iLEX PRIVACY NOTICE
Last updated on 10 June 2020
1.1 iLex respects your privacy and is committed to protecting your personal data. This privacy notice will give you information on how iLex collects and processes your personal data and tell you about your privacy rights.
1.2 This privacy notice applies to all services we provide and to the platforms, websites (including our public website ilex.sg) or apps we own and operate (the “Platform“).
1.3 We continually improve our methods of communication and adding new functionality and features to the Platform and our services. As such, we keep our privacy notice under regular review and we may amend it. We encourage you to check this privacy notice frequently and anytime you submit personal data via the Platform.
2. Who are we?
2.1 The terms “iLex”, “we”, “us”, “our” and “ours” when used in this privacy notice includes Institutional Lending Exchange Pte. Ltd., our subsidiaries, divisions, branches, affiliates or companies under the control of Institutional Lending Exchange Pte. Ltd..
2.2 We have appointed a data protection officer (DPO). If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Attention to iLex DPO
Email address: [email protected]
Postal address: Institutional Lending Exchange Pte. Ltd., 36 Carpenter Street, The Hive, Singapore 059915
3. Which personal data might be collected?
3.1 When we use the term “personal data”, we mean any information about you (as individual) from which you can be identified like:
- Identity Data – e.g. first name, last name, username or similar identifier, title;
- Contact Data – g. billing address, email address and telephone numbers;
- Financial Data – bank account and payment card details;
- Transaction Data – details about payments to and from you and other details of Services you have purchased from us;
- Technical Data – e.g. IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform;
- Profile Data – e.g. your username and password, purchases or orders made by you, preferences, feedback and survey responses;
- Usage Data – e.g. information about how you use our Platform and services; and
- Marketing and Communications Data – e.g. your preferences in receiving marketing from us and, as the case maybe, our third parties and your communication preferences.
3.2 Is it compulsory to provide us personal data?
No. You are not obliged to provide us with personal data. In such a case, it means that you might not be able to use our Platform and/or we may not be able to perform our services. We may also have to cancel a service you have with us but we will notify you if this is the case.
3.3 What about aggregated and anonymised data?
The term “personal data” does not include data which can’t identify you. For example, we may create aggregated and anonymised data (such as statistical or demographic data for our own purpose) which will not directly or indirectly reveal your identity. For example, we may aggregate your personal data to calculate the percentage of users accessing a specific Platform feature, to improve our services, to identify trends, develop new services, etc. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
3.4 Which data we do not collect?
We do not collect any special categories of personal data about you (like details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. How is your personal data collected?
We use different methods to collect data from and about you including through:
4.1 Data you provide us directly when you use our Platform/services like your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our services, create an account on our Platform, subscribe to our publications, request marketing to be sent to you, enter a promotion or survey or give us feedback or contact us.
4.2 Data we collect automatically when you interact with our Platform (automated technologies or interactions) like Technical Data about your equipment, browsing actions and patterns.
- A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
- We may use the following cookies:
- Strictly necessary cookies – these are cookies that are required for the operation of our Platform. They include, for example, cookies that enable you to log into secure areas of our Platform;
- Analytical or performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our Platform when they are using it. This helps us to improve the way our Platform works, for example, by ensuring that users are finding what they are looking for easily;
- Functionality cookies – these are used to recognise you when you return to our Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region);
- Targeting cookies – these cookies record your visit to our Platform, the pages you have visited and the links you have followed. We will use this information to make our Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
- You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Platform.
4.3 Data we get from third-parties (or publicly available sources) like Technical Data from analytics providers, advertising networks, search information providers, Identity and Contact Data from publicly available sources, etc. In the event that you are an individual who does not have any relationship with us, but you believe that an iLex client or user has provided us your personal data, please contact that iLex client or user for any questions you may have about your personal data.
5. How do we use your personal data?
5.1 We will only use your personal data when the law allows us to.
5.2 When collected, we will use your personal data to perform a contract with you, to comply with a legal obligation or where it is necessary for our legitimate interests and they’re not overridden by your rights.
5.3 This includes using your personal data for the following purposes:
- to manage our relationship with you;
- to communicate with you;
- to assist you;
- to improve our Platform and services, marketing, customer relationship and experiences and develop new services;
- to protect you from fraudulent activities, administer and protect our business and Platform;
- to market to you (refer to details below); and
- to analyse, aggregate and report (aggregated and anonymised data).
5.4 Generally, we do not rely on consent as a legal basis for processing your personal data and we may process your personal data without your knowledge or consent, in compliance with this privacy notice, where this is required or permitted by law.
5.5 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
5.6 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.7 Specific case of Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
- Promotional offers from us – We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us but you can opt out of receiving that
- Third-party marketing – we will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- Opting out – You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of you using our Platform and/or services.
6. How can we share your personal data?
6.1 If we need to share your personal data with third parties, we will only disclose it to:
- other companies in the iLex group of companies;
- third parties service providers;
- professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
- regulators and other authorities who require reporting of processing activities in certain circumstances; and
6.2We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. Can your personal data be transferred to another country?
If and when we share data, it may be transferred out of the country you reside, for example to Singapore where our IT servers are located or to any other country where iLex group companies may be located from time to time or where we have a data backup location (Australia). In such cases, we will ensure your personal data is protected by, in addition to any other safeguards we may put in place, ensuring transfer of your personal data only to overseas organisations which are bound (either by law, contract or otherwise) to provide a standard of protection which is comparable to that under the Data Protection Act 2012 (Singapore).
8. How is your data secured?
8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How long may we use your personal data for?
9.1 We will only retain your personal data for as long as we have a relationship with you or as long as it is reasonably necessary to fulfil the purposes we collected it for. Following that period, we will make sure it is deleted or anonymised (in which case we may use this information indefinitely without further notice to you).
9.2 However, we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
9.3 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
10. What are your legal rights?
10.1 Under certain circumstances, you have rights under data protection laws in relation to your personal data:
- Request access to your personal data – this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of your personal data – this enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data – this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data – where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request transfer of your personal data to you or to a third party – we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Right to withdraw consent at any time where we are relying on consent to process your personal data – however, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
10.2 If you wish to exercise any of the rights set out above, please contact us at [email protected]
10.3 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
10.4 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.5 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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