The purpose of this policy ("Data Protection Policy") is to inform you of how Network for Electronic Transfers (Singapore) Pte Ltd. manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) ("the Act"). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to Network for Electronic Transfers (Singapore) Pte Ltd. and its related corporations (collectively, the "Companies"), as well as its representatives and/or agents (collectively referred to herein as "NETS", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to NETS in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.
NETS may from time to time update this Data Protection Policy to ensure that this Data Protection Policy 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 Data Protection Policy as updated from time to time on our website www.nets.com.sg. Please check back regularly for updated information on the handling of your Personal Data.
1. In this Data Protection Policy, "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.
2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.
Collection of Personal Data
1. Generally, we collect Personal Data in the following ways:
a. when you submit any form, including but not limited to application, registration, declaration or other forms;
b. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
c. when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
d. when you use our electronic services, or interact with us via our websites or use services on our websites;
e. when you request that we contact you or request that you be included in an email or other mailing list;
f. when you respond to our promotions, initiatives or to any request for additional Personal Data;
g. when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
h. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
i. when you are contacted by, and respond to, our sales representatives or our marketing representatives and customer service officers;
j. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
k. when you submit your Personal Data to us for any other reason.
2. When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data unless you provide such information or login with your account credentials.
3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
Purposes for the Collection, Use and Disclosure of Your Personal Data
1. Generally, NETS collects, uses and discloses your Personal Data for the following purposes:
a. responding to your queries, feedback, complaints and requests;
b. verifying your identity;
c. managing the administrative and business operations of NETS and complying with internal policies and procedures;
d. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales);
e. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
f. matching any Personal Data held which relates to you for any of the purposes listed herein;
g. preventing, detecting and investigating crime and analysing and managing commercial risks;
h. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
i. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
j. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
k. conducting investigations relating to disputes, billing or fraud;
l. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on NETS (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
m. purposes which are reasonably related to the aforesaid.
2. In addition, NETS collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
a. If you are a NETS cardholder or a consumer who is making payment via our electronic payments services (including payments through NETS Self-Service Station or eNETS):
i. processing your application for NETS' products and services;
ii. providing customer service and support (including but not limited to processing your payments, transactions and refunds, resolving any technical difficulties, disputes or problems that you may encounter in connection with the use of our products and services, assisting you in claiming cards that have been retained at automated teller machines and attending to your requests for any other products and services);
iii. facilitating card personalisation and embossment;
iv. transaction reconciliation and invoicing;
v. creating and maintaining our cardholders' profiles in our system database;
vi. administering debt recovery and debt management;
vii. administering rewards and benefits; and/or
viii. purposes which are reasonably related to the aforesaid.
b. If you are an employee, business partner, sole proprietor, director, agent, representative or authorised signatory of an organisation that is a merchant partner of NETS;
i. processing your application for NETS' products and services;
ii. facilitating the daily operation of our products and services and providing customer service and support (including but not limited to processing payments, transactions and refunds, resolving any technical difficulties, disputes or problems that you may encounter in connection with the use of our products and services and attending to your requests for any other products and services);
iii. facilitating your appointment as an authorised signatory;
iv. creating and maintaining our merchants' profiles in our system database;
v. administering debt recovery and debt management;
vi. administering rewards and benefits; and/or
vii. purposes which are reasonably related to the aforesaid.
c. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by NETS:
i. assessing your suitability as an external service provider or vendor for NETS;
ii. managing project tenders and quotations, processing orders or managing the supply of goods and services;
iii. processing and payment of vendor invoices and bills;
iv. managing business operations and product development;
v. facilities management (including but not limited to maintaining the security of our premises); and/or
vi. purposes which are reasonably related to the aforesaid.
d. If you submit an application to us as a candidate for employment:
i. conducting interviews;
ii. processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
iii. obtaining employee references and for background screening;
iv. assessing your suitability for the position applied for;
v. facilities management (including but not limited to maintaining the security of our premises and recording entries and exists); and/or
vi. purposes which are reasonably related to the aforesaid.
e. If you sit on the Board of Directors of NETS:
i. facilitating your appointment as a board member;
ii. maintaining statutory registers and to manage the publication of directors' statistics on annual reports and circulars;
iii. facilitating the execution of duties and administrative matters; and/or
iv. purposes which are reasonably related to the aforesaid.
3. Furthermore, where permitted under the Act, NETS may also collect, use and disclose your Personal Data for the following "NETS Additional Purposes":
a. providing or marketing additional products, services and benefits to you, including but not limited to special events, promotions, loyalty and reward programmes from NETS;
b. matching Personal Data with other data collected for other purposes and from other sources (including but not limited to third parties) in connection with the provision, marketing or offering of products and services by NETS;
c. leads generation and management for marketing NETS' products and services;
d. administering and organising contests, lucky draws, promotional events, competitions and marketing campaigns, and personalising your experience at NETS' touchpoints;
e. communicating to you advertisements involving details of our products and services, special offers and rewards, either to our merchants and users of our products and services generally, or which we have identified may be of interest to you;
f. conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
g. purposes which are reasonably related to the aforesaid.
4. If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, NETS may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.
5. In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
6. You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
7. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you have requested from NETS.
Disclosure of Personal Data
1. NETS will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
a. NETS' related corporations;
b. companies providing services related to insurance to NETS as well as agents, contractors or third party service providers who provide operational services to NETS, such as courier services, telecommunications, information technology, payment, printing, billing, technical services, training, market research, call centre, security or other services to NETS;
c. vendors or third party service providers in connection with marketing promotions and services offered by NETS;
d. our merchant partners including other banks;
e. external banks, credit card companies, secretarial agents, billing organisations and their respective service providers;
f. 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);
g.. our professional advisers such as consultants, auditors and lawyers;
h. relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
i.any other party to whom you authorise us to disclose your Personal Data to.
1. When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
2. Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on you.
3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
1. If you:
a. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
b. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
c. would like to obtain access and make corrections to your Personal Data records,
you can approach us via the following channels:
NETS Customer Service Hotline
(65) 6274 1212
Write to our Data Protection Officer at:
Data Protection Officer
298 Tiong Bahru Road #04-01/06
2. Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact such party directly to make any queries, feedback, complaints, and access and correction requests to NETS on your behalf.
3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, NETS may not be in a position to continue to provide its products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with NETS, and your being in breach of your contractual obligations or undertakings. NETS' legal rights and remedies in such event are expressly reserved.
1. This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.