v3.0 – Last updated 31 March 2022
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 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 investment advisory services (to be launched in May 2022), 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 do 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 including but not limited to (e.g. bank balance information, investment portfolio, property information), information relating to your financial services providers (e.g. bank account information), preferences and objectives (e.g. financial objectives and goals), and other information which you voluntarily disclose to us.
Without prejudice to the above, in respect of the Health Module (as defined in the Health Module Terms), we may collect the following data you provide to us: Height, weight, sex, date of birth, and other data volunteered by you regarding your quality of life e.g. smoking and drinking habits
When you join our mailing list: To join our mailing list, please submit your email via the mailing list signup on Autumn’s website.
You warrant that any personal information you provide to us is current, complete and accurate.
- Account creation
To create an account, you need to provide data including information such as your name, email address, phone number, your country of residence and a password. You also agree that we may, with your permission, retrieve your personal information from the MyInfo platform maintained by the Singapore government. If you make a purchase or sign up for a subscription, you will need to provide payment and billing information.
- 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.
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:
In addition to collecting and processing personal information (as detailed below), our service providers may collect the following types of data from your use of our Site and/or your use of their services, for the following purposes:
- Metadata (ancillary usage data, e.g. IP address) may be used for providing services and related internal or regulatory compliance uses, such as the provision of service performance statistics);
- Anonymised data and anonymised aggregated data (anonymised data aggregated with anonymised data from other service provider users) may be used for providing, maintaining and supporting the service provider services, compiling statistical reports, performance tracking, transaction categorisation and merchant identification services.
- 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 do 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 and our service providers and agents may collect, use, disclose and process your personal information for the following purposes:
- 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;
- In respect of the Investment Module (as defined in the Investment Module Terms – to be launched May 2022), we and our service providers and agents may collect, use, disclose and process your personal information for the following purposes: To be updated May 2022.
- In respect of the Health Module (as defined in the Health Module Terms), we and our service providers and agents may collect, use, disclose and process your personal information for the following purposes:
- providing you with health-related information, including to calculate a health status/ index for you, to help you to improve your overall health.
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 professional advisers and service providers in order to provide administrative, financial, legal, accounting, information technology, authentication, 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.
- Data 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.
- Data 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 five (5) 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, namely:
- 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.
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
- Third party websites and services
This Policy does not apply to any linked third-party websites which we do not operate or control.
For any grievance you may contact our Data Protection Officer at firstname.lastname@example.org.