1. PURPOSE OF NOTICE STATEMENT
The following is the privacy notice statement (“Privacy Notice”) of Ample Transfers Pte. Ltd. (formerly known as AmeerTech Remittance & Exchange Services Pte. Ltd.) (collectively, “we”, “our”, or “us”) and sets forth our policies & practices in connection with personal data that we collect through our website, and any mobile sites, applications, or other mobile interactive features (collectively, the “Platform”).
Our Notice is to comply—and ensure that our employees comply—with the requirements of the Singapore Personal Data Protection Act (2012) (“PDPA”) and any other relevant privacy laws in the locations in which we operate.
In order to use the services provided on our Platform, you will have to share your personal data with us.
This Privacy Notice explains how we handle personal data you share with Ample Transfers.
“Personal data” is personally identifiable information that identifies you as an individual, such as your name, mailing address, email address, age range, and the like. Personal data is only obtained when you voluntarily provide the information to us. We use personal data to better understand your needs and interests and to provide you with better service.
“Data Subjects” are Individuals accessing the Platform or who are registering to use the services on the Platform and who voluntarily provide personal data to us (“you” or “your”) are covered by this Privacy Notice.
3. AMPLE TRANSFERS PRIVACY PRINCIPLES
Your privacy matters to us. Our business has been built on trust between our customers and ourselves. To preserve the confidentiality of all information you provide to us, we shall maintain the following privacy principles:
(a) we will first obtain your consent to collect, use, or disclose your personal data;
(b) we only collect personal data that we believe to be relevant and necessary, in order to help us conduct our business;
(c) we use your personal data to provide you with better customer services and products;
(d) where your consent has been provided, your personal data may be transferred to third parties, including other Ample Transfers companies or agents, as may be advised to you, either within or outside Singapore, and as permitted by law. Any contracts with these third parties will include the necessary provisions to safeguard the personal data that is being transferred to them in accordance with the PDPA;
(e) we may be required from time to time to disclose your personal information to governmental or judicial bodies or agencies or our regulators, if required to do so by law;
(f) we shall take reasonable measures to ensure that your personal data in our possession or control is accurate and up-to-date;
(g) we protect the personal data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, or disposal of such data.
(h) we may collect, use and disclose your personal data pursuant to an exception under the Personal Data Protection Act or as required/authorised under any other written law.
By maintaining our commitment to these principles, we will ensure that we respect the inherent trust that you place in us.
This Notice shall stipulate:
i. our purposes of personal data collection;
ii. the important controls we employ for protecting personal data;
iii. the classes of persons we can transfer personal data to;
iv. the data access and correction right of customers;
v. our Notice for data transfer;
vi. use of personal data in direct marketing;
vii. retention of personal data; and
viii. withdrawal of your consent.
4. PURPOSES OF DATA COLLECTION
(a) From time to time, it may be necessary for you to supply us your personal data in connection with the opening or continuation of accounts and the establishment or continuation of facilities or provision of opening or continuation of accounts and the establishment or continuation of facilities or provision of commercial services.
(b) Failure to supply such personal data may result in our inability to open or continue accounts or establish or continue facilities or provide services to you.
(c) We may also collect personal data in the ordinary course of the continuing our business relationship, for example, when you effect a payment transaction or avail any of our other services through the Platform.
(d) Notification will be sent to you on the preferred currency that you have subscribed.
(e) We, or authorised third parties, may use your personal data for any one of the following purposes:
i. conducting credit checks and carrying out matching procedures at the time of application for credit and at the time of regular or special reviews which normally will take place at least once each calendar year;
ii. creating and maintaining our credit assessments;
iii. ensuring your ongoing credit worthiness;
iv. designing services or related products for your use;
v. marketing services, promotional materials, or other services or products for which we may or may not be remunerated;
vi. determining the amount of indebtedness owed to or by you;
vii. enforcement of your obligations, including, without limitation, the collection of amounts outstanding from you
viii. complying with the obligations, requirements or arrangements for disclosing and using data that apply to us including:
1. any law binding or applying to us existing currently and as may be amended, from time to time;
2. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers existing currently and in the future that apply to us; or
3. any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on us by reason of our financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations.
4. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within our intragroup companies, subsidiaries, or affiliates, and any other use of data and information in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities; or
5. other types of uses for personal data in connection with our business.
5. IMPORTANT CONTROLS EMPLOYED BY AMPLE TRANSFERS FOR PROTECTION OF PERSONAL DATA
(a) Personal data in our possession and under our control shall be kept confidential and private under encryption. We shall take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal data. We shall store all the personal data you provide on our secure servers;
(b) Physical copies shall be under lock and key with logged access;
(c) Unfortunately, however, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. Any losses of personal data shall be handled at the outset as per legislated requirements or guidelines. Should there be one, we shall make arrangements to notify the relevant internal & external stakeholders. Periodic updates will be arranged to notify on actions and remedies taken with the final solution to be shared, on a fair and equitable basis. The final handling decision lies with us, based on legal and regulatory priorities firstly followed by its social responsibility.
6. CLASSES OF PERSONS WE CAN TRANSFER PERSONAL DATA
Ample Transfers may provide such personal data to the following third parties for the purposes set out in Section:
(a) any agent, contractor or third-party service provider who provides administrative, telecommunications, computer, payment, debt collection or other services to it in connection with the operation of its business;
(b) any other person or entity under a duty of confidentiality within our group companies which has to be in line with their nature of function on a need to know basis;
(c) any person or entity to whom we are obliged or otherwise required to make disclosure under the requirements of any law binding on or applying to our relevant group company, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers with which our relevant group company is expected to comply, or any disclosure pursuant to any contractual or other commitment of our relevant group company with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be existing currently and in the future applying to itself or its subsidiaries; or
(d) any other person or entity (including its associated companies or affiliates) who had established or proposes to establish any business relationship with it or recipient of the data. In all instances we shall ensure that our contracts with such third parties shall stipulate that the third parties shall act in accordance with the PDPA with respect to your personal data.
7. ACCESS TO AND CORRECTION OF PERSONAL DATA
(a) You have the right:
i. to check whether we hold your personal data;
ii. to access and correct your personal data;
iii. to request that we correct any of your personal data that may be inaccurate; and
iv. to inquire about our policies and practices in relation to personal data and to be informed of the kind of personal data held by us.
(b) The above requests can be addressed to The Data Protection Officer (DPO). We may require you to verify your identity before we provide you access to your personal data.
(c) We may charge you a fee in accordance with our Schedule of Fees and Guidelines to access to your personal data.
8. CONSEQUENCES OF NOT CONSENTING AND/OR PROVIDING PERSONAL DATA NECESSARY FOR TRANSACTION/SERVICE
Please be noted that should you not consent and provide us with the relevant personal data to fulfil the “Purposes” of collection, use and disclosure of your personal information it may hinder our ability to continue to interact with you.
For Job Applicants: We may not be able to make a decision on your suitability for recruitment and employment or comply with the law and therefore, we may not be able to make an offer of employment.
For Visitors to the Office: We may not be able to allow you to enter the office premises
For Customers: We may not be able to provide services, onboarding support and ongoing services support.
9. ACCURACY OF PERSONAL DATA
Ample Transfer shall make a reasonable effort to ensure that personal data collected by or on behalf of the organisation is accurate and complete. Ample Transfer may presume that personal data provided directly by the individual concerned is accurate in most circumstances. When in doubt, Ample Transfer may consider requiring the individual to make a verbal or written declaration that the personal data provided is accurate and complete.
10. DATA TRANSFER
Upon obtaining your consent, your personal data may be processed, kept, transferred or disclosed in and to any country by us and in accordance with the PDPA and the laws, rules, regulations, or governmental orders of that country.
11. USE OF DATA IN DIRECT MARKETING
Before we use your personal data in direct marketing, we will obtain your explicit consent (which includes an indication of no objection) to do so.
Nothing in this Privacy Notice shall limit your rights under the PDPA.
12. RETENTION OF PERSONAL DATA
We retain your personal data for the period necessary to carry out the purposes outlined in this Privacy Notice unless a longer period is required or permitted by law.
We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected and are no longer necessary for legal or business purposes.
13. WITHDRAWAL OF CONSENT
You understand that Ample Transfers mainly provides financial services that are regulated in Singapore by the Monetary Authority of Singapore, and that we may collect your personal information for the purposes of conducting financial transactions with you. In this case, Ample Transfers’ collection of Personal Data is governed by the prescribed personal data regulations that are outlined in the MAS’ Payment Services Act 2019.
You may, at any time, request to delete your data collected by us and you have the right to withdraw your Consent (whether in part or in whole) at any time by contacting our Data Protection Officer (DPO) as indicated below at Clause 16.
You understand that the deletion of your data or withdrawal of your consent can and shall be carried out as long as it does not contravene the legislative regulatory obligations by which the usage of Ample Transfers’ website, platform, products, or services is subject to.
(a) Strictly necessary cookies.
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
(b) Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(c) Functionality cookies.
These are used to recognise you when you return to our website. 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).
You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our website if cookies are disabled.
15. CHANGES TO PRIVACY NOTICE
This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
16. DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Telephone: +65 6252 7327
Address: Ample Transfers Pte. Ltd. (formerly known as AmeerTech Remittance & Exchange Services Pte. Ltd.)
246 Balestier Road, Singapore 329706