Privacy Policy

PRIVACY POLICY

Last Updated: 14 October 2020

This Privacy Policy and its Addendum(s) (“Policy”) describe how ETG PTE LTD, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “ETG”, “we”, “us” or “our”) collect, use, process and disclose your Personal Data through the use of ETG’s Application, Platform, Software and/or Websites (including all mobile applications and websites operated by ETG (respectively “Apps” and “Websites”), products, features and other services (collectively, “Services”).

This Policy applies to our customers, sales agents, partners, third-party providers, vendors, suppliers and service providers (collectively “you”, “your” or “yours”). We are committed to respect your privacy and to protect your personal data. This Policy is to be read along with the Terms and Conditions of the Apps, Websites and Services stated above for your use of the Apps on your phone, computer, tablet or any other electronic device. Please read the Policy fully and carefully to understand our practices regarding your personal data and the way we treat it.

By agreeing to terms and conditions of the Websites and Apps and the Privacy Policy to access and use the Services on the Apps, you consent to the collection, storage, use, translation, aggregation, anonymisation or other forms of data processing of your personal data. Your personal data will be processed according to this Privacy and you are agreeing to be bound by it.

“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, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information.

COLLECTION OF PERSONAL DATA

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

You provide your Personal Data to us

We collect, use, store, translate, aggregate and transfer different types of data including but not limited to your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

create a user account or merchant/sales agent / service provider profile to use the app;
provide information to assess your eligibility to provide your company’s services as a third-party provider;
provide information to assess your eligibility to be a sales agent of our Partners;
interact with us via our social media pages;
filling up a Contact Us enquiry form where necessary;
participate in events organised by us; and
fill up demographic information in surveys.

When our services are used

Personal Data may be collected through the normal operation of our Application, Platform, Software, Websites and Services. Some examples are:

booking of sales agents for consultation visits
booking of third-party providers’ services
feedback, ratings and compliments;
transaction information (such as payment method);
information about how you interacted with our Application, Platform, Software, Website or Services (such as features used and content viewed);
device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers); and
personal data you enter in messages when you use our in-app communication features.

From other sources

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

referral programmes where applicable;
our business partners;
insurance and financial providers;
publicly available data;
governmental sources of data;
marketing services providers or partners.

Sensitive Personal Data

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

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to ETG. In the event that such Personal Data of a minor is disclosed to ETG, 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.

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 the point of contact for the appointments. 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.

II. USE OF PERSONAL DATA

ETG may use, store, translate, aggregate, combine, transfer and process your Personal Data for the following purposes (“Purposes”).

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:

provide you with Services across our various business segments;
engage you to provide Services;
create, administer and update your account;
verify your identity;
perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
process and manage your rewards;
enable communications between our users;
process, manage or verify your application for subscriptions made for the services available on ETG and
enable our sales agents and merchants to serve you.

Customer support

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

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

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. We may also collect aggregated data such as statistical or demographical data that may be derived from your personal data although it may not be personal data per se as we may not be able to identify you or any particular individual from the aggregated data.

Legal purposes

We may use 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 or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

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

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

Marketing and promotions

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

send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
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.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, you may write in to ETG to make the request.

III. DISCLOSURE OF PERSONAL DATA

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

Other users

For example, if you are a customer, we may share your name and location with our sales agents or merchants.

If you are a sales agent or merchant, we may share your Personal Data with your customer including your name, profile photo and average rating where applicable.

With ETG partners at your request

For example, if you requested a service through a ETG partner or used a promotion provided by a ETG partner, ETG may share your Personal Data with that ETG partners. Our partners include partners that integrate with our App or our App integrates with, household service provider partners, or business partners which ETG collaborate with to deliver a promotion or other specialised services.

With subsidiaries and affiliates

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

With ETG’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:

payment processors and facilitators;
background check and anti-money laundering service providers;
cloud storage providers;
marketing partners and marketing platform providers;
data analytics providers;
research partners, including those performing surveys or research projects in partnership with ETG or on ETG’s behalf; and
sales agents and merchant partners;

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.

RETENTION OF PERSONAL DATA

We retain your Personal Data for as long you maintain your ETG 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 will 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 and/or remove the data if required to do so within reasonable time.

COOKIES

ETG, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of the Websites and Apps. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

ETG may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes ETG does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of this Personal Data through your mobile device settings.

PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your personal data is protected. This includes measures to prevent data from getting lost, or used or accessed in an unauthorised way. We limit access to your personal data to our employees on a need to know basis. Those processing your personal data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that 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 through any online means, therefore, any transmission remains at your own risk.

VII. DATA SECURITY

We implement certain security measures including encryption and firewalls to protect your personal data from unauthorised access. However, you agree and acknowledge that the above mentioned measures do not guarantee absolute protection to the personal information and by accessing the Websites and Apps, you agree to assume all risks associated with disclosure of personal data arising from and/or due to the breach of firewalls and secure server software.

Where, if applicable, we have given you (or where you have chosen) a password that enables you to access certain parts of our Websites or Apps, you are responsible for keeping this password confidential. We require you not to share the password with anyone.

VIII. BUSINESS TRANSACTIONS

You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, you personal data might be among the assets transferred.

AMENDMENTS AND UPDATES

ETG 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 Application, Platform, Software, Websites or Services, purchase products from ETG or continuing to communicate or engage with ETG 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:

ETG Data Protection Officer

c/o ETG Pte Ltd

Email: enquiry@etg.com.sg