Privacy & Data Protection Policy

1. INTRODUCTION

This Privacy and Data Protection Policy (the “Policy”) applies to your use of the website www.brucbond.com and all related sites (the "Website"), and applications, services and tools provided by the Company (as defined below) (the "Services",) and sets out how we may collect, use and disclose Personal Data for your access to and use of the Website and Services.

Please note that this Policy is of general application and may be amended, modified or supplemented by contracts, agreements or other forms (including the fair notification form) you may enter into from time to time with us as required by the Company for compliance with applicable laws and regulations (including MAS Notice PSN01 issued by the Monetary Authority of Singapore). This may further limit your rights in relation to our collection, use, disclosure of and also access and right of correction to your Personal Data (as defined below).

All terms not otherwise defined herein, shall have the meaning ascribed to them in the Terms and Conditions (see paragraph 13 below). The Services are developed, owned and operated by Bruc Bond Pte. Ltd. and any of its group of companies (together “Company”, "we"). This Policy specifies what information we collect and how we collect the information, how we use the collected information, and how we share the information and protect it. Contact Us details are provided at the end of the Policy, for feedback or any privacy enquiries you may have.

“Personal Data” means data from which any individual can be identified, whether through the data alone or in conjunction with other information that we have or are likely to have access to, which may include without limitation, your name, address, telephone number, government-issued identification number, email address, payment information, IP address, the type of services subscribed to and such other necessary data regarding your transaction(s) with us etc.

Please note that this Policy is governed by Singapore law.

Please read the following carefully to understand our practices regarding your Personal Data and how we will treat it.

2. SCOPE AND CONSENT

By accessing, applying for, using our Services or by visiting the Website, or submitting your Personal Data, you confirm that you accept and consent to the practices describe in this Policy, including the collection, use and disclosure of your Personal Data for the stated purposes herein. This Policy (together with our Terms and Conditions and any other documents referred to in it) applies, without limitation, to:

Your use of the Website and Services, whether by using your computer, your mobile device or any other device;
Email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and the Company.

Learn more to understand how we will treat your Personal Data:

If you are not agreeable to any aspect of this Policy, please do not continue to use the Services, access the Website or submit any Personal Data to us.

Please note that we provide certain Services to both individual consumers and businesses and this Policy applies to both and should be read and interpreted accordingly.

3. THE INFORMATION WE COLLECT FROM YOU

We have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with the Services as well as the purposes listed out in paragraph 5 of this Policy. We may collect, receive and process any information, including your Personal Data and other details submitted, shared or exchanged in connection with the Services. You may provide some of this information to us, for example by filling in forms, or by corresponding with by us phone, e-mail, web chat or otherwise. We may collect some of it through automatic means, for example by using cookies when you visit our Website. We may also obtain data about you from third parties.

Learn more to understand which information we collect:

When underwriting new clients, the Company routinely collects ‘Know Your Customer’ and

Anti-Money Laundering data from clients. Client's data subjects' details may be crosschecked against lists and search libraries to verify that such details are correct and not subject to blacklisting or service prohibitions.

Information you provide us:

When you register to our Website and Services you will be requested to provide Personal Data such as: your full name, e-mail address, phone number, address, gender, date of birth, contact details, location, nationality and country of residence, and any other contact information you choose to provide on or via the Services or in any other communications with the Company.
When you use the Services you will be requested to provide additional Personal Data and KYC information such as: your identification number, photograph, a copy of an identification card (e.g. ID card, driving license and/or passport), various business and financial information, including bank account details and any information of your transactions and financial activity with other payment processors, copies of utility bills, etc., and any proof of your identity as we may request. The legal regulation framework that applies on the Services may change from time to time, and accordingly we may require some additional information from you in order for compliance with any new or updated regulations.
Any other information you may provide regarding your personal situation (including financial information required to establish your financial standing and/or your suitability for our Services). This information may include any Personal Data and/or identification information or other personally sensitive data and extends to any information which may be available on a public register or public domain.
Information relating to any transaction processed and/or items purchased via the Services, including the location of the recipient or purchase, the value, the time and any feedback that is given in relation to such transaction;
Information you may provide when you communicate with us by phone, e-mail, SMS, a website or portal, or once you enter information on our Website, submit survey responses or any other electronic means. We may monitor and record phone calls, e-mails, Voice over Internet Protocol (VoIP) calls, chat logs, or other communications between you and our Customer Service representatives or other Company representatives. When visiting our offices, access control systems and other monitoring systems may be in operation.
Any other information that you or your customers provide us.

Information we get from your use of our Website and Services:

Information on your requested transactions provided through your use of the Services.

Information we collect from third parties

In order to fulfill our legal obligations to prevent fraud and money laundering and for risk assessment purposes, we will obtain information about you from our trusted service providers when you request to use our Services and at any time when we feel it is necessary to prevent fraud, to minimize financial risks or to prevent other risks, for instance - your financial history information.

4. INFORMATION WE COLLECT AUTOMATICALLY

We automatically collect Personal Data associated with your use of the Website or Services when you access and use the Services, or by using third party services.

When you access and use the Services, we may collect information about your visit to our Website, your usage of the Services, and your web browsing. That information may include your IP address, your operating system, your browser ID, location data, browser type, domain names, language settings and other information about how you interacted with our Website or other websites. It may also include anonymized demographic information, which is not unique to you or identifying you, such as your postal code, age, gender, preferences, interests and favorites. We may collect the abovementioned information as a part of log files as well as through the use of cookies, log files and other tracking technologies on the Services, as specified under paragraph 10 below.
We may use third party services, such as Google Analytics, to collect and process such data in order to analyze the traffic to the Website.

5. PURPOSE FOR COLLECTION, USE, AND DISCLOSURE

If you provide any Personal Data to us, you consent to, and in any case are deemed to have authorised us to collect, retain, use, and disclose that Personal Data for the following purposes:

verifying your identity, as well as ascertaining and/or verifying that any information provided by you is correct (including by communicating with third parties and cross-checking against databases);
verifying your eligibility to register as a user of the Website, your suitability for our Services and conducting know-your-client and other background and due diligence checks;
processing your registration as a user, providing you with a log-in ID for the Website and maintaining and managing your registration and account(s) with us;
providing the Services to you, including fulfilling the Company's obligations;
meeting our obligations, contractual or otherwise, to you or to financial or other institutions;
conducting investigations and proceedings required by applicable laws and regulations (for example, anti-money laundering/combating the financing of terrorism laws) and meeting our obligations to any relevant regulatory authority (whether in or outside Singapore, including but not limited to the Monetary Authority of Singapore) or to comply with any sanction requirements;
detecting, preventing, mitigating and investigating fraudulent or illegal activities;
providing you with customer service and responding to your queries, feedback, claims, complaints, or disputes;
producing data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
conducting research for analytical purposes but not limited to data mining and analysis of your transactions with us in order to improve the products and services which we are providing to you;
protecting or enforcing our rights to recover any debt owing to us;
performing research or statistical analysis in order to improve the content and layout of the Website and Services, to improve our product offerings and services and for marketing and promotional purposes;
providing notices, surveys, product alerts, communications and other marketing materials to you relating to Services offered by us and the Website;
fulfilling record keeping obligations prescribed by any regulatory or governmental authority;
fulfilling any other purpose that is required or permitted by any law, guidelines and/or relevant regulatory authorities;
making such disclosures as may be required for any of the above purposes or as required by law or similar rule or in respect of any claims or potential claims brought against us; or
any other purpose reasonably related to the foregoing.

Learn more about the use of your Personal Data by us:

We may use information collected about you, including Personal Data, for any one of the purposes listed in paragraph 5 above. You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at singapore@brucbond.com or by choosing to opt out of receiving additional promotional e-mails from the Company by clicking on the 'unsubscribe' link in any such e-mail, or by following any instructions the Company may include in the message sent to you (the “Opt-out request” or “Request”). Please note that, once we receive your request, it may take an additional period of time for the Opt-Out Request to become effective. Note that, if you opt-out of our promotional communications, the Company may still e-mail or communicate with you from time-to-time, if the Company needs to provide you with information or for other commercially, non-marketing reasons related to the Services.

Please be informed that no automated decisions or profiling are made in the course of the processing of your Personal Data.

6. DISCLOSING OF INFORMATION TO THIRD PARTIES

You further agree that we may disclose and transfer your Personal Data to third parties to assist us with providing you with access to our Services, with suppliers working on our behalf, where we have your permission, or where we are required or permitted to do so by law. We may also share your Personal Data with third parties to comply with our legal obligations, to prevent any fraudulent or illegal activities related to our Services, to respond to legal process or to protect the rights or property of the Company, our customers or others. We attempt to minimize the amount of Personal Data we disclose to what is directly relevant and necessary to accomplish the specified purposes.

Learn more about the cases of disclosure of information to third parties:

We will not disclose to third parties the Personal Data gathered about you via the Website and Services, inasmuch as this information identifies you personally, except in the cases set forth hereinafter:

(a) To collect, hold and manage your Personal Data through the Company's trusted vendors (including their sub-contractors) who apply suitable safeguards to protect the privacy and security of your Personal Data, for example, cloud computing platform and hosting services provider, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction;

(b) To bill and collect money owed to us by our clients;

(c) To Credit and Financial Institutions that take part in the processing of the services: including the credit institution where you maintain bank account and any other financial institutions who may process payments;

(d) Risk management. We use trusted third parties to secure transaction processing and to conduct identity verification and prevention checks of fraud or any other illegal activities or otherwise address security (including IP address checks) or technical issues (for example, World Check by Thomson Reuters for money laundering detection) and of bank transfer transaction, and we send Personal Data to these third parties to process payments;

(e) To communicate with our customers about their account and provide customer support, including by our third party trusted vendors;

(f) To provide information to our authorized representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, security and other requirements;

(g) To provide, support, and improve the Services we offer. This includes, for example, aggregating information of your use of the Services or Website and sharing this information with third parties to improve and support our Services and to make certain features of the Services available to you;

(h) To promote use of our Services where permitted under applicable laws and regulations. With your express consent, sharing your contact information (but not information relating to your account(s) or financial standing) with our trusted vendors that assist us in sending marketing e-mails and advertisement, including via social media platforms. You can stop receiving our promotional messages by following the unsubscribe instructions included in every email or by contacting us at singapore@brucbond.com.

(i) To satisfy applicable laws and regulations, if and as applicable, including reports to Anti-Money Laundering authorities and to any other competent authority, with accordance to legal requirements, to financial institutions that take part in the processing of the services for compliance purposes, and to comply with a judicial proceeding, court order, or legal process;

(j) To enforce the Terms and Conditions, including investigation of potential violations thereof, and to protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law;

(k) In the event the Company goes through a business transition such as a merger, acquisition of all or a portion of the Company's assets, your Personal Data may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations.

Please note that third parties (whether located in Singapore or overseas) that we may disclose your information to include but are not limited to:

our related corporations;
companies and/or organizations that act as our agents, affiliates and/or professional advisors or third party vendors;
companies and/or organizations (including the Credit and Financial Institutions) that assist us in processing and/or otherwise fulfilling the Services and/or transactions that you have requested;
agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services;
any other person notified by you as authorized to give instructions or to use the account(s) or Services on your behalf;
relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, and the Inland Revenue Authority of Singapore, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them; or
any other party to whom you authorise us to disclose your personal data.

Please note that these third parties may be in other countries where the laws on processing Personal Data may be less stringent than in your country.

Except where permitted as stated, the Company does not sell, rent, share or otherwise disclose Personal Data to third parties.

The Company may transfer and disclose to third parties or otherwise use non-Personal Data at its own discretion.

7. Storing your data

The Personal Data that we may collect may be transferred to, stored at and processed in a destination outside Singapore, where your Personal Data may not be protected by the same standards. We endeavor to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. By using the Website and Services, you agree to this transfer, storing or processing.

Learn more to understand the reasons for storing Personal Data outside Singapore and/or your territory:

Any Personal Data which we may collect may be transferred to, processed and stored at destinations outside Singapore, where your Personal Data may not be protected by the same standards, for the reasons set out below:

Where our hosting provider or cloud computing platform is outside Singapore.
Transfer to our affiliated companies that is needed for providing the Services.
If necessary for providing the Services.
Where our anti-fraud agencies, credit reference agencies and other service providers that are based outside Singapore, require access to your data to perform their obligations to us and provide the requested Services to you.
Where Personal Data is processed by staff operating outside your territory or outside Singapore who work for us or one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of orders, the processing of payment details and support services in provision of the Services. Where such staff is acting on behalf of the Company, we will take all steps reasonably necessary to ensure that reasonable security arrangements are put in place so that your Personal Data is treated securely and in accordance with applicable laws and regulations and with this Policy.

8. DATA RETENTION

We may retain your Personal Data in conformance with applicable laws and regulations, in order to: comply with legal requirements (including any requirements imposed by the Monetary Authority of Singapore) or to protect Company's legal interests, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms and Conditions and take other actions otherwise permitted by law.
This Data retention is applicable during the period of business relationship, cancellation of business relationship, or if your related application is declined or suspended for a period as long as permitted or required under any applicable law or regulation, for legal, regulatory, fraud and other financial crime prevention including but not limited to the purpose of providing information required by the applicable authorities.

9. USE OF “COOKIES”

We use cookies to ensure you get the best experience on our Website. You can choose to enable or disable Cookies in your internet browser or delete them. If you choose to delete them, you may lose any information that enables you to access the Website more quickly and efficiently.

Learn more on what a cookie is and how you can disable it:

What is a cookie?

Cookies are alphanumeric identifiers that are transferred to and stored in your device through your web browser for record-keeping purposes. Some cookies allow making it easier for you to navigate a website, while others are used to enable a faster log-in process or to allow us to track your activities on a website.

When you access the Website, you will be presented with a message bar requesting your consent to set those cookies. By continuing to browse the Website, you are enabling us to place cookies on your computer and/or our partners to provide a better experience and service to you.

Cookies generally process your IP-address but they do not save your Personal Data like e-mail address or phone number.

This Website may place the following type of Cookies:

Essential cookies: These cookies are necessary to allow you to access and move around our Website and use all its features. Without these cookies, you would not be able to access our Website and/or to use certain important features.
Visitor Cookie: These cookies are part of our security mechanisms and are used to identify visitors (each visitor representing a specific computer) of the Website,
Analytics cookies: This Website also uses analytics cookies placed by Google Analytics (including Google Tag Manager) to measure the number of visits and the parts of the website that are the most popular among our Website visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of this Website and is used to improve the contents of this Website to enhance your user experience. To opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout/ (or to other Google link as may be updated from time to time)
Advertising cookies: These third party cookies, such as Google Adwords, help ensure that our advertisements are as relevant to you as possible. These cookies track and record information (including by Google) regarding your browsing habits and activity, and use this information to enable us to show you relevant/personalised marketing content across the Internet. Using these cookies, our third party vendors may collect personally identifiable information (for instance when information collected by such cookies is associated with your Google Account) and use this to display our targeted advertising to you. For example, some advertising cookies help select advertisements that are based on your interests. You can opt out of Google’s use of the abovementioned cookies by visiting Google’s Ads Settings: https://adssettings.google.com/authenticated (or other Google link as may be updated from time to time).

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed.

A customer may oppose the registration of cookies in his/her connected terminal by setting his/her Internet browser as follows:

For Safari:

Select "Edit" then "Preferences" menu
Click on the "Security" icon
Select the desired options for cookies

For Mozilla Firefox:

Select "Tools" then "Options" menu
Click on the "Privacy" icon
Select the desired options for cookies

For Microsoft Internet Explorer:

Select "Tools " then "Internet Options" menu
Click on the "Privacy" tab
Select the desired level using the cursor

For Chrome:

Select the "Settings " then "Privacy" menu
Click on the tab " Content Settings "
Select the desired options for cookies

For further details, please consult the help menu in your internet browser.

You can choose to delete cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings. You are therefore informed that the opposition to the registration of cookies can make inaccessible all or part of the Website features.

10. THIRD PARTY SERVICES

Certain Services on the Website, such as services provided by Facebook or Google, are in fact managed by bodies other than the Company. In these cases, the Services are provided or operated not via the Company computers alone, but rather via the other bodies as stated.

The Company is entitled to be assisted by third parties, including advertising companies, for the purpose of presenting advertisements on the Website or on other websites or providing other services. It is possible that these parties use information about your online activity (which does not include identifying Personal Data), among others in order to provide advertisements for products and services which may interest you.

Without derogation to the foregoing, you confirm that you are aware that your activity on the Website may enable third parties, such as online search engines, to rely on the nature of your activity as stated, in order to present to you adapted advertisements in the framework of online activity, even outside of the Website, as an inseparable part of their ongoing activity and in the absence of any affinity to the Company’s activity. The activity of third parties as stated is subject to the privacy policy used by them alone, and is done in their full and exclusive responsibility, without the Company having any accountability whatsoever for it.

11. THIRD PARTY LINKS

The Services contain links to third party websites and services, which are outside the Company's control and are not covered by this Privacy Policy. The Company does not assume responsibility for the privacy practices of such other websites to which it may link or web-sites that link to the Services, and encourages you to review those privacy policies yourself.

12. SECURITY PRECAUTIONS TO PROTECT YOUR INFORMATION

We take a great care in implementing and maintaining reasonable and appropriate security procedures consistent with prevailing industry standards to protect the security of the Website, the Services, and our users’ Personal Data from accidental loss and from unauthorised access, use, alteration and disclosure.

While we take reasonable precautions against possible security breaches of the Services, no website or internet transmission is completely secure, and we cannot guarantee (i) that unauthorized access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your data while it is being transmitted to and from the Services; any transmission is at your own risk. The Company urges you to take steps to keep your Personal Data safe, including your Account password, and to log out of your Account after use.

You are responsible for keeping this password confidential and complying with our instructions. You must not share your credentials with anyone else, and you authorise the Company to act upon instructions and information from any person that enters your credentials. You also agree to promptly notify us of any information you have provided to us which has changed.

13. TERMS AND CONDITIONS

Please also review the Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of the Services, at: https://www.brucbond.com/legal/apac-conditions.

14. YOUR PRIVACY RIGHTS

Where applicable, you may have certain rights under data protection legislation, including the right to object to direct marketing and the right to access the Personal Data held about you and you may ask us to make any necessary corrections to ensure it is accurate and up to date.

Learn more on other rights available:

You may have certain rights under data protection legislation including the right to access the Personal Data held about you and you may ask us to make necessary changes to ensure that it is accurate and up to date. Where applicable, data protection legislation may also provide the following rights in relation to Personal Data which can also be discussed with us by using the Contact Us section below:

request us to give you access to it;
request us to rectify inaccurate or incomplete information, or erase it, where applicable;
request us to restrict or to stop our using it, in certain circumstances; withdraw your consent to our collection, use, or disclosure of it;
data portability, in certain circumstances;
opt out from our direct marketing, if applicable; and
lodge a complaint with the Personal Data Protection Commission.

15. CHANGES TO OUR PRIVACY AND COOKIE POLICY

We may amend this Privacy and Cookie Policy from time to time as needed with a prior notice about updates or changes. Your continued use of Website and Services will constitute your acceptance of the revised Policy. Therefore, you should periodically check this Website to review the most current terms and conditions of the Privacy and Cookie Policy.

16. CONTACT US

If you have any additional questions or concerns about this Policy, please feel free to contact us any time through the Services or by writing to us at singapore@brucbond.com.

Last updated on February 2020

Legal