AUTUMN PRIVACY POLICY

v1.2 - Last Updated 7th October 2020

Your personal information is important to us

Your personal information is important to Autumn and it is our policy to respect and protect your personal information. This Policy outlines how we collect, manage and share the personal information we hold about you, in compliance with applicable laws and regulations. It also tells you how you can exercise your privacy rights.

The Autumn Privacy Policy applies to personal information that we collect through our website www,autumn.sg and our mobile applications (collectively, the “Site”).

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Privacy Policy.

The Site is not intended for or directed to persons under the age of 18, and we will not knowingly collect information from persons under 18. To provide information to us through registration or in any other manner on the Site, you must be 18 years of age or older.

What does Autumn do?

Autumn is a platform that enables users to consolidate their financial and health information in one place. The Site provides a range of services to the users including but not limited to portfolio analysis, will creation, documentation storage and other products and services around retirement planning, health and wellbeing. Autumn is headquartered in Singapore

What personal information we collect from you

We collect or receive personal information in a few different ways via the Site. Often, you choose what information to provide, but sometimes we require certain information in order for you to use, and for us to provide you with, the Site and the experiences you reserve or access through the Site.

Data you provide to us: We may collect your name, email address, financial information, financial services providers, preferences, and other information which you voluntarily disclose to us.
Registration for information: To join our mailing list

Account Creation: To create an account, you need to provide data including information such as your name, email address, phone number and a password. If you make a purchase or sign up for a subscription, you will need to provide payment and billing information.

Profile: To complete your profile, you may provide other information, such as a photo/live picture, birthdate and a national identity card or passport. This is to comply with local compliance requirements relating to customer identification.

Data collected automatically through your use of the Site

We log usage data when you visit or otherwise use our Site, such as when you view or click on content or ads (on or off our Site), perform a search, browse, schedule a reservation and install or update one of our mobile apps. Specifically, the information we collect automatically may include information like internet protocol (“IP”) address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked.

We may also collect precise geolocation data pertaining to your mobile device, if you have consented to providing this to us through your device settings. We may use this information to provide, promote, and improve our services (for example, understanding the country you reside in) and for related reasons, such as sanctions, fraud prevention and security purposes. Please note that if you do not consent to providing your geolocation data, certain features of the mobile application may not work.

The information we collect automatically enables us to better understand the visitors who come to our Site, where they come from, and what content on our Site is of interest to them. This enables us to improve the quality and relevance of our Site to our visitors.

Cookies, Web Beacons and Other Similar Technologies.

We use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across the Site, including when you use different devices. To learn more, including how to change your cookie settings please see below

The links listed below provide more information about what cookies are installed, how to allow, block or remove installation from your computer. Depending on which browser you use, the user may follow these links:

Data collected from others

From time to time, we may receive personal information about you from third party sources to assist us in providing, evaluating and improving our Site and offerings, but only where these third parties represented that you gave your consent either or are otherwise legally permitted or required to disclose your personal information to us.

How we use your personal information

We will only collect, use, and disclose your personal information for the purposes you have been notified of and consented to or which are permitted under applicable laws and regulations.

We will not sell, rent or give away personal information to third parties for commercial purposes without your consent.

We may process your personal information for the following:

  • providing you with products and services as subscribed to or requested by you;
  • accessing and analysing your financial information as requested by you;
  • processing your applications for products and services, effecting payments from and to you, processing transactions and completing instructions or requests;
  • providing customer service, customer support and technical support, including in relation to product updates;
  • market research and surveys with the aim of improving our products and services;
  • marketing purposes, promotional events, competitions and lucky draws;
  • complying with and monitoring compliance with applicable laws and regulations, voluntary codes, internal policies (including that of our affiliates’), contractual obligations (including between us and our affiliates) and other requirements;
  • maintaining the security of our Site, including to verify your identify, to investigate or prevent possible fraud or other violations of our Terms of Use or this Privacy Policy and/or in connection with possible attempts to harm our members, visitors, or other third parties.

Depending on the purpose of processing your personal information, personal information may be disclosed to:

  • our affiliates anywhere in the world, including any officer, employee, agent or director of any affiliate;

  • your financial services providers, in order to access your financial information as requested by you;

  • our joint venture partners, business alliance partners or other investors or potential investors (in connection with the actual or potential merger, sale, acquisition or investment) provided we inform the relevant third party it must use your personal information only for the purposes disclosed in this Privacy Policy;

  • our professional advisers and service providers in order to provide administrative, financial, legal, accounting, information technology, research or other services;

  • a merchant or a member of a card association where the disclosure is in connection with use of a card; and

  • anyone authorised by you, as specified by you or in any contract with you;

  • any person to whom disclosure is required or permitted under applicable laws and regulations;

  • anyone we consider necessary to facilitate requests for services or applications for products with our affiliates; and

  • anyone we consider necessary in order to provide services in connection with a product or service.

Security

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We monitor our systems for possible vulnerabilities and attacks. However, we cannot guarantee 100% security of any information that you send us. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal information arising from such risks.

Personal information may be transferred to, or stored at, a location outside of Singapore or your country of residence, which may not have data protection law. The security of your personal information is important to us. We have technical and organisational security measures in place to safeguard your personal information. When using external service providers, we require that they adhere to security standards mandated by us. We may do this through contractual provisions, including any required by a privacy regulator, and oversight of the service provider. Regardless of where personal information is transferred, we take all steps reasonably necessary to ensure that personal information is kept securely.

Retention

We retain your personal information in line with our legal and regulatory obligations and for business and operational purposes. In the majority of cases this will be for seven years from the end of your relationship with us. We will cease to retain your personal information when we no longer require such personal information for the purposes we originally notified you of or for any business or legal needs.

Your rights

You have data protection rights including:

1) If you wish to access, correct, update or request withdrawal of consent for your personal information, you can do so by contacting the Data Protection Officer.
2) You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Additionally, opting out of marketing communications does not mean that we cannot continue using and disclosing your Personal Information for other purpose set out in this Privacy Policy.

To make a request to access or correct the personal information we hold about you, or to make a request to withdraw your consent previously given, please contact our Data Protection Officer (details below).

Updates to this Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

Third party websites and services

Our Site may contain links to third-party websites or mobile apps, including social sharing features and other related tools. Please be aware that Autumn does not control these linked websites or apps and that this Privacy Policy does not apply to any information you give to the owner of these websites or apps. We encourage you to read the privacy policy of any third-party website or app that you visit before you provide them with any information.

This Policy does not apply to any linked third-party websites which we do not operate or control.

Contacting us

You may contact our Data Protection Officer at privacy@autumn.sg.