Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how Custodia Pte. Ltd. manages personal data in accordance with the Singapore Personal Data Protection Act 2012 (the “Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Data, including your Personal Data.

 
By interacting with us, submitting information to us or signing up for any services offered by us, you agree and consent to Custodia Pte. Ltd., its employees, related corporations and affiliates, (collectively referred to herein as “Custodia“, “us“, “we” or “our“), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Data, including your Personal Data, and disclosing such Data to our authorised service providers and third parties in the manner set forth in this Privacy Policy.

We may from time to time update this Privacy Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on the Tessary Service website. Please check regularly for updated information on the handling of your Data.

For avoidance of doubt, this Privacy Policy forms a part of the terms and conditions of use of our Tessary Service (“Terms of Use”). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Terms of Use, the Privacy Policy shall prevail. All defined terms contained in the Terms of Use shall apply to this Privacy Policy unless otherwise specifically stated.
 

    1. Data Collected by Us
       

      1. Under this Privacy Policy, “Data” consists of Personal Data and Aggregate Information.
      2. “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):
        1. your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
        2. information about your use of the Tessary Service, but only to the extent that we may identify you from such information, including cookies, IP address, subscription account details and membership details;
        3. your employment history, education background, and income levels; or
        4. your payment related information, such as your bank account or credit card information, and your credit history.
      3. “Aggregate Information” is data or informatin from which you cannot be identified, such as the behaviour of an unnamed user when using the Tessary Service (including the frequency and duration of use of a particular website, product, or service), the number of page views (or page impressions) that occur on one of the Tessary Service websites, and common entry and exit points into the Tessary Service websites. We may derive Aggregate Information by aggregating or anonymising Personal Data given to us. Aggregating means presenting the information in groups or segments e.g. age groups or postal codes. Anonymising means stripping the information of personally identifiable features.
    2. Collection of Personal Data
       

      1. Generally, we collect your Personal Data in the following ways:
        1. when you submit forms relating to any of our products or services;
        2. when you upload any personal documents, including but not limited to, your will, title deeds, or bank account details;
        3. when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
        4. when you interact with our customer service officers;
        5. when you use the Tessary Service by way of establishing any mobile application or online accounts with us;
        6. when you request that we contact you;
        7. when you are contacted by, and respond to, our marketing representatives and agents;
        8. when you respond to our request for additional Data;
        9. when you ask to be included in an email or other mailing list;
        10. when you respond to our promotions and other initiatives;
        11. through our use of cookies and other technologies (see paragraph 5 below for more details on such technologies);
        12. when we receive references from business partners and third parties, for example, where you have been referred by them; and/or
        13. when you submit your Data to us for any other reason.
      2. If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
      3. If you request for any service that relates to the use of information on your location (“Location-based Service”), and we agree to provide such service, we may collect information on your location using GPS, Bluetooth, your IP Address, Wi-Fi hotspot, cell-tower locations, and other similar technologies. You may withdraw consent to our collection, use, transmission, processing and maintenance of location data at any time by not using the location-based features and turning off the location services settings (as applicable) on your device. When using third party services that use or provide location data as part of the Tessary Service, you are subject to and should review such third party’s terms and privacy policy on use of location data by such third party services.
      4. You should ensure that all Personal Data you submit to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
    3. Purposes for the Collection, Use and Disclosure of Personal Data
       

      1. Generally, we collect, use and disclose Personal Data for the following purposes:
        1. responding to your queries and requests and responding to complaints;
        2. managing our infrastructure and business operations, and complying with internal policies and procedures;
        3. matching any Personal Data held which relates to you for any of the purposes listed herein;
        4. verifying your identity;
        5. preventing, detecting and investigating crime, including money-laundering, and analysing and managing other commercial risks;
        6. protecting and enforcing our contractual and legal rights and obligations;
        7. conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
        8. preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances;
        9. compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
        10. conducting market research and customer satisfaction surveys to improve our customer service; develop new products, as well as personalise the services we offer you;
        11. improving our services, for example by looking at usage patterns;
        12. provide updates, offers, invitations to events and deliver relevant advertising, including through voice calls, emails and SMS, with your prior consent or if otherwise permitted under local laws and regulations;
        13. inform you of service and security issues;
        14. prevent and detect fraud or other crimes and recover debts;
        15. ensure the safety and security of our properties and systems; and/or
        16. any other purpose relating to any of the above.
      2. In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
        1. If you have an Account with us:
            1. to process your application for an Account;
            2. to maintain your Account with us;
            3. to verify and process your personal particulars and payments in relation to provision of any goods and services to you;
            4. to provide you with the goods and services which you have signed up for;
            5. communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
            6. resolving complaints and handling requests and enquiries;
            7. conducting market research for profiling and statistical analysis for the improvement of services provided by us; and
            8. the processing of your Personal Data in relation to any of the purposes stated above.
        2. If you use download or use the Tessary Service or any other services provided by us on one our websites and/or mobile platform:
          1. to process your application for subscription to the Tessary Service;
          2. to maintain your Account with us and to ensure your access of Tessary Service is within the scope of your subscription;
          3. to verify and process your personal particulars and payments in relation to the provision of goods and services connected to your Account;
          4. communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
          5. resolving complaints and handling requests and enquiries;
          6. conducting market research for profiling and statistical analysis for the improvement of services provided by us; and
          7. the processing of your Personal Data in relation to any of the purposes stated above.
      3. In relation to particular products or services or in your interactions with us, we may also specifically notify you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well.
    4. Disclosure of Personal Data
       

      1. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above, to the following third parties, whether they are located overseas or in Singapore:
        1. our employees and affiliates;
        2. agents, contractors or third party service providers who provide operational services to us, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to us;
        3. vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on our sites, whether in conjunction with us or not;
        4. external business and charity partners in relation to corporate promotional events;
        5. in the event of default or disputes, any debt collection agencies or dispute resolution centres and/or firms;
        6. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
        7. anyone to whom we transfer or may transfer our rights and duties;
        8. banks, credit card companies and their respective service providers;
        9. our professional advisors such as our auditors and lawyers;
        10. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
        11. any other party to whom you authorise us to disclose your personal data; and
        12. research institutions for market analysis purposes.
      2. In some cases, we may encrypt, aggregate and/or anonymise the information, turning such Personal Data into Aggregate Information, before sharing it.
      3. We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations.
      4. If we are involved in a reorganisation, merger, acquisition or sale of our assets, your Personal Data may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your Account) of any such deal and outline your choices in that event.
      5. If you request for any Location-based Services, and we agree to provide such Location-based Services, we may in the course of providing such Location-based Services, and in accordance with your instructions, disclose your location to the third-parties, or the relevant authorities (including the police).
    5. Cookies & Other Technologies
       

      1. The Tessary Service websites, online services, interactive applications, email messages, programs and advertisements may use cookies and other technologies, such as pixel tags, click-through URLs, and web beacons, to collect Personal Data and Aggregate Information from you. YOU MAY NOT BE AWARE OR NOTIFIED THAT SUCH SOFTWARE OR PROGRAM IS RUNNING AND/OR COLLECTING AGGREGATE INFORMATION AND PERSONAL DATA FROM YOU WHEN YOU USE THE TESSARY SERVICE.
      2. Should you wish to disable the cookies on any Tessary Service website, you may do so by changing the setting on your internet browser. However, you may not be able to access certain part(s) of our websites.
    6. Use and Disclosure of Aggregate Information
       

      1. We may collect and create Aggregate Information in the same way that we obtain Personal Data.
      2. For the purposes of collection and creation of Aggregate Information, we may also use an independent company (the “Third Party Market Research Company”) to collect, measure and analyse the usage across the Tessary Service. Such Third Party Market Research Company shall collect Aggregate Information in the same way that we do.
      3. Aggregate Information may be used for any purpose we deem fit.
      4. Aggregate Information may be processed by the Third Party Market Research Company and provided to us to assist in analysing the usage of the Tessary Service and any other purposes we deem fit.
      5. Aggregate Information may also be made accessible to media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
      6. We may also use Aggregate Information in the same way that we use Personal Data.
    7. Third-Party Sites
       
      In using the Tessary Service you may be shown links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to the Tessary Service. We encourage you to learn about the privacy policies of such third party websites. SOME OF THESE THIRD PARTY WEBSITES MAY BE CO-BRANDED WITH OUR NAME, LOGO OR TRADEMARK, EVEN THOUGH THEY ARE NOT OPERATED OR MAINTAINED BY US. Once you have left the Tessary Service you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
    8.  

    9. Withdrawal, Access and Correction of your Personal Data
       

      1. Should you wish to withdraw consent to the use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found at paragraph 9 below.
      2. Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.
      3. Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with us and you being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
    10. Personal Data Protection Officer
       
      The Personal Data Protection Officer is Chen Zaoxiang and can be contacted at wayne@tessary.com
    11.  

    12. Protecting Your Information
       
      We will take reasonable steps to protect your Personal Data against unauthorised disclosure, including:

      1. safeguards to prevent security breaches in our network and database systems;
      2. limits on access to information in our systems and the systems of our business partners and vendors; and
      3. strict verification processes to prevent unauthorised access to information.
    13. Respecting Your Contact Information
       

      1. We are committed to complying with the Do Not Call (DNC) provisions under the Act. We are always striving to engage our customers in more targeted and relevant ways. We may send marketing messages to your Singapore telephone number if:
        1. you have given us consent;
        2. you have not registered with the national DNC Registry, or
        3. the sending of such messages is permissible under applicable laws and regulations.
      2. We generally do not provide marketing messages. If we do, our marketing messages aim to update you about our offers, rewards programmes and special deals from us, or our preferred partners and advertisers.
      3. You can choose to continue receiving such messages or to opt out of receiving such messages.
      4. Please note that after opting out, you may still continue to receive non-marketing messages, such as product updates and service notices as permitted under applicable local laws and regulations.
    14. Governing Law and Dispute Resolution
       

      1. This Privacy Policy shall be governed in all respects by the laws of Singapore.
      2. All disputes, controversies, or difference arising out of or in connection with this Privacy Policy shall first be submitted to the Singapore Mediation Centre for resolution by mediation in accordance with the Mediation Procedure for the time being in force. The Parties agree to participate in the mediation in good faith and undertake to abide by the terms of any settlement reached.
      3. Any dispute arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this paragraph.
        1. The seat of the arbitration shall be Singapore.
        2. The Tribunal shall consist of one (1) arbitrator.
        3. The language of the arbitration shall be English.