Horangi Data Protection Policy

(Last updated on 23 February 2017)

  1. This Horangi Data Protection Policy (“HDPP”) applies to your Personal Data collected by Horangi Pte Ltd (“Horangi”) (referred to herein as “us”, “we” or “our”).
  2. This HDPP sets out how Horangi manages Personal Data in compliance with the Personal Data protection principles under the Personal Data Protection Act (Act No. 26 of 2012). Please take a moment to read this HDPP so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
  3. This HDPP describes how we may collect, use, disclose, process and/or manage your Personal Data and applies to all Personal Data that you provide to us and the Personal Data we hold about you. By providing us with your Personal Data, you consent to our collection, use and disclosure (including transfer) of your Personal Data in accordance with this HDPP. Please DO NOT provide any Personal Data to us if you do not accept this HDPP.
  4. Horangi may, from time to time, update the HDPP to ensure its consistency with future developments, legal and regulatory requirements, and changing organisational needs. You acknowledge and agree to be bound by this HDPP, as may be amended from time to time by us. Please check back regularly for updated information on the handling of your Personal Data.
  5. Personal Data
    1. In this HDPP, “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 Personal Data include name, address, contact details, identification numbers, telephone numbers, email address and photographs.
    2. For the purposes of this HDPP, Personal Data excludes any business contact information (i.e. an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes).
    3. Your provision of Personal Data to us is voluntary. However, if you choose not to provide us with the Personal Data we require, it may not be possible for us to contact you or provide you with the products or services that you require from us.
    4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
  6. Collection of Personal Data
    1. Generally, we collect Personal Data when you:
      1. register for any of our products or services;
      2. use any of our products or services;
      3. submit any Personal Data or document concerning any Personal Data to us;
      4. perform an online transaction on any of our platforms;
      5. report a problem with any of our platforms;
      6. fill in our surveys and provide feedback;
      7. access or request for access to our premises;
      8. contact us whether through email, fax, telephone, or writing; and/or
      9. submit your Personal Data to us for any other reason.
    2. If you provide us with any Personal Data relating to a third party, by submitting such information to us, you represent and warrant to us that you have obtained the consent of that third party to provide us with their Personal Data for the respective purposes. In this regard, you agree to indemnify us against any complaint, claim, damage, loss, penalty or fines relating to this representation and warranty on Personal Data relating to the third party.
  7. Purposes for the Collection, Use and Disclosure of your Personal Data
    1. Generally, Horangi collects, uses and discloses your Personal Data for the following purposes:
      1. Service-related purposes, which include but are not limited to:
        1. Managing your relationship with us;
        2. Providing you with the products and services that you have requested, including products and services from third party service providers;
        3. Assisting you with your enquiries, complaints, and related requests;
        4. Contacting you for feedback after the provision of our products and services; and
        5. Keeping you informed and updated on our products and services.
      2. Purposes connected or relevant to our business, which include but are not limited to:
        1. complying with our legal obligations and requirements;
        2. enforcing obligations owed to us;
        3. research into the development of new products and services or improvement of our existing products and services;
        4. processing data relating to accounting, risk management and record keeping;
        5. carrying out research, planning and statistical analysis; and
        6. staff training.
      3. Marketing-related purposes, which include but are not limited to:
        1. Sending marketing messages to you in various modes including but not limited to electronic mail, direct mailers, facsimile, short messaging service, telephone calls, and other mobile message services. We will only send marketing messages to your Singapore telephone number via SMS, telephone calls and other mobile messaging services, if we have your clear and unambiguous consent to do so or if you have not registered your number with the Do Not Call registry.
  8. Disclosure of Personal Data
    1. Horangi will take reasonable steps to protect your Personal Data against unauthorised disclosure.
    2. Subject to the provisions of any applicable law, your Personal Data may be disclosed by Horangi to service providers for the purposes as set out at Clause 7 above. In this regard, you agree that we may disclose your Personal Data to third parties whom we engaged to provide necessary products or services, including but not limited to:
      1. Service providers and/or data processors working on our behalf and providing services such as human resource management, debt collecting, hosting and maintenance services, delivery services, handling of payment transactions, marketing, etc;
      2. our consultants and professional advisers (such as accountants, lawyers, auditors, managing agents); and
      3. service providers assisting us in the provision of products and services to you.
    3. You agree that we may also disclose your Personal Data as required or permitted by law. You also agree that we may disclose your Personal Data to regulatory authorities, statutory bodies or public agencies for the purposes of complying with their respective requirements, policies, directives, guidelines and/or contracts.
  9. Transfer of Personal Data out of Singapore
    1. You consent to us transferring your Personal Data to any location outside of Singapore for the purposes set out at Clause 7 above.
    2. If we transfer your Personal Data to a country or territory outside of Singapore, we will ensure that the recipient of the Personal Data provides a standard of protection that is comparable to the protection which your Personal Data enjoys under the laws of Singapore. In this regard, the recipients will be under legally binding obligations to:
      1. ensure that the collection, use and/or disclosure of your Personal Data would be for the purpose(s) for which you have given consent;
      2. take steps to ensure accuracy and completeness of your Personal Data when your Personal Data is used to make a decision that affects you, or if it is to be disclosed to third parties;
      3. make security arrangements to protect your Personal Data; and
      4. only retain your Personal Data if necessary for legal and business purposes.
  10. Retention of Personal Data
    1. We will retain Personal Data to fulfil the abovementioned purposes set out at Clause 7 above and in accordance with our legal and business purposes.
  11. Data Security
    1. Horangi will take reasonable efforts to protect Personal Data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot guarantee the security of any Personal Data we may have collected from or about you, or that no malicious code (such as viruses, bugs, trojan horses, spyware, adware or other malware) will enter the platforms on which Personal Data is hosted.
    2. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you use our online portals. We urge you to take every precaution to protect your Personal Data when you are on the Internet.
  12. Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
    1. If you have any questions or concerns regarding any aspect of this HDPP or the Personal Data you have provided or wish to make a request or withdraw your consent given for any or all purposes set out in this Policy, you can contact our Data Protection Officer at legal@horangi.com.
    2. We may not be in a position to continue to provide our products or services to you if you withdraw your consent for purposes that are necessary for the provision of such products or services.
    3. You may request for correction or access to the Personal Data we have collected about you. However, please note that we may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so or if our records have been destroyed in accordance with our internal data retention policies.
  13. Liability
    1. Under no circumstances will we be liable for any indirect, incidental, special, punitive or consequential damages whatsoever, including but not limited to loss of revenues, profits or business or business interruption arising out of or in connection with this HDPP, regardless of whether such damages could have been foreseen or prevented by either Party.
    2. Without prejudice to the application of Clause 13.1, to the extent permitted by law, in no event shall our aggregate liability, or our liability to any third party, for damages, direct or otherwise, arising out of or in connection with this HDPP, exceed the total value equivalent to any fee or payment made by you to us, or any contract sum contained in any agreement entered between you and us.
    3. Nothing in this HDPP shall be construed to limit or exclude our liability for death or personal injury caused by us or for fraudulent misrepresentation or fraud.
  14. Governing Law
    1. This HDPP shall be governed in all respects by the laws of the Republic of Singapore.
    2. You agree any dispute or claim arising out of or in connection with this HDPP shall be subject to the exclusive jurisdiction of the Singapore courts.