1.1 This policy ("Privacy Policy") describes how Asia Wealth Platform Pte. Ltd. (Company No. 201624878Z) ("StashAway") manages Personal Data which is in our possession or under our control. "Personal Data", is defined in the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”), and currently refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.
1.2 By using our services pursuant to your agreement(s) with us ("Services"), operating any account maintained with us, accessing the online platform operated by us (which is accessible through our website at www.stashaway.com or through our mobile application) ("Platform"), websites or mobile applications, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.
1.3 This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have at law to collect, use, process or disclose your Personal Data.
1.4 The words "we", "us", "our" or any of their derivatives refer to StashAway and its successors and any novatee, assignee, transferee or purchaser of StashAway's rights and/or obligations hereunder and any reference to StashAway includes a reference to such successor, novatee, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
1.5 This Privacy Policy shall be governed by, and construed in accordance with, the laws of Singapore. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Singapore.
The column on the left sets out StashAway's (i.e. our) Privacy Policy. The Privacy Policy describes how we manage Personal Data in our possession or under our control.
This Summary in this right column provides a short explanation of the Privacy Policy. This is not legally binding and not comprehensive, and you are encouraged to read and understand the Privacy Policy.
If there are any differences between the Summary and the Privacy Policy, the Privacy Policy prevails.
Before you use our Services, operate any accounts maintained with us, access or use our Platform, websites, mobile applications or otherwise provide information to or communicate with us, you must agree to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.
2.1 We collect, use, disclose, transfer and otherwise process Personal Data about you or individuals who are connected or associated with you including but not limited to your legal representatives (“Associated Persons”) in accordance with this Privacy Policy.
2.2 The Personal Data that we collect or may collect include:
Section 2 sets out the type of Personal Data that we collect or may collect from you.
3.1 The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
Section 3 sets out where we may obtain Personal Data from.
4.1 We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes, the following purposes ("Purposes"):
Section 4 sets out how we may use your Personal Data. This includes using your Personal Data for the provision of our Services / Platform to you, for marketing purposes, and to comply with regulatory requirements.
5.1 We may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in Singapore or otherwise, to carry out the Purposes. This includes, disclosing and sharing your Personal Data with the following:
provided that in the case of disclosures under any of the circumstances in (a) to (d), we shall procure that the recipient is subject to the same duty of confidence.
We may also disclose and share your Personal Data with other persons in connection with the Purposes described in Section 4.
6.1 You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please click on the “Unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer at dataprotection@stashaway.com.
6.2 You may also withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the Purposes described in Section 4 by submitting your request in writing or via email to our Data Protection Officer.
6.3 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
6.4 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Section 6.2 above.
6.5 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
You have the right to withdraw any consent provided by you to receive any marketing information from us or to the collection, usage and/or disclosure of your personal data in connection with the Purposes described in Section 4. We will seek to process your withdrawal request within ten (10) business days. However, a withdrawal of your consent to collect, use and/or disclosure your personal data in connection with the Purposes described in Section 4 means that we may not be able to continue to provide you with our Services.
7.1 You may also request access to Personal Data we hold, or request the rectification of any inaccurate data. If you would like to do so, please contact our Data Protection Officer at dataprotection@stashaway.com.
7.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
7.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
You may contact our Data Protection Officer to access or request changes to your Personal Data.
8.1 To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
8.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
We have introduced administrative, physical and technical measures to ensure the protection of your Personal Data with us.
9.1 The accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any applicable law.
The accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data.
We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
We may transfer your Personal Data outside Singapore. If we do, we will comply with applicable data protection and privacy laws.
We may retain your Personal Data for as long as it is necessary for the purpose it was collected, for business purposes or to comply with applicable laws.
12.1 Our Platform, websites and mobile applications (“apps” or an “app”) use cookies. A cookie is a small text file placed on your computer, system or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our apps.
12.2 A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.
12.3 You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites or the Platform.
12.4 We also use analytics programs such as Google Analytics for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Features of Google Analytics that we may use include Remarketing with Google Analytics, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting. Accordingly, your information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience. You may refer to https://www.google.com/policies/privacy/partners for more information about how your data is collected through Google Analytics.
12.5 We and our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as Google advertising cookies) or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support or endorse the goals, causes or statements of these websites or mobile applications which display our ads.
12.6 Using the Google Ad Settings (https://www.google.com/settings/u/0/ads/authenticated), you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences.
We may collect information, your Personal Data, through cookies on our Platform, website and mobile applications. We use analytics programs such as Google Analytics to manage and improve our websites, mobile applications, the Platform and/or our Services. We may with the help of Google Analytics use your browsing behaviour and prior usage patterns together with any other Personal Data previously provided by you in accordance with this Privacy Policy.
Our websites may contain links to other websites which are not maintained by us. This Privacy Policy only applies to our websites, mobile applications, the Platform and/or our Services. When visiting these third party websites, you should read their privacy policies which will apply to your use of the websites.
This Privacy Policy does not apply to third party websites which may be linked to our websites.
Apart from obtaining your consent to this Privacy Policy, we may have additional rights at law to collect, use, process or disclose your Personal Data:
Where your consent is not required:
Where consent is deemed to have been obtained from you:
We may be able to collect, use, process and disclose your Personal Data in certain situations where your consent is not required, or where your consent is deemed to have been obtained from you, with respect to your use of our Services, your operation of any accounts maintained with us, access or use our Platform, websites, mobile applications or otherwise provide information to or communicate with us.
Our Privacy Policy may change from time to time. We will post any privacy policy changes on this page, for which you will be notified. If you continue to use our Services, operate any account maintained with us, access our Platform, websites or mobile applications, and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such changes without reservation.
The Privacy Policy is subject to changes made by us; and if you continue to use our Services, operate any account maintained with us, access our Platform, websites or mobile applications, and/or otherwise provide information to or communicate with us, you will be treated as if you have agreed to the changes.
If you have any questions about any aspects of this policy or your Personal Data, please contact our Data Protection Officer at dataprotection@stashaway.com or +65 6958 1052.
You may contact our Data Protection Officer if you have any questions about this Privacy Policy.