The privacy policy herein (“Privacy Policy”) is applicable to the Platform (as defined in the TCU or “general terms and conditions of use”) provided by KHALON & GILL MONEYLENDERS PTE LTD (UEN No. 201725475H) (“KHALON & GILL MONEYLENDERS PTE LTD ”) to which you may have access. It sets out the basis on which KHALON & GILL MONEYLENDERS PTE LTD collects Personal Data from you and how we process your Personal Data in accordance with the Singapore Personal Data Protection Act (“PDPA”).
The security of your Personal Data is important to KHALON & GILL MONEYLENDERS PTE LTD. KHALON & GILL MONEYLENDERS PTE LTD has in place safeguards to protect the Personal Data stored with it. This Privacy Policy describes how KHALON & GILL MONEYLENDERS PTE LTD may collect, use, disclose, process and manage your Personal Data and applies to any individual’s Personal Data which is in our possession or under our control.
By visiting our Platform, you accept and consent to the practices set out below.
- Agreement
By accessing the Platform, you agree to be bound by the terms in this Privacy Policy herein, our TCU (please access and read the same here ) and Declaration (please access and read the same here ) (collectively the “Terms of Use”).
By accessing the Platform you agree that you have thoroughly read and understood the TCU and Agreement, as well as agree to be bound by the TCU and Agreement. If you do not agree with any part of this Privacy Policy, you must immediately discontinue your access and any use of the Platform.
You agree that KHALON & GILL MONEYLENDERS PTE LTD may modify, delete or replace this Privacy Policy at any time in its sole and absolute discretion and without prior notice to you. Such changes may be published online, will constitute sufficient notice to you, and will be effective upon publication. If you continue to access and/or use the Platform after the change or addition takes effect, you are deemed to have accepted the change or addition without reservation. It is your responsibility to review this Privacy Policy periodically to ensure familiarity with its content.
- Definition of Personal Data
“Personal Data” is defined as data that can be used to uniquely identify a natural person. It means any data, regardless of its format, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access.
Personal Data can be collected from various sources and processed by KHALON & GILL MONEYLENDERS PTE LTD. Without limitation, some examples of data which on its own or jointly, can be used to identify a natural person are:
- personal particulars (e.g. name, contact details, residential address, date of birth, identity card/passport details, and/or education details);
- specimen signature(s);
- financial details (e.g. income, expenses, and/or credit history);
- images and biometrics such as thumbprints, voice and video recordings of you, including our conversations with you for verification or other purposes;
- employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- tax and insurance information;
- information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
- banking information (e.g. account numbers and banking transactions);
- your personal opinions made known to KHALON & GILL MONEYLENDERS PTE LTD e.g. through feedback or surveys;
- information relating to your activities, habits, preferences and interests arising from your use of the Platform, our partners or vendors; and/or
- other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of the Platform or as part of their delivery to you.
- Process, Collection, Use and Disclosure of Personal Data
For the purposes outlined below, we may collect and process the following information about you:
(a) information that you provide us (which may include your name, national identity number, address, email address, telephone number, credit card information, financial information and other Personal Data) by filling in forms on our Platform, or by corresponding with us (by phone, email or otherwise), for example;
(i) when you register for an account with us on our Platform;
(ii) when you register for an account with us on our Platform;
(iii) when you report any problem to us;
(iv) when you use certain features on our Platform; or
(v) when you complete any survey or questionnaire we send you.
(b) Information we collect about you – information automatically collected when you visit our Platform, for example:
(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(ii) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number; and
(c) Information we receive from third parties – We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
We only retain Personal Data for so long as it is necessary and in accordance with law and regulation. Data may be archived as long as the purpose for which the Personal Data was used still exists.
KHALON & GILL MONEYLENDERS PTE LTD may collect, process, use or disclose your Personal Data for our business purposes, including without limitation:
- developing and providing the Platform (whether made available by KHALON & GILL MONEYLENDERS PTE LTD), including but not limited to;
- executing loans or other transactions and requests, including processing, settlement, clearing or reporting on these loans or transactions;
- carrying out research, planning and statistical analysis; or
- assessing and processing applications, instructions or requests from you;
- communicating with you, including providing you with updates on changes to the Platform and loan facilities (whether made available by KHALON & GILL MONEYLENDERS PTE LTD) including any additions, expansions, suspensions and replacements of or to the Platform and loan facilities and their terms and conditions;
- managing our infrastructure, business operations and complying with internal policies and procedures;
- responding to queries or feedback;
- addressing or investigating any complaints, claims or disputes;
- verifying your identity for the purposes of providing the Platform or loan facilities;
- conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
- complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any Singaporean or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
- monitoring products and services provided by or made available through KHALON & GILL MONEYLENDERS PTE LTD;
- complying with obligations and requirements imposed by KHALON & GILL MONEYLENDERS PTE LTD from time to time by any credit bureau or credit information sharing services of which KHALON & GILL MONEYLENDERS PTE LTD is a member or subscriber;
- creating and maintaining credit and risk related models;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enabling any actual or proposed assignee or transferee, participant or sub-participant of KHALON & GILL MONEYLENDERS PTE LTD’s rights or obligations to evaluate any proposed transaction;
- enforcing obligations owed to KHALON & GILL MONEYLENDERS PTE LTD;
- in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice;
- administering benefits or entitlements in connection with our relationship with you or arising from your participation in events, campaigns, or marketing promotions by KHALON & GILL MONEYLENDERS PTE LTD or in conjunction with our partners. This will include the administration of loyalty, rewards programmers, lucky draws, and/or sending gifts and awards;
- providing, improving and developing our services;
- researching, designing and launching new features or products;
- presenting content and information in our Platform in the most effective manner for you and for the device you use;
- providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
- complying with laws and regulations applicable to us in or outside of Singapore;
- responding or taking part in legal proceedings, including seeking professional advice;
- for direct marketing purposes;
- communicating with you and responding to your questions or requests; and
- purposes directly related or incidental to the above.
In addition to the above purposes, KHALON & GILL MONEYLENDERS PTE LTD may also use Personal Data for purposes set out in the TCU and other terms and conditions that govern our relationship with you.
We may use your Personal Data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:
(a) the Personal Data that may be used in direct marketing are those that you provide to us or we collect from you as stated above;
(b) the type of services or products that may be offered or advertised will be our products or services, seminars, conferences or events, and those of our affiliates or business partners;
(c) the relevant information may be sent to you by email, in-app message or phone message or call;
(d) you may opt out at any time by calling us at 63921251 . We will cease to send you marketing information without charge.
You acknowledge that we will disclose your Personal Data to our partners in the course of providing services to you, and that your Personal Data will be used by our partners for the purposes of providing loan services to you, including but not limited to:
(a) verifying your identity;
(b) retrieving of data and reports from the Moneylenders Credit Bureau and any other credit bureaus;
(c) generating personalised loan offers for you;
(d) contacting you to finalise loan terms and arrange for execution of loan documents; and
(e) any other purposes directly related or incidental to the above, and in such case you acknowledge that your Personal Data will be subject to our partners’ respective privacy policies.
4. Security Measures
KHALON & GILL MONEYLENDERS PTE LTD shall protect your Personal Data in the KHALON & GILL MONEYLENDERS PTE LTD’s control or possession by making reasonable security arrangements (including, where appropriate, physical, administrative, procedural and information & communications technology measures) to prevent:
- unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of your Personal Data, or other similar risks; and
- the loss of any storage medium or device on which Personal Data is stored.
All information you provide to us is stored on our secure servers.
We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Platform; any transmission is at your own risk.
- Use of Personal Data for Marketing Purposes
KHALON & GILL MONEYLENDERS PTE LTD may use your Personal Data to recommend you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, KHALON & GILL MONEYLENDERS PTE LTD will comply with the Personal Data Protection Act of Singapore.
- Disclosure and Sharing of Personal Data
In order to carry out the purposes set out herein, KHALON & GILL MONEYLENDERS PTE LTD may from time to time and in compliance with all applicable laws on data privacy disclose your Personal Data to any personnel of KHALON & GILL MONEYLENDERS PTE LTD or to third parties, whether located in Singapore or outside of Singapore.
Please be assured that when KHALON & GILL MONEYLENDERS PTE LTD discloses your Personal Data to any third party, KHALON & GILL MONEYLENDERS PTE LTD requires them to ensure that any Personal Data disclosed to them are kept confidential and secure. Further, Personal Data transferred outside Singapore by way of disclosure to third parties will be protected at a standard that is comparable to the PDPA.
KHALON & GILL MONEYLENDERS PTE LTD wishes to emphasise that KHALON & GILL MONEYLENDERS PTE LTD does not sell Personal Data to any third parties and KHALON & GILL MONEYLENDERS PTE LTD shall remain fully compliant to any duty or obligation of confidentiality imposed on KHALON & GILL MONEYLENDERS PTE LTD under the TCU and Agreement that governs our relationship with you or KHALON & GILL MONEYLENDERS PTE LTD’s customers or any applicable law.
The Platform and/or our communications with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites and understand your rights. We accept no responsibility or liability for any practices of third-party websites.
We will keep your Personal Data we hold confidential but you agree we may provide information to:
(a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act (Chapter 50);
(b) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the provision of support services);
(c) our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
(d) our partners (including licensed moneylenders and banks);
(e) persons under a duty of confidentiality to us;
(f) persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Singapore; or
(g) actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Singapore.
We will reasonably endeavour to ensure that any third party who receives your Personal Data from us shall handle such Personal Data in accordance with applicable laws and regulations.
The Personal Data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by persons referred to above who operate outside Singapore. In such case, the following will apply:
(a) where we transfer your Personal Data to countries outside of Singapore, we will obtain your consent for such transfer to be made and will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA;
(b) by submitting your Personal Data you agree to this transfer, storing or processing of data outside Singapore. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy Policy
- Cookies and Related Technologies
Our Platform uses cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.
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 to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.
We may use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Platform or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
We may use the following cookies:
(a) 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, use a shopping cart or make use of e-billing services.
(b) Analytical/performance cookies – They 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 helping users find what they are looking for more easily.
(c) 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).
(d) Targeting cookies – These cookies record your visits 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 information displayed on it more relevant to your interests.
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 do so, you may not be able to access all or parts of our Platform.
We may use third-party web services on our Platform. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Platform and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.
- Other Websites
Our Platform may contain links to other websites which are not maintained by KHALON & GILL MONEYLENDERS PTE LTD. This Privacy Policy only applies to the websites and mobile application pages of KHALON & GILL MONEYLENDERS PTE LTD. When visiting these third-party websites, you should read their privacy policies which will apply to your use of the third-party websites.
- Retention of Personal Data
Your Personal Data is retained as long as the purpose for which it was collected remains, and until it is no longer necessary to serve the purposes of the agreement between you and KHALON & GILL MONEYLENDERS PTE LTD as set out in the TCU, or for any other legal or business purposes.
- Accuracy of Personal Data
Where you provide Personal Data to KHALON & GILL MONEYLENDERS PTE LTD, you shall make reasonable effort to ensure that the Personal Data is accurate and complete before providing the same to KHALON & GILL MONEYLENDERS PTE LTD. KHALON & GILL MONEYLENDERS PTE LTD shall put in place adequate measures to ensure that the Personal Data in its possession or control remain or is otherwise accurate and complete. In any case, KHALON & GILL MONEYLENDERS PTE LTD shall take steps to correct any errors in the Personal Data as soon as practicable upon your written request.
- Access and Correction
You may request access or make corrections to your Personal Data held by KHALON & GILL MONEYLENDERS PTE LTD by way of a written request. You have the right to:
(a) check whether we hold Personal Data about you;
(b) access any Personal Data we hold about you; and
(c) require us to correct any inaccuracy or error in any Personal Data we hold about you.
Any such request may be subject to a small administrative fee to meet our cost in processing your request. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
- Contact Us
To contact KHALON & GILL MONEYLENDERS PTE LTD on any aspect of this policy or your Personal Data or to provide any feedback that you may have, please visit any of our branches or get in touch with our data protection officer in the following ways:
Tel: +65-63921251
Email: enquiry@khalonandgillml.com
In addition, should KHALON & GILL MONEYLENDERS PTE LTD be aware that your Personal Data has been compromised and is, or likely to result in significant harm to you, KHALON & GILL MONEYLENDERS PTE LTD will notify you and advise on the possible steps to protect yourself from further potential harm.
- Amendments and Updates of KHALON & GILL MONEYLENDERS PTE LTD ’s Privacy Policy
KHALON & GILL MONEYLENDERS PTE LTD may in its sole discretion amend this Privacy Policy from time to time to ensure that this policy is consistent with any developments to the way KHALON & GILL MONEYLENDERS PTE LTD uses your Personal Data or any changes to the laws and regulations applicable to KHALON & GILL MONEYLENDERS PTE LTD. KHALON & GILL MONEYLENDERS PTE LTD will make available the updated Privacy Policy on our website (Insert website link to privacy policy). All communications, transactions and dealings with KHALON & GILL MONEYLENDERS PTE LTD shall be subject to the latest version of this Privacy Policy in force at the time. By continuing to use our Platform when the changes come into effect, you agree to be bound by the revised and latest Privacy Policy.
- Governing Law & Jurisdiction
This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts in the event of any dispute.
- Special handling of NRIC numbers
As of 1 September 2019, the Singapore Personal Data Protection Commission issued stricter rules regarding organisations’ collection, use and handling of NRIC numbers.
Given our role, we collect your NRIC number and disclose this to partners to facilitate provision of services in accordance with applicable law and regulation. We detail below the purposes for our collection and use of your NRIC number:
(a) Compliance with legal requirements under the Moneylenders Act: Pursuant to the Singapore Moneylenders Act, licensed moneylenders must obtain NRIC numbers (among other Personal Data) of every loan applicant before granting loans; and
(b) Compliance with legal requirements under the Moneylenders Act: Pursuant to the Singapore Moneylenders Act, licensed moneylenders must obtain NRIC numbers (among other Personal Data) of every loan applicant before granting loans; and;
Given the risks and potential impact of any unauthorised use or disclosure of Personal Data associated with your NRIC number, we provide a greater level of security to protect your NRIC number by storing your NRIC number in an encrypted database. We will not disclose your NRIC number to any merchant or third party unless you agree to.
We collect your full NRIC number at the time of registration and store this for as long as reasonably necessary and in accordance with law. We are committed to protecting your privacy and you have our assurance that we will handle and protect your NRIC number with particular care.