1.1 This Policy statement provides information on the obligations and policies of MatcHub in respect of an individual’s Personal Data. MatcHub undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of MatcHub or that which shall be collected by MatcHub in the future.
2. Contacting the Data Protection Officer 2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of MatcHub, MatcHub shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, MatcHub has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that MatcHub receives your complaints and enquiries, please send via email to the Data Protection Officer (the “DPO”) of MatcHub at the following email address: contact＠matchub.co.
2.3 Please note that if your personal data has been provided to us by a third party, you should contact that individual to make such queries, complaints, and access and correction requests .
2.4 Should you not wish MatcHub to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within 30 days. Please note however that the Act is subject to other laws and regulations, and where such Personal Data is not required under such other laws and regulations, the and the services that you will be able to receive from us would be greatly affected.
2.5 We may rely on the legitimate interests exception of the Act to collect, use or disclose personal data without consent for some or all of the following purposes:
To prevent misuse of our services;
To prevent money laundering;
To prevent terrorism;
To prevent fraud;
Investigation or proceedings;
Recovering a debt from you;
Paying a debt to you;
In the course of the provision of legal services or obtaining legal services;
Where the collection, use, or disclosure of your personal data is for the purposes of the preparation of a credit report by a credit bureau, or where the collection, use, or disclosure of the personal data relates to the provision of a credit report provided by a credit bureau to a member of the credit bureau in relation to a transaction between you and the member of the credit bureau.
To confer an interest or a benefit under a private trust or benefit plan / administer that trust or benefit plan, at the request of the settlor or the person establishing the benefit plan, as the case may be;
Where the personal data is provided to us by another individual to enable the organisation to provide a service for the personal or domestic purposes of that other individual and is collected, used or disclosed (as the case may be) by us solely for that purpose;
Where the personal data is included in a document produced in the course, and for the purposes, of an individual’s employment, business or profession and is collected, used or disclosed (as the case may be) for purposes consistent with the purpose for which the document was produced; and
For entering into an employment relationship with the individual or appointing the individual to any office or managing or terminating the employment relationship with or appointment of the individual.
2.6 For more information on our reliance on the legitimate interests exception, please contact the relevant DPO as listed in Clause 2.2. 3. Statement of Practices Types of Personal Data Collected: 3.1 As part of its day-to-day activity, MatcHub may collect from you, through various means, including via forms used by MatcHub from time to time, some or all of the following data:
Education information and history;
Bank account/credit card details;
Photographs and images.
Purpose of Collection of Personal Data 3.2 Where the data mentioned in Clause 3.1 falls within the definition of Personal Data under the Act, such Personal Data is collected for the purposes of our; for creation of your online account on our website; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and access; for security purposes; and any other purposes as notified to you from time to time.
Disclosure of Personal Data 3.3 In order to carry out the functions described above, MatcHub may, from time to time, disclose your Personal Data to MatcHub’s employees, and authorised service providers and vendors including but not limited to the payment processing vendor.
3.4 Without derogating from any of the above, MatcHub may also disclose your Personal Data to the following third parties:
Regulators and law enforcement officials;
Third party service providers and consultants;
Credit, debit and charge card companies, banks and other entities processing payment; and
Any agent or subcontractor acting on MatcHub’s behalf for the provision of MatcHub’s services.
3.5 MatcHub may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
To the extent that MatcHub is required to do so by the law;
In connection with any legal proceedings or prospective legal proceedings;
To establish, exercise or defend MatcHub’s legal rights;
To the purchaser (or prospective purchaser) of any asset which MatcHub is (or is contemplating) selling;
To any person and/or entity for the purpose of processing such information on MatcHub’s behalf;
To third parties who provide services to MatcHub or on its behalf;
With your consent; and
For the purposes of disaster recovery.
3.6 Under certain circumstances, telephone calls made to MatcHub’s office may be recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or request, and for quality control and training purposes.
4. Transfer of Personal Data Overseas Your Personal Data may, in the future, be processed by MatcHub, its affiliates, agents and third parties providing services to MatcHub, in jurisdictions outside of Singapore as Personal Data may be stored in servers located outside of Singapore. In this event MatcHub will comply with the terms of the Act.
5. Accuracy of Personal Data Where possible, MatcHub will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, MatcHub is able to validate the data provided against pre-existing data held by MatcHub. In some cases, MatcHub is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of MatcHub, please update the information on your profile with us regularly or if that is not possible, at the email address provided at Clause 2.2.
6. Protection of Personal Data MatcHub uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly anyone outside MatcHub access to this data, other than to you or as described in this Policy. However, MatcHub cannot ensure or warrant the security of any information you transmit to MatcHub and you do so entirely at your own risk.
7. Access and Correction of Personal Data 7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
Check whether MatcHub holds any Personal Data relating to you and, if so, ; and
Require MatcHub to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 MatcHub reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.
7.3 If you wish to verify the details you have submitted to MatcHub or if you wish to check on the manner in which MatcHub uses and processes your personal data, MatcHub’s security procedures mean that MatcHub may request proof of identity before we reveal information. 8. Storage and Retention of Personal Data MatcHub will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of MatcHub and where the Personal Data is deleted from MatcHub’s electronic, manual, and other filing systems in accordance with MatcHub’s internal procedures and/or other agreements.
9. Contacting you MatcHub will be allowed to contact you using all of the communication means you have provided to MatcHub, for the purposes as stated above in Clause 3.2.
10. Changes to Policy MatcHub reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by MatcHub. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the exclusive jurisdiction of the Singapore courts.