Last updated: May 2020
1. Definitions and interpretation
2. Collection of Personal Data
2.1 WLC may collect Personal Data such as:
(a) email address, physical contact information, date of birth and gender information and financial information, such as credit card or bank account numbers;
(b) transactional information based on your activities on the App;
(c) technical information provided by your internet browser, including but not limited to the computer's internet protocol address, browser type, webpage you were visiting prior to arriving at the App, the browsing history on the App, the time spent on the App's pages, the items and information searched for on the App, access times and dates, and other statistics;
(d) information collected by cookies, web beacons, and other similar technologies; and
(e) any Personal Data which you may provide to WLC, including Personal Data relating to a third party.
2.2 WLC may collect Personal Data when:
(a) you register with WLC for any of WLC's services, or to use the App;
(b) you use any of WLC's services or the App, and perform transactions on the App;
(c) you submit any Personal Data or document containing Personal Data to us;
(d) you report a problem with the App, provide your feedback to WLC, or otherwise communicate with WLC
2.3 If you provide us with any Personal Data relating to a third party, by submitting such information to WLC, you represent, warrant and undertake that you are duly authorised to provide WLC with such Personal Data, and that the relevant third party has given its consent for WLC's collection, use, disclosure, processing and management of such Personal Data.
2.4 To the maximum extent permitted by law, you agree to indemnify us against any complaint, claim, damage, loss, penalty or fines relating to your provision of Personal Data to us, including but not limited to your representation, warranty and undertaking in respect of a third party's Personal Data.
3. Use and Disclosure of Personal Data
3.1 WLC may use Personal Data to:
(a) verify your identity, update our records and generally maintain your account with us;
(b) provide our services and customise the content shown to you;
(c) facilitate the provision of goods and services and payment thereto pursuant to any Order Agreement;
(d) develop, operate, improve, deliver and maintain our services;
(e) respond to your queries and resolving complaints;
(f) carry out polls, surveys, analysis and research on how our services and the App are being used and how these can be improved;
(g) conduct research into the development of new products and services, or improvement of existing products and services;
(h) process data relating to accounting, credit and risk management, and record keeping;
(i) carry out research, planning and statistical analysis;
(j) update you on the App and the services;
(k) send you marketing and/or promotional materials on our latest products and services of carefully selected third parties and contractual app partners, when you consent in our [I Agree with Terms and Conditions] checkbox during new user in-app registration form;
(l) send you service-related messages;
(m) perform functions or services as otherwise notified to you at the time of collection;
(n) prevent potentially prohibited or illegal activities;
(p) enforce obligations owed to us.
3.2 WLC will take reasonable steps to protect Personal Data against unauthorised disclosure.
3.3 WLC may disclose Personal Data to third parties, including but not limited to Vendors/Partners:
(a) for any of the purposes listed in clause 3.1 above save for clause 3.1(k) above;
(b) to enable Vendors to provide the Vendor's Goods and Services to you;
(c) to provide necessary products or services on behalf of or for WLC, including but not limited to:
(i) human resource management, debt collection, hosting and maintenance services, delivery services, handling of payment transactions, and marketing;
(ii) professional services such as bookkeeping, legal advice, audit, and tax advice;
(iii) assisting WLC in the provision of products and services to you;
(d) to fulfil WLC's respective contractual obligations; and
(e) as required or permitted by law, including to regulatory authorities, statutory bodies or public agencies pursuant to any legislation, regulations, requirements, policies, directives, guidelines, orders and contracts.
3.4 WLC may also transfer Personal Data to any location outside of Singapore for any of the purposes listed in clause 3.1 above, provided that the requirements of the PDPA are complied with. WLC shall ensure that the Personal Data transferred outside of Singapore is protected at a standard that is comparable to the protection under the PDPA.
3.5 WLC shall retain Personal Data for as long as the purpose for which the Personal Data was collected remains, and until such time when retention of the Personal Data is no longer necessary for any other legal or business purposes.
4. Withdrawal of Consent
4.2 However, the withdrawal of your consent may result in WLC not being able to continue to provide our products or services to you or perform our contractual obligations to you, and you release and hold harmless WLC from any complaint, claim, damage, loss, penalty or fines which you may have against WLC or which you may incur as a result. WLC's legal rights and remedies are expressly reserved.
5. Access, correction and update of Personal Data
5.1 You shall ensure that all Personal Data provided to WLC is accurate, complete and up-to-date. If there are any changes to your Personal Data, or if you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your Personal Data.
5.2 You may request access to your Personal Data held by WLC, subject to any fees which WLC may charge for processing your request for access. Such fees will depend on the nature and complexity of your access request. Information on the processing fee will be made available to you.
6. Security of Personal Data
6.1 WLC shall make reasonable security arrangements to protect Personal Data in our possession or under our control, to prevent unauthorised access, collection, use, disclosure, copying, modification, deletion or similar risks.
6.2 While WLC will comply with their obligations under the PDPA and under clause 6.1, the security of any system or network storing or handling Personal Data cannot be fully assured, and the Providers do not guarantee, in respect of the Platform:
(a) that there will be no security incidents; or
(b) that there will be no malicious code (such as viruses, bugs, Trojan horses, spyware or other malware).
9. Governing Law and Dispute Resolution
The language to be used in the arbitral proceedings shall be English. The decision of the arbitrator shall be final and binding on all the Parties. The costs and expenses of the arbitration, including the fees of the arbitration and the arbitrator, shall be borne equally by each Party and each Party shall pay its own fees, disbursements and other charges of its counsel, except as may be determined by the tribunal.