SCash Privacy policy

3.1.     We may collect, use and disclose your Personal Data for the following purposes:

3.1.1.        To register you as a user or new customer or Merchant and manage your account; 

3.1.2.        To facilitate your access to and use of our services on the Platform; 

3.1.3.        To process orders, payments, refunds and deliveries of your order(s); 

3.1.4.        To manage your account, including managing payments, fees and charges and collecting and recovering money owed to us; 

3.1.5.        To manage and maintain our relationship with you; 

3.1.6.        To display your name, username or profile on the Platform. 

3.1.7.        To operate, maintain, secure and improve our business and Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that fraud prevention;

3.1.8.        To deliver personalized content, advertisements and recommendations to you; 

3.1.9.        To conduct marketing campaigns, promotions, surveys and events; 

3.1.10.     To contact and communicate with you in relation to the above purposes; and 

3.1.11.     To comply with applicable laws, regulations and lawful requests by authorities.

3.2       Legal Basis

            We collect, use and disclose Personal Data based on one or more of the following legal bases under the PDPA:

3.2.1.  your consent (including express and deemed consent by conduct or contractual necessity;           

         3.2.2. deemed consent by notification, where permitted by the PDPA, after providing you with clear notice and a reasonable opt-out period and assessing no likely adverse effect; 

            3.2.3.   legitimate interests, where the benefits to SCash or another person outweigh any likely adverse effect on you. We identify the legitimate interest, assess and mitigate adverse effects, and document our assessment; 

            3.2.4. business improvement purposes permitted under the PDPA; and 

            3.2.5. where required or authorised by applicable law. 

3.3       Legitimate Interests

            In certain circumstances, we may collect, use or disclose your Personal Data without your consent where such collection, use or disclosure is permitted under the Personal Data Protection Act 2012 of Singapore (“PDPA”), including where it is necessary for our legitimate interests or those of another person, and such legitimate interests outweigh any adverse effect on the individual.

            Before relying on legitimate interests as a legal basis, we will:

·                      identify the legitimate interests being pursued;

·                      assess the likely adverse effects on the individual; and

·                      implement reasonable measures to eliminate, mitigate or reduce such adverse effects.

            Examples of legitimate interests that we may rely on include:

·                     detecting, preventing or investigating fraud, security breaches or other potentially illegal activities;

·                     ensuring network and information security of our Platform and systems;

·                     preventing misuse or abuse of our services;

·                     business operations such as internal audits, risk management and data analytics; and

·                     enforcing our contractual rights, policies and terms of use.

            Where required under the PDPA, we will provide appropriate notification to individuals of the purposes and legitimate interests relied upon prior to, or as soon as reasonably practicable after, the collection, use or disclosure of Personal Data.