Privacy Policy

Updated: 25 February 2022

Data Protection Notice

This privacy policy (“Privacy Policy”) sets out the basis which Fraxtor Private Limited (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and other applicable data protection laws. This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of, or shared with, organisations which we have engaged to collect, use, disclose, store or process personal data for our purposes. “Personal data”, is defined in the PDPA and currently refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.

Personal Data

As used in this Notice: “customer” means an individual who:

(a) has contacted us through any means to find out more about any goods or services we provide, or

(b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer who can be identified:

(i) from that data; or

(ii) from that data and other information to which we have or are likely to have access.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include but not limited to:

(a) Identity and Contact data, which includes your name, NRIC Identification number, passport, telephone number, mailing address, email address, images of your passport or identification documents, date of birth, nationality, gender, marital status,photographs and other audio-visual information;

(b) Employment and Financial Information, which includes your financial position, status, history or bank account information;

(d) Usage data, which includes information about how you use our website, products and/or services, including cookies, IP address, and account details;

(e) Technical data, which includes details about the devices and technology you use including internet protocol address, your login data, and other technology on the devices you use to access our website, mobile application products and/or services; and/or

(f) Compliance data, which includes any other personal data permitted by or required to comply with any applicable local or foreign laws, acts, regulations, subsidiary legislation notices, notifications, circulars, licence conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time (“Applicable Laws”) and our internal control and compliance policies.

3. Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).

Sources of Information

The personal data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:

(a) information provided or submitted by you through among others, your dealings and agreements with us, which includes information provided when registering as a customer, providing information regarding any account which you may open with us, providing answers to security questions, completing any confirmations, declarations or forms, or through your utilization of any of our services, accessing or viewing our website and platform;

(b) as applicable, publicly available or publicly accessible information; and

(c) such other written, electronic or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.

We generally do not collect your personal data unless:
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after:

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and

(ii) you (or your authorised representative) have provided content to the collection and usage of your personal data for those purposes, or

(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

Consent is deemed to have been obtained from you in the following scenarios:

(a) if we have notified you of our intention to and the purpose for which we will collect, use or disclose your personal data, and you have not taken any action to opt out of such collection, use or disclosure within the period stated;

(b) where it is reasonably necessary for us to disclose your personal data to other third parties (including on a downstream basis) so that we can perform our obligations to you; or

Purpose of Collection, Use and Disclosure of Personal Data

7. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

(c) communicating with you, including on communications on matters relevant to your relationship with or interest in us, providing you with updates on our goods and/or services, and responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us;

(e) processing payment or transactions;

(f) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g) complying with any Applicable Laws, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(h) to understand your needs and preferences;

(i) to improve the content, appearance and utility of our website and platform, to assess and improve the products and services that you use or may use, and to manage and develop infrastructure and business operations;

(j) to prevent, detect and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks, to detect and protect us or any third parties against negligence, fraud, theft and other illegal activities, to protect and enforce our contractual and legal rights and obligations, and to seek professional advice, including legal advice;

(k) to conduct audits, reviews and analysis of our internal processes, for action planning and managing commercial risks, and to manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

(l) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

(m) any other purposes for which you have provided the information; and

(n) any other incidental purposes related to or in connection with the above.

8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

Disclosure and Sharing of Personal Data

9. We may disclose your personal data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in Singapore or otherwise, to carry out the purposes set out above.

10. This includes, disclosing and sharing your personal data with the following:

(a) any of our directors, officers, employees, representatives, agents or delegates;

(b) any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates;

(d) our affiliates in the course of or in connection with our provision of the services requested by you;

(e) any service providers, agents, contractors, delegates, suppliers or third parties which we may appoint from time to time to provide us with services in connection with the website, platform or the services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;

(f) any sub-contractors which any of our service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the website, platform or the services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;

(g) anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you, or anyone to whom any agreement we have with you (or any part thereof) is transferred to or may be transferred to;

(h) any person who we believe in good faith to be your legal advisers or other professionals;

(i) any relevant governmental or regulatory authority, in so far as we need to do so to keep to any Applicable Laws, or which we in good faith believe that we should keep to; and

(j) pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under a court order or otherwise);

(k) parties which assist us in carrying out the purposes laid out above in this Privacy Policy; and

(l) any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any Applicable Laws, provided that in the case of disclosures under any of the circumstances in (a) to (d), we shall procure that the recipient is subject to the same duty of confidence.

Third Party Data

11. Where you disclose personal data of other individuals to us, you warrant that such individuals have consented to us collecting, using and/or disclosing such personal data for:

(a) the relevant purpose for which you made the disclosure or as was notified to you at the relevant time; and

(b) the other purposes as described above in this Privacy Policy.

Reliance on the Legitimate Interests Exception

12. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Fraxtor Private Limited or another person. In relying on the legitimate interests exception of the PDPA, Fraxtor Private Limited will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

13. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

(a) Fraud detection and prevention;

(b) Detection and prevention of misuse of services;

(d) Collection and use of personal data on company-issued devices to prevent data loss.

14. The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

Withdrawing your Consent

15. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request for us to stop using and/or disclosing your personal data, or for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

16. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

17. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause above.

18. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under Applicable Laws.

Access to and Correction of Personal Data

19. If you wish to make

(a) an access request for a copy of the personal data we hold about you or information about the ways in which we use or disclose your personal data, or

(b) a correction request to edit any of your personal data we hold about you,

you may submit a written or email request to our Data Protection Officer at the contact details provided below.

20. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

21. We will respond to your request as soon as reasonably possible. Should we be unable to respond to your request within thirty (30) days, we will inform you in writing within that thirty (30) days of when we will be able to attend to your request . If we are unable to provide you with any personal data or to make a correction requested by you, we generally will inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

Protection of Personal Data

22. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

23. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Accuracy of Personal Data

24. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

Retention of Personal Data

25. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

26. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

Transfer of Personal Data Outside of Singapore

27. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

Data Protection Officer

28. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

DPO: Joyce Ng

Deputy DPO: Cher Lim

Email: accounts@fraxtor.com

Address: 101 Cecil Street, #10-08 Tong Eng Building, Singapore 069533

Effect of Privacy Policy and Changes to Privacy Policy

29. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

30. If there is any inconsistency between the terms and conditions set out here and any other separate agreement between us and you, this Privacy Policy shall prevail to the extent of the inconsistency in respect of the subject matter specifically addressed in this Privacy Policy, subject to Applicable Laws.

31. This Privacy Policy may be amended, supplemented or otherwise modified by us at any time without any advance notification or obtaining your consent. Any amendments or supplements to, or other modifications of, this Privacy Policy shall be posted on our website and we do not have an obligation to inform you separately of any such revision. You agree that any revision to this Privacy Policy can and may take effect immediately upon publication or at such other timing as we may specify in writing. You agree that any notification of amendments in the abovementioned manner shall be sufficient notice to you, and your continued access to the website and platform shall be deemed as your unconditional acceptance to such revised Privacy Policy. You are therefore reminded to check the Privacy Policy regularly for the latest updated version.

Cookies

32. When you browse our websites or use our mobile applications, we use cookies to store information about how you use these websites or mobile applications in order to improve the quality of service provided to you. To understand what type of cookies we use and how these work when you use our websites, please refer to our Cookie Policy.

Cookie Policy

This cookie policy (“Cookie Policy”) explains how and why Fraxtor Private Limited (“we”, “us”, or “our”) use cookies on our websites.

By continuing to use our website and/or platform without changing your settings, you consent to our use of cookies as set out in this Cookie Policy. If you do not agree to our use of cookies as set out in this Cookie Policy, you should disable or delete the cookies associated with the websites by changing the setting on the web browser on your device accordingly.

This Cookie Policy may be amended, supplemented or otherwise modified by us at any time without any advance notification or obtaining your consent. Any amendments or supplements to, or other modifications of, this Cookie Policy shall be posted on our website and we do not have an obligation to inform you separately of any such revision. You agree that any revision to the Cookie Policy can and may take effect immediately upon publication or at such other timing as we may specify in writing. You agree that any notification of amendments in the above mentioned manner shall be sufficient notice to you, and your continued access to the website and platform shall be deemed as your unconditional acceptance to such revised Cookie Policy. You are therefore reminded to check the Cookie Policy regularly for the latest updated version.

This Cookie Policy was last updated on 25 February 2022.

What Are Cookies?

Our website and platform use cookies, which are tiny files that are downloaded to your computer or mobile device when you visit our website and platform. This page describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the sites functionality.

How We Use Cookies?

We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore it is recommended that you do not disable cookies.

The Cookies We Set

(a) Account Related Cookies

If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your site preferences when logged out.

(b) Login related cookies

We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.

This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.

(d) Orders processing related cookies

This site offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.

(e) Forms related cookies

When you submit data through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.

(f) Site preferences cookies

In order to provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. In order to remember your preferences we need to set cookies so that this information can be called whenever you interact with a page is affected by your preferences.

(g) Acceptance of terms cookies

We may use cookies to record and store your acceptance of our terms of services (including our Terms of Use, Privacy Policy and the Cookie Policy).

(h) Site and service improvement cookies

To improve our site and services, we may use cookies to collect statistical information about users of our websites or platform (for example, time spent on each page and which links our users choose to click). We may occasionally offer surveys and questionnaires to understand our user base more accurately, which may use cookies to remember who has already taken part in a survey to provide you with accurate results after you change pages.

Third Party Cookies

In some special cases we also use cookies provided by trusted third parties. Where third party marketing cookies are used to gather information about your browsing activities, please note that we do not have access to, nor control over these third parties’ use of cookies or other tracking technologies or the content of their advertisements.

The following section details which third party cookies you might encounter through this site.

This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content.

For more information on Google Analytics cookies, see the official Google Analytics page.

From time to time we test new features and make subtle changes to the way that the site is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the site whilst ensuring we understand which optimisations our users appreciate the most.

The Google AdSense service we use to serve advertising uses a DoubleClick cookie to serve more relevant ads across the web and limit the number of times that a given ad is shown to you.

For more information on Google AdSense see the official Google AdSense privacy FAQ.

More Information

Hopefully that has clarified things for you and as was previously mentioned if there is something that you aren’t sure whether you need or not it’s usually safer to leave cookies enabled in case it does interact with one of the features you use on our site.

For more general information on cookies, please read “What Are Cookies”.

However if you are still looking for more information, you can contact us by email at: contact@fraxtor.com.

Governing Law

33. The governing law set out in our Terms & Conditions are incorporated by reference with the same force and effect as though set out in full herein.