SwipeLah! Privacy Policy

This Privacy Policy (“Policy”) describes how SwipeLah! Pte. Ltd. And its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “ SwipeLah! ”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of SwipeLah! Apps and Websites (including all mobile applications and websites operated by SwipeLah! (respectively “Apps” and “Websites”), products, features and other services globally (collectively, “Services”).

This Policy applies to our customers, agents, vendors, suppliers, partners (such as merchant partners), contractors and service providers (col lectively “you”, “your” or “yours”)

“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, persona l interests, email address, your image, government - issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information.

This Policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the applicable website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the relevant website(s) and/or service(s) including mobile applications and DO NOT provide any personal data to us.

1. Collection of Personal Data

We collect Personal Data abo ut you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.

1.1 You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may prov ide your Personal Data to us when you:

  1. fill up a user profile or registration forms;
  2. provide information to assess your eligibility to provide services as a Merchant - partner;
  3. interact with our social media pages;
  4. participate in contests or events organised by us;
  5. when you report any problem to us;
  6. when you use certain features on our Site or our App;
  7. when you request any support from us;
  8. when you refer friends;
  9. when you register community page with us;
  10. use biometric features to identity yourself; and/or
  11. fill up demographic information in surveys.

1.2 When our services are used

Personal Data may be collected through the normal operation of our Apps, Websites, Services. Some examples are:

  1. your location (to detect currently location to send the relevant advertis ement );
  2. feedback, ratings and compliments;
  3. transaction information (such as payment method and winning details including SwipeCash );
  4. information about how you interacted with our Apps , Website or services (such as features used and content viewed);
  5. information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain p ages, 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 numbers;
  6. Information we receive from third parties - We work with third parti es 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 w ill notify you when we receive information about you from them and the purposes for which we intend to use that informatio n;
  7. device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers); an d
  8. personal data you enter in messages when you use our in - app communication features or community pages .

1.3 From other sources

When we collect Personal Data from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

  1. referral programmes;
  2. our business partners, such as fleet partners, payment providers, ride - hailing partners and transport partners;
  3. insurance and financial providers;
  4. publicly available data;
  5. governmental sources of data;
  6. when our users add you as an emergency contact; and
  7. m arketing services providers or partners.

1.4 Sensitive Personal Data

Some of the information that we collect is sensitive in nature. This includes information such as national ID numbers, race, marital status, an d your health or religious beliefs. We only collect this information when this is necessary to comply with legal or regulatory requirements.

1.5 Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Persona l Data to SwipeLah!. In the event that such Personal Data of a minor is disclosed to SwipeLah! , you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions .

1.6 When you provide personal data of other individuals to us

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your referral . If you provide us with their Personal Data, you represent and warrant that you have and you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.

1.7 Data Collected by Automated

Various technologies may be used on our website and our mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. Examples of such technologies include:

  1. Click-stream data. A visit to one of our websites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
    - the visitor’s IP address
    - the date and time of the visit
    - the referral URL (the site from which the visitor has come)
    - the pages visited on our website
    - information about the browser used (browser type and version, operating system, etc)
  2. Cookies. A number of places on our website and our mobile and web-based applications make use of cookies. These are essentially small text files that are stored on your computer’s hard drive or your user device by your web browser. We can use cookies to identify the owner of a user account. In other words, cookies help to make our website or our (mobile and web-based) applications more user-friendly, more effective and more secure. The cookies usually used by us are so-called “session cookies”, which are automatically deleted at the end of the visit to the relevant website. By default, web browsers enable the use of cookies but this function can also be disabled. However, this will result in some services not being available. It is also possible to manually delete cookies after their use via the web browser. More information may be available from your web browser provider.
  3. Flash cookies. A particular form of cookie is the flash cookie. In contrast to normal cookies, these cookies are not created and saved by the web browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted or disabled via the browser; this is only possible if you follow instructions available from the Adobe Flash Player website. You can also obtain more information about these cookies on that website.
  4. Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or our mobile applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
  5. Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and our mobile applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobileapplications, or to find out what information and services our visitors or registered customers are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties.

2. Use of Personal Data

SwipeLah! may use, combine and process your Personal Data for the following purposes (“Purposes”).

2.1 Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve our products and services. This includes using your Personal Data to:

  1. provide you with Services across our various business verticals;
  2. engage you to provide S ervices;
  3. create, administer and update your account;
  4. verify your identity;
  5. enable features that personalise your App, such as lists of your favourite places ;
  6. perform internal operations necessary to provide our S ervices, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends ;
  7. protect the securit y or integrity of the Services and any facilities or equipment used to make the Services available;
  8. process and manage your rewards and winnings;
  9. enable communications between our users; and
  10. process, manage or verify your application for subscription with SwipeLah! and to provide you with subscribers’ benefits.

2.2 Customer support

We use Personal Data to resolve customer support issues. For example, we may:

  1. investigate and address concerns;
  2. monitor and improve our customer support responses;
  3. respond to questions, comments and feedback; and
  4. inform you about steps taken to resolve customer support issues.

2.3 Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your personal data, improve and enhance the safety and security of our services, develop new features, products and services, and facilitate insurance and finance solutions.

2.4 Legal purposes

We may u se the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors o r any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

  1. comply with court orders or other legal, governmental or regulatory requirements;
  2. enforce our Terms of Service or other agreements ; an d
  3. protect our rights or property in the event of a claim or dispute.

We may also use your Personal Data in connection with merger s , acquisitions, joint venture s , sale of company assets, consolidation , restructuring, financing, business asset transaction s , or acquisition of all or part of our business by another company.

2.5 Marketing and promotions

We may use your Personal Data to market SwipeLah! and SwipleLah!’s partners’ sponsors’ and advertisers’ products, services, events or promotions. For example, we may :

  1. send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
  2. notify, invite and manage your participation in our events or activities;

We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.

you may opt out any time by emailing us at opt-me-out@swipelah.com. We will cease to send you marketing information without charge

3. Disclosure of Personal Data

We need to share Personal Data with various parties for the Purposes. These parties include:

3.1 With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

3.2 With SwipeLah!’s service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

  1. payment processors and facilitators;
  2. background check an d anti - money laundering service providers;
  3. cloud storage providers;
  4. marketing partners and marketing platform providers;
  5. data analytics providers;
  6. research partners, including those performing surveys or research projects in partnership with SwipeLah! or o n SwipeLah!’s behalf;
  7. fleet and merchant partners;
  8. insurance and financing partners; and

3.3 With our legal advisors and governmental authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties.

4. Retention of Personal Data

We retains your Personal Data for as long you maintain your SwipeLah! account. Once your Personal Data is no longer necessary for the Services or Purposes, or we no longer have a legal or business purpose for retaining your Personal Data, we take steps to prevent access or use of such Personal Data for any purpose other than compliance with this privacy policy, or for purposes of safety, security, fraud prevention and detection.

5. International transfers of Personal Data

Your Personal Data may be transferred from country, state and city (“Home Country”) in which you are present while using our services to another country, state and city (“Alternate Country”). You understand and consent to the transfer of your Personal Data from your Home Country to the Alternate Country.

6. Cookies

6.1 Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

6.2 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.

6.3 We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site 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).

6.4 We use the following cookies:

  1. Strictly necessary cookies – These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  2. Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
  3. Functionality cookies – These are used to recognise you when you return to our Site. 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).
  4. Targeting cookies – These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.

6.5 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 Site.

6.6 We may use third-party web services on our Site. 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 Site 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

7. Third-party sites

Our Site, our App or our communication 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 understand your rights. We accept no responsibility or liability for any practices of third-party websites.

8. Security

8.1 All information you provide to us is stored on our secure servers.

8.2 Any payment transactions will be encrypted using TLS/SSL technology.

8.3 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

8.4 We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

8.5 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 Site; any transmission is at your own risk.

8.6 We endeavor to take precautions to ensure that the information you have provided is protected against unauthorised or unintended use, access or disclosure. However, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control.

9. Data transfer

9.1 The 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 in Clause 3 above who operate outside Singapore.

9.2 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.

10. Your rights

10.1 You have the right to:

  1. check whether we hold personal data about you;
  2. access any personal data we hold about you; and
  3. require us to correct any inaccuracy or error in any personal data we hold about you.

10.2 Any request under Clause 10.1 may be subject to a small administrative fee to meet our cost in processing your request.

11. Amendments and updates

SwipeLah! shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Apps, Websites or Services, purchase products from SwipeLah! or continuing to communicate or engage with SwipeLah! following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.

If you have any queries about your personal data, please contact our Data Privacy Officer at:

SwipeLah! Data Protection Officer
c/o SwipeLah! Pte. Ltd.
14 Robinson Road,
#08-01A Far East Finance Building,
Singapore 048545
Email: dataprotection@swipelah.com

The original of this Privacy Statement is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.

12. Governing Law

12.1 This Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy

13. Disclaimer