Privacy Policy

Data Protection Policy

1. DATA PROTECTION POLICY
   1. This Data Protection Policy ("Policy") sets out the basis which MARGIN WHEELER PTE LTD and/or its related corporations (“we”, “us”, “our”) may collect, use, disclose or otherwise process personal data of our users in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”).
   2. This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
2. PERSONAL DATA
   1. As used in this Policy:
      1. "user" means an individual who:
         1. has contacted us through any means to find out more about any goods or services we provide; or
         2. may, or has, entered into a contract with us for the supply of any goods or services by us; and
      2. "personal data" means data, whether true or not, about an individual who can be identified:
         1. from that data; or
         2. from that data and other information to which we have or are likely to have access;
   2. Examples of personal data that we may collect include:
      1. identification information such as name, NRIC or FIN, passport or other identification number, date of birth, nationality and gender;
      2. contact information such as residential address, email address, country code and contact number;
      3. information relating to your use of our services, such as records of transactions and communications with us.
   3. Personal data does not include information about companies and other organisations. However, information about company officers (such as directors) and shareholders, such as their names and identification numbers, may be personal data.
3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
   1. We may collect personal data in one or more of the following ways:
      1. when you provide it to us directly;
      2. when your authorised representative provides your personal data to us and you have given that person consent to do so;
      3. when you use our website;
      4. when you use our services (including through emails, telephone calls, messaging platforms, meetings, and the provision of documents and information for onboarding, ongoing administration and for our purposes for the performance of our services); or
      5. when we receive it from third parties, business partners or public sources for the purposes set out in this Policy, and where the collection is in accordance with applicable laws.
4. COOKIES AND SIMILAR TECHNOLOGIES
   1. Our website and services use cookies and similar technologies (such as scripts and pixels). These help us:
      1. operate and secure the website;
      2. understand how visitors use our website;
      3. improve our content, marketing and services; and
      4. manage and respond to enquiries submitted through our website.
   2. In particular, we may use:
      1. Google Analytics (GA4) for website and usage analytics;
      2. Google Tag Manager to manage and deploy website tags; and
      3. Google Ads for conversion tracking and optimisation;
   3. It is noted that these third-party providers process information in accordance with their own privacy policies. We do not control and are not responsible for their independent data handling practices beyond our configuration and consent controls.
   4. Some of this information, such as IP addresses, device identifiers and cookie identifiers, may be considered personal data when it can be linked to you. We will obtain consent where required for the use of cookies and similar technologies that collect personal data for analytics or marketing purposes. You may manage cookies through your browser settings. If you disable cookies, some features of our website or services may not function properly.
   5. We do not currently use a cookie consent banner and a cookie preferences tool. You may manage cookies through your browser settings. If you disable cookies, some features of our website may not function properly.
5. PURPOSES OF COLLECTION, USE AND DISCLOSURE
   1. We may collect, use and disclose your personal data for one or more of the following purposes:
      1. to provide our services, including incorporation, corporate secretarial, nominee director, accounting, taxation and other services that we make available to you from time to time;
      2. to prepare, file and submit documents to government agencies and regulators in connection with our services (for e.g., filing your information with the Accounting and Corporate Regulatory Authority of Singapore when incorporating your entity or with the Inland Revenue Authority of Singapore when filing your tax computations);
      3. to verify your identity and carry out due diligence, including through checks with third-party screening providers (such as Sumsub for identity verification and ComplyAdvantage Mesh for know-your-business searches), and through information provided by you, your authorised representatives and public or regulatory sources;
      4. to process payments, issue invoices and receipts, and manage renewals, billing and collections;
      5. to send reminders relating to annual returns and other statutory or contractual deadlines (for e.g., to provide your entity’s monthly bank statements where such entity had engaged our nominee director services);
      6. to respond to your queries, feedback or complaints and provide customer support;
      7. to manage our relationship with you, including communications about service updates and administrative notices;
      8. to send you marketing messages about our products and services where you have given your consent or where permitted by law;
      9. to enforce our contractual rights and manage disputes, including the recovery of sums owed to us;
      10. to comply with applicable laws, regulations, codes of practice, guidelines and rules, and to assist in law enforcement and regulatory investigations; or
      11. any other purposes that we may have notified you of and for which you have provided consent, where required.
   2. We will not collect, use or disclose your personal data for purposes that a reasonable person would not consider appropriate in the circumstances.
6. MARKETING COMMUNICATIONS
   1. We may use your contact details to send you information about our products, services, promotions and events.
   2. We will only do so:
      1. with your consent, where consent is required; or
      2. as otherwise permitted under the PDPA.
   3. You may withdraw your consent to receive marketing messages at any time by using the unsubscribe facility in our messages or by contacting our Data Protection Officer.
   4. To avoid doubt, administrative, service-related, compliance, billing, renewal and account notices are not considered marketing communications and will be sent regardless of your marketing consent status.
7. DISCLOSURE OF PERSONAL DATA
   1. We may disclose your personal data to one or more of the following parties for the purposes set out above:
      1. our employees and departments that need the information to perform their duties;
      2. our collaborative partners, agents, contractors and third-party service providers that process data on our behalf, such as our website hosting provider, IT service providers, and third-party screening providers used for know-your-customer / know-your-business checks (for e.g., Sumsub and ComplyAdvantage Mesh);
      3. our professional advisers, including auditors, lawyers and consultants;
      4. debt collection agencies, credit reporting agencies or dispute resolution centres in the event of default or disputes;
      5. government agencies, regulators, statutory boards and law enforcement authorities, and their agents, where required by applicable law or where we consider such disclosure reasonably necessary;
      6. any party to whom disclosure is required in connection with the purposes described in this Policy, such as counterparties in a corporate transaction or service engagement.
   2. Where we disclose personal data to third parties who process personal data on our behalf, we will require them to protect the personal data in a manner that is consistent with this Policy and the PDPA.
8. WITHDRAWAL OF CONSENT
   1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until it is withdrawn by you in writing.
   2. You may withdraw your consent and request that we stop collecting, using or disclosing your personal data for any or all of the purposes described in this Policy by contacting our Data Protection Officer.
   3. Upon receiving your request, we may require reasonable time to process it and to notify you of the consequences of your withdrawal. In general, we will process your request within one calendar month. Depending on the extent of your withdrawal, we may not be able to continue providing some or all of our services to you.
   4. Withdrawal of consent does not affect our rights to continue to collect, use or disclose personal data where such collection, use or disclosure without consent is permitted or required under applicable laws.
9. ACCESS AND CORRECTION
   1. You may request:
      1. access to personal data that we hold about you;
      2. information about how we may have used or disclosed your personal data in the past year, to the extent required by law; and
      3. correction of any errors or omissions in your personal data.
   2. Requests should be made in writing to our Data Protection Officer. We may charge a reasonable fee for processing an access request, and will inform you of the fee before we process the request.
   3. We will respond to your request as soon as reasonably practicable in accordance with the PDPA. If we are unable to provide you with any personal data or to correct it, we will explain why, subject to any legal restrictions.
10. ACCURACY
    1. We take reasonable steps to ensure that personal data we collect is accurate and complete, especially where it is likely to be used to make a decision that affects you or to be disclosed to another organisation.
    2. We may rely on personal data provided by you (and, where applicable, your authorised representatives and third-party screening providers) to keep your records up to date. Please inform us promptly if there are changes to your personal data so that we can update our records.
11. PROTECTION
    1. We take reasonable physical, administrative and technical measures to protect your personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
    2. Examples of such measures include access controls, encryption or pseudonymisation where appropriate, secure system configurations and staff training on data protection.
12. RETENTION
    1. We will cease to retain your personal data, or remove the means by which the data can be associated with you, when it is reasonable to assume that the purpose for which the personal data was collected is no longer being served and retention is no longer necessary for legal or business purposes.
    2. We may retain personal data for a longer period where necessary for legal, regulatory or accounting purposes, or to protect our interests in the event of disputes.
13. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
    1. We may transfer, store or process personal data outside Singapore where it is necessary for our operations or where our service providers (for e.g., providers of website analytics and advertising measurement) process data in other jurisdictions. If we do so, we will comply with the PDPA’s transfer limitation obligation and will ensure that the receiving party provides a standard of protection to personal data that is at least comparable to the protection under the PDPA.
    2. This may include entering into appropriate contractual arrangements with the recipient or relying on other permitted transfer mechanisms.
14. DATA BREACHES
    1. If we become aware of a data breach involving personal data under our control, we will assess the breach in accordance with the PDPA and applicable guidelines issued by the Personal Data Protection Commission of Singapore (“PDPC”). Where the breach is notifiable, we will notify the PDPC and affected individuals as required by law.
15. LINKS TO OTHER SITES
    1. Our website may contain links to third-party websites. We do not control and are not responsible for the content, privacy policies or practices of such websites. You should review the privacy policies of those websites before providing any personal data to them.
16. DATA PROTECTION OFFICER
    1. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request under this Policy, you may contact our Data Protection Officer via email at [email protected] with a copy to [email protected].
17. CHANGES TO THIS POLICY
    1. We may update this Policy from time to time. You can tell when this Policy was last updated by checking the “Updated” date at the top of this page.
    2. Your continued use of our services after any changes to this Policy will constitute your acknowledgement of the updated Policy.