Investing Note Data Protection and Privacy Policy

This data protection and privacy policy ("Privacy Policy") was last updated on 19 October 2017.

Investing Note Pte. Ltd. ("Investing Note", "us", "we", or "our") operates http://investingnote.com (the "Site"). We take our responsibilities under data protection and privacy laws seriously, including our responsibilities under Singapore’s Personal Data Protection Act 2012 (the "PDPA"). We also recognise the importance of the Personal Data you, as a user of the Site, have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data. This page informs you of our policies regarding the collection, use, disclosure and processing of Personal Data we receive from users of the Site.

We use your Personal Data only for providing and improving the Site. By accessing or otherwise using the Site, you agree to the collection and use of your Personal Data and information provided in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible at link.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your Personal Data, please do not hesitate to contact us.


COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

While using our Site, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personal Data may include, but is not limited to, your name, email address, postal address and phone number.

You may provide your Personal Data to us and we may collect your Personal Data in certain situations, such as (but not limited) to signing up as a member of the Site or subscribing for premium subscription services on the Site. We will collect your Personal Data in accordance with the PDPA. We will notify you of the purposes for which your Personal Data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your Personal Data for the intended purposes, unless an exception under the law permits us to collect, use and/or disclose your Personal Data without your consent.


PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

The Personal Data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your Personal Data, including but not limited to:

  1. consideration your application for membership and/or premium subscription programme;
  2. processing, administering and managing your membership and/or premium subscription programme;
  3. processing any transactions or payments made by you and to maintain payment records;
  4. administering and maintaining the functions and features of the Site;
  5. contacting you or communicating with you via telephone call, text message, fax message, email and/or postal mail for the purposes of processing, administering and managing your membership with us;
  6. administering lucky draws, contests or promotions which you have participated in or signed up for;
  7. for publicity purposes and conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance the services we provide to you, where you have consented for us to do so;
  8. for sending you marketing messages relating to our and our affiliates’ products and services by way of email, telephone calls, SMS/MMS and/or facsimile, where you have consented for us to do so;
  9. publicity and promotion with a view to marketing our business, where you have consented for us to do so. In this regard, your Personal Data will be processed by us for the purpose of conducting publicity and/or the development of promotional materials for use by us, such as but not limited to publication of your image and Personal Data on public media platforms such as the newspaper, the Internet, magazines, our in-house notice boards, our newsletters, social media platforms etc.;
  10. record-keeping purposes;
  11. responding to legal process, pursuing legal rights and remedies, defending litigation and managing any complaints or claims;
  12. complying with any applicable law, regulation, legal process or government request; and
  13. storing, hosting and/or backing up (whether for disaster recovery or otherwise) your Personal Data, whether within or outside Singapore,

(collectively, the "Purposes").


As the purposes for which we may/will collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the PDPA or by law.


Your Personal Data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for one or more of the Purposes:
  1. Investing Note's head office, affiliates and subsidiaries;
  2. any of our agents, contractors or third party service providers that process or will be processing your Personal Data on our behalf including but not limited to those third party service providers which have been engaged by us to : (i) to provide and maintain any IT equipment used to store and access your personal information; (ii) to operate and maintain features on the Site; or (iv) otherwise in connection with the provision of membership or premium subscription services to you;
  3. Investing Note's auditors and legal advisors;
  4. financial institutions, credit card companies and payment processors; and
  5. public and governmental / regulatory authorities, courts and other alternative dispute forums,
  6. (the “Permitted Parties”).


Log Data

Like many site operators, we collect information that your browser sends whenever you visit our Site ("Log Data"). This Log Data may include information such as your computer's internet protocol ("IP") address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.


Cookies

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.

Like many sites, we use such 'cookies' to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Site. We may use 'cookies' for the following purposes:
  1. to improve your user experience on this Site;
  2. to remember your preferences;
  3. to help us understand how this Site is performing;
  4. to monitor traffic to this Site; and
  5. to enable this Site to function properly.

Personal Data (if any) that we collect from you through cookies may be passed to our third party service providers, whether located in Singapore or elsewhere, for one or more of the Purposes (see above), for managing and/or administering our website, or for the purpose of data hosting/storage/backup.

Your use of this Site constitutes consent by you to our use of cookies and to the matters set out herein.


Security

The security of your Personal Information is important to us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.


Links To Other Sites

Our Site may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the terms and conditions as well as the privacy policy of every site you visit.

Investing Note has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party sites or services.


Request to Withdraw Consent

You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control (including your consent for the use of your Personal Data for direct marketing) by submitting your request to the contact email address set out below.

We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your Personal Data in the manner stated in your request.

However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we will not be able to continue with your existing relationship with us.


Changes To This Privacy Policy

Investing Note may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on the Site. You are advised to review this Privacy Policy periodically for any changes.


Contact Us

If you have any questions about this Privacy Policy, please contact us.