Privacy Policy - X Star Technology Pte. Ltd.

Last updated: 10th February 2025

Your Privacy is Important to Us

This Privacy Policy applies to our services (the “Platform”), which include our websites, applications, software and related services accessed via any platform or device that link to this Privacy Policy.

In this policy, “we”, “us” means X STAR TECHNOLOGY PTE. LTD. (“X STAR”) and its affiliates and subsidiaries, “you” means the persons to whom this policy applies, including but not limited to users, subscribers, publishers, members, and others who visit and use the Platform.

The security of your personal data is important to us. We have in place safeguards to protect the personal data stored with us. This policy describes how we may collect, use, disclose, process and manage your personal data.

This policy applies to any individual’s personal data which is in our possession or under our control, whether collected through the Platform or any other means, in accordance with the Personal Data Protection Act 2012 (the “PDPA”) and the EU General Data Protection Regulation (the “GDPR”) (where applicable).

By providing your Personal Data, you hereby agree and consent to the handling your Personal Data in the manner set forth in the prevailing Privacy Policy which may be updated or modified from time to time and which is available on the Platform.

What Personal Data We Collect

We define “Personal data” as data that can be used to uniquely identify a natural person. Personal data can be collected from various sources (including through interfaces powered by artificial intelligence (“AI”)) and processed by us. Some examples of data which, on its own or jointly, can be used to identify a natural person are:

personal particulars (e.g. name, contact details, residential address, date of birth, identity card/FIN/passport details, vehicle information, and/or education details);
specimen signature(s);
financial details (e.g. income, expenses, and/or credit history);
images and biometrics such as thumbprints, voice and video recordings of you, including our conversations with you for verification or other purposes;
employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
tax and insurance information;
information about your risk profile, investments, investment objectives, knowledge and experience and/or business interests and assets;
financial information (e.g. account numbers and financial transactions);
your personal opinions made known to us e.g. through feedback or surveys;
information relating to your activities, habits, preferences and interests arising from your use of products and services of us, our partners or vendors; and/or
other electronic data or information relating to you such as IP addresses, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.

You may have provided the Personal Data to us personally or authorized other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals.

Where you give us Personal Data about other individuals, you confirm that you are authorized to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in the section “How We Use the Personal Data”, or other purposes for which your consent has been sought and obtained.

How We Use the Personal Data

We may use the personal data you provided for our business purposes (including through interfaces powered by AI) as set out below:

developing and providing financial facilities, products or services (whether made available by us or through us), including but not limited to:
1. executing Hire Purchase, loan, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions;
2. carrying out research, planning and statistical analysis and conducting surveys; or
3. analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customisation strategies;
assessing and processing applications, instructions or requests from you;
communicating with you, including providing you with updates on changes to products, services and financial facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and financial facilities and their terms and conditions and collecting your opinions through surveys;
managing our infrastructure, business operations and complying with internal policies and procedures;
responding to queries or feedback;
addressing or investigating any complaints, claims or disputes;
verifying your identity for the purposes of providing financial facilities, products or services, granting security clearance and allowing access to our systems;

conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
monitoring products and services provided by or made available through us, including to prevent, detect and investigate crime/fraud;
complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
creating and maintaining credit and risk related models;
financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
enabling any actual or proposed assignee or transferee, participant or sub-participant of our rights or obligations to evaluate any proposed transaction;
enforcing obligations owed to us;
in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice;
administering benefits or entitlements in connection with our financial relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. This will include the administration of loyalty, rewards programmes, lucky draws, and/or sending gifts and awards;
facilitating attendance at events/ functions organized by us or in which we are involved;
evaluating and improving our products and services; and/or
for purposes that are ancillary to or in furtherance of the above purposes.

In addition to the above purposes, we may also use personal data for purposes set out in the Terms and Conditions on the Platform that govern our relationship with you.

Use of Personal Data for Marketing Purposes

We may use your personal data to recommend you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the Personal Data Protection Act of Singapore (PDPA) and other applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (GDPR).

In respect of sending telemarketing messages to your Singapore telephone number via short message service, telephone calls (voice or video), facsimile and other mobile messaging services, please be assured that we shall only do so if:

you have provided your clear and unambiguous consent in writing or other recorded form for us to do so;
you have not indicated to us in our ongoing relationship that you do not wish to receive telemarketing messages sent to your Singapore telephone number and you have not registered that number with the National Do Not Call Registry.

To find out more on how you can change the way we use your personal data for marketing purposes, please contact us (please see the “Contact Us” section below).

At the same time, we may continue to send you messages as part of our ongoing relationship with you and nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.

Disclosure and Sharing of Personal Data

We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any personnel of us or to third parties, whether located in Singapore or elsewhere, in order to carry out the purposes set out above. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.

An example of such sharing would be for the purposes of providing or offering products or services that might be of interest to you based on your collected information or other data relating to your interactions with us, our partners or vendors.

For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or as our customer. You may also contact us for more information (please see the “Contact Us” section below).

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, such as the GDPR.

Disclosure and Sharing of Personal Data

Other Websites/Applications

The Platform may contain links to other websites/applications which are not maintained by us. This Privacy Policy only applies to the Platform. When visiting these third-party websites/applications, you should read their privacy policies which will apply to your use of the websites/applications. We have no control over, do not review, and cannot be responsible for, these third-party websites or applications or their contents. Please be aware that the terms of this privacy policy do not apply to these third-party websites or applications or content, or to any collection of information after you click on links to these third-party websites, applications or content.

Children and Teens

We do not knowingly collect or maintain personal information from persons under 18 years-of-age. If we learn that personal information of persons under 18 has been collected on or through the Platform, we will take appropriate steps to delete this information. If you believe that we have inappropriately collected personal information from a Young User, please contact us as soon as possible.

Retention of Personal Data

Your personal data and other information is retained as long as the purpose for which it was collected and remains until it is no longer necessary for any other legal or business purposes.

You may request deletion of your account at any time by sending your request to us via email listed in Contact Us.

Following such request with appropriate review by us, we will delete the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, we retain location, device, and usage data for these purposes for a reasonable period as may be necessary; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, we may be unable to delete your account, such as if there’s a balance on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete the account as described above.

We may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if we deactivate a user’s account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new account on the Platform in the future. If you violate our any policies or conditions on the Platform, we may remove your profile and user content from public view immediately, but may keep other information about you to process the violation.

Data Security

We take appropriate administrative, technical and physical security measures to safeguard your personal information from unauthorized access and disclosure. For example, from our side, only authorized employees are permitted to access personal information, and they may do so only for permitted business functions. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your personal information. You should use caution whenever submitting information through the Platform and take special care in deciding which information you provide us with.

You are responsible for maintaining the secrecy of your password and account information at all times.

Access and Correction

You may request access or make corrections to your personal data held by us. X STAR may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you. We may also take a reasonable period of at least 10 business days after receiving your correction request to process and update the change.

There are also other data protection and privacy laws that provides relevant individuals with additional rights including the right to obtain information on how we processes your personal data, receive certain information provided in an electronic format and/or request that these be transmitted to a third party, withdraw consent to the processing of your personal data, request for your information to be erased, object or restrict the use or processing of your information in some circumstances e.g. GDPR. These will be subject to ongoing obligations imposed on the Platform pursuant to any applicable law or regulation, and/or the legitimate reason or entitlement to continue processing your information, and/or to refuse that request.

Where a request is made to withdraw consent, we will inform you of the likely consequences of withdrawing consent and the timeframe to effect the withdrawal. Such requests will be processed within a reasonable timeframe, taking ten business days or more depending on the complexity of the request. In some cases, not providing the personal data, or withdrawing consent to the use, processing, or disclosure of the personal data, may adversely affect our ability to continue our financial relationship with you.

Please contact us (please see the “Contact Us” section below) for details on how you may request access, correct or exercise your rights with respect to the processing of your personal data.

Contact Us

To contact us on any aspect of this policy or your personal data or to provide any feedback that you may have, please get in touch with our Customer Service Executive in the following ways:

Via post: X STAR TECHNOLOGY PTE. LTD.

7 TEMASEK BOULEVARD, #37-03, SUNTEC TOWER ONE, SINGAPORE 038987

Attn: Customer Service Executive

Via email: yvonne.liaw@xstar.sg

In addition, should we be aware that your data has been compromised and is, or likely to result in significant harm to you, we will notify you and advise on the possible steps to protect yourself from further potential harm. Please be assured that you can always validate such notifications from us by contacting us.

Amendments and Updates of the Privacy Policy

This Privacy Policy does not affect any rights which we may have at law in connection with the handling of your Personal Data. We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way we use your personal data or any changes to the laws and regulations applicable to us. We will make available the updated policy on the Platform. You agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on the Platform. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.

When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy and posting the new Privacy Policy or providing any other notice required by applicable law. Your continued access to or use of the Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Platform.