Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, you agree and consent to S21 Credit collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
S21 Credit may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Please check back regularly for updated information on the handling of your Personal Data.
- In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified
a. from that data; or
b. from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
- Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
Collection of Personal Data
- Generally, we collect Personal Data in the following ways:
a. when you submit an application form or other forms relating to any of our loan products and services
b. when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
c. when you use some of our services, for example, websites and apps including establishing any online accounts with us;
d. when you request that we contact you, be included in an email or other mailing list;
e. when you respond to our promotions, initiatives or to any request for additional Personal Data;
f. when you are contacted by, and respond to our customer service officers;
g. when we receive references from business partners and third parties, for example, where you have been referred by them;
h. when we seek information from third parties about you in connection with the products and services you have applied for; and
i. when you submit your Personal Data to us for any other reasons.
- When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
- If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
- You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
Purposes for the Collection, Use and Disclosure of Your Personal Data
- Generally, S21 Credit collects, uses and discloses your Personal Data for the following purposes:
- responding to your queries and requests;
- managing the administrative and business operations of S21 Credit and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- resolving complaints and handling requests and enquiries;
- preventing, detecting and investigating crime and analyzing and managing risks;
- providing media announcements and responses;
- monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- conducting investigations relating to disputes, billing, suspected illegal activities or fraud;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on S21 Credit (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
- purposes which are reasonably related to the aforesaid.
- opening or continuation of accounts and establishing or providing you with the loan products and services you subscribe to
- facilitating the continuation or termination of your subscription to our loan products and services
- facilitating the daily operation of the loan products and services (including but not limited to billing, customer service, customer verification);
- processing of payment instructions, debit facilities and/or credit facilities requested by you;
- enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
- administering and processing any insurance claims and payments arising under the respective policies; credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies)
- In relation to particular loan products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
Disclosure of Personal Data
- S21 Credit will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- S21 Credit’s employees to provide content, loan products and services to you, address your questions and requests in relation to your accounts, subscription and billing arrangements with us as well as our loan products and services, to activate, deactivate, install, maintain and operate our services;
- companies providing services relating to insurance and debt collection consultancy to S21 Credit;
- agents, contractors or third party service providers who provide operational services to S21 Credit, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to S21 Credit;
- vendors or third party service providers in connection with loan products and services offered by S21 Credit;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
- collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
- credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;
- external banks, credit card companies and their respective service providers;
- our professional advisers such as auditors and lawyers;
- relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
- any other party to whom you authorise us to disclose your Personal Data to.
- A cookie is a small piece of information that is placed on your computer when you visit certain websites.
a. enabling certain features and functions on our websites, eg. remembering your user-id, favourite loan selections, browsing and other service preferences;
b. building up a profile of how you and other users use the website;
c. improving the efficiency of our website;
d. administering services to you and to advertisers;
3. and establishing usage statistics
- Most internet browsers provide you the option of turning off the processing of cookies , but this may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which it operates.
- S21 Credit is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the S21 Credit website.
Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
- If you:
a. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
b. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
c. would like to obtain access and make corrections to your Personal Data records, please contact S21 Credit as follows:Email: firstname.lastname@example.org
Write in: Data Protection Officer
Blk 704 Ang Mo Kio Avenue 8
- Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to StarHub on your behalf.
- If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, S21 Credit may not be in a position to continue to provide its loan products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with S21 Credit, and your being in breach of your contractual obligations or undertakings.
S21 Credit’s legal rights and remedies in such event are expressly reserved.
- This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.