using the contact details stated below.
Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
Unsubscribe and Revocation of Consent
If you wish to unsubscribe to the processing of your Personal Data for Additional Purposes by MAB, please click on the link “Unsubscribe” which is embedded in the relevant email or message in order not to receive any such messages in the future. Please note that if you unsubscribe, we may still send you service-related messages, such as invoices, project updates.
If you wish to revoke the consent that MAB has obtained from you for the Purposes stipulated herein, please notify MAB using the contact details stated below
Transfer of Personal Data
Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any services provided by MAB (“Alternate Country”), to companies under MAB which are located outside of your home nation or Alternate Country and/or where MAB’s ervers and/or service providers and partners are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.
Disclosure to Third Parties
Your personal data may be transferred, accessed or disclosed to third parties for the Purposes and Additional Purposes. Further, MAB may engage other companies, service providers or individuals to perform functions on its behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties include, without limitation:
- MAB partners, which include parties with whom MAB collaborates with for certain events, programs and activities;
- Event management companies and event sponsors;
- Marketing research companies;
- Service providers, including, information technology (IT) service providers for infrastructure, software and development work;
- Professional advisors and external auditors, including legal advisors, financial advisors and consultants;
- Other entities within MAB; and
- Governmental authorities to comply with statutory, regulatory and governmental requirements.
Your Personal Data may also be shared in connection with a corporate transaction, such as the formation of a joint venture, a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.
Access and Correction
Subject to any exceptions under applicable laws of your home nation or Alternate Country, you may request access or make corrections to your personal data held by MAB. MAB may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
The GDPR also provides relevant individuals with additional rights including the right to obtain information on how MAB process your personal data, receive certain information provided in an electronic format and/or request that these be transmitted to a third party, request for your information to be erased, object or restrict the use or processing of your information in some circumstances. These will be subject to ongoing obligations imposed on the MAB pursuant to any applicable law or regulation, and/or the MAB’s legitimate reason or entitlement to continue processing your information, and/or to refuse that request.
Please contact us (please see the “How to contact us” section below) for details on how you may request access or correction to, or exercise your rights with respect to the processing of your personal data.
Matchabuilder Data Protection Officer
c/o Delphi Capital Ptd Ltd.
12G Enterprise Road, L2A
Subject to any laws of your home nation or Alternate Country, MAB reserves the right to impose a fee for access of your Personal Data in the amounts as permitted therein.
In respect of your right to access and/or correct your Personal Data, MAB has the right to refuse your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.
A cookie is a small amount of data that our web server sends to your web browser when you visit certain parts of our website and the use of which is intended to assist our understanding of your interest in our website. We may use the cookies to personalise the content, recommendations, advertisements and communications delivered to you so that they are more relevant to you and your interests.
Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our web site but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the web site.
Please note that the cookies do not personally identify users although they do identify a user’s browser. You can always choose to disable cookies from being stored on your computer by changing your browser settings. Disabling cookies however, may result in a limited experience of our functionality and services and in some cases may mean that we are unable to provide you with the services, or parts of the services, that you have requested.
Additionally, we may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.
If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of this information through your mobile device settings, or by submitting your details here
Personal Information from Minors and Other Individuals
Parent(s) or legal guardian(s), please do not allow the minor (individuals under 18 (eighteen) years of age) under your care to submit Personal Data to MAB. In the event that such Personal Data is provided to MAB, you hereby consent to the processing of the minor’s Personal Data and personally accept and agree to be bound by this Policy and take responsibility for his or her actions. We encourage parents to get involved with their children’s online usage and to be aware of the activities in which they are participating.
In some circumstances you may have provided personal data relating to other individuals (such as your spouse, family members or friends) and in such circumstances you represent and warrant that you are authorized to provide their personal data to MAB and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Policy.
Acknowledgement, Consent, and Data Retention
By communicating with MAB, using MAB services, purchasing products from MAB or by virtue of your engagement with MAB, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and transfer of your Personal Data by MAB as described in this Policy.
We shall have the right to amend this policy from time to time to ensure that this policy is consistent with any developments to the way MAB uses your personal data or any changes to the laws and regulations applicable to MAB. We will make available the updated policy on our web sites. By continuing to communicate with MAB, using MAB services, purchasing products from MAB or by your continued engagement with MAB following the modifications, updates or amendments to this Policy, such actions shall signify your acceptance of such modifications, updates or amendments.