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PRIVACY POLICY

This Data Protection Notice (“Notice”) sets out the basis which Nebulas Tree Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Notice:

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, mailing address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

5. We may collect and use your personal data for any or all of the following purposes:

  • performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
  • verifying your identity;
  • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
  • managing your relationship with us;
  • processing payment or credit transactions;
  • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • any other purposes for which you have provided the information;
  • transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
  • any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:

  • where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
  • to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION

8. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Nebulas Tree Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, Nebulas Tree Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

9. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

  • Fraud detection and prevention;
  • Detection and prevention of misuse of services;
  • Network analysis to prevent fraud and financial crime, and perform credit analysis; and
  • Collection and use of personal data on company-issued devices to prevent data loss.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.

USE OF COOKIES AND SIMILAR TECHNOLOGIES

10. We use cookies and other tracking technologies on our website to enhance user experience, monitor website performance, and deliver personalised content and advertisements. By accessing or using our website, you consent to our use of such technologies in accordance with this Policy.

11. When you interact with our website, we may automatically collect certain information, including but not limited to:

  • Browser type and operating system
  • IP address and location
  • Pages visited, time spent, and referral source
  • Device identifiers and session data

This information helps us maintain and enhance our website performance, detect security issues, and understand user behavior.

12. We may use third-party analytics and advertising tools (e.g., Google Analytics, Facebook Pixel, LinkedIn Insight Tag) that deploy cookies or similar technologies. These providers may collect and process data independently according to their own privacy policies. We recommend reviewing these policies directly on their respective websites.

13. You may choose to disable cookies in your browser settings. Most browsers allow you to manage cookies through the settings menu. Please note that disabling cookies may affect the functionality and user experience of our site.

WITHDRAWING YOUR CONSENT

14. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

15. 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 thirty (30) business days of receiving it.

16. 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 goods or 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 clause 14 above.

17. 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.

ACCESS TO AND CORRECTION OF PERSONAL DATA

18. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

19. 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.

20. We will respond to your access or correction request within thirty (30) days of receiving your request.

PROTECTION OF PERSONAL DATA

21. We have implemented appropriate physical, administrative and technical measures to protect personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

22. We restrict access to personal data to those employees who require the data to perform their duties and ensure that these employees are aware of and comply with our policies and procedures in relation to the protection of personal data.

RETENTION OF PERSONAL DATA

23. We retain your personal data only as long as necessary for the purposes for which the personal data was collected or to comply with any legal or regulatory requirement.

TRANSFER OF PERSONAL DATA OUTSIDE SINGAPORE

24. We may transfer your personal data outside Singapore for the purposes described in this Notice, including to organisations which we have engaged to provide services to us or on our behalf.

25. We will ensure that any transfer of your personal data outside Singapore is made in accordance with the PDPA and other applicable laws.

WITHHOLDING OF PERSONAL DATA

26. If you choose not to provide us with your personal data when requested, it may affect our ability to provide our goods and/or services to you, and we may not be able to process any requests, applications or transactions you make with us.

CONTACT US

27. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Data Protection Officer
Email Address: [email protected]

EFFECT OF NOTICE AND CHANGES TO NOTICE

28. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

29. We may revise this Notice from time to time without any prior notice to you, and the updated version of this Notice shall be posted on our website. You should check the website from time to time to ensure that you are aware of the current version of this Notice.

Effective date: 03/06/2025
Last updated: 03/06/2025