V5.0 – Last updated 25 Nov 2022
Your privacy is important to Autumn and it is our policy to respect and protect your privacy.
It also tells you how you can exercise your privacy rights.
The Site, App and Autumn Materials are 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 or otherwise in connection with the Site, App and/or Autumn Materials, you must be and warrant that you are 18 years of age or older.
- What does Autumn do?
The Site and App, together with the Autumn Materials, are intended to be a platform that enables users to, amongst others, consolidate their financial and health information in one place. The Site and App, together with the Autumn Materials, provide a range of products, services, features and functionalities to the end-users, such as but not limited to certain investment advisory services, portfolio analysis, will creation, documentation storage and other products and services around retirement planning, health and wellbeing.
Autumn is headquartered in Singapore.
- What Data do we collect or receive from you?
We (including our service providers and agents) collect or receive Data in a few different ways via the Site, App and/or Autumn Materials or otherwise provided or made available to you. Often, you choose what information to provide, but from time to time, we may request or require certain information in order for you to access and/or use, and for us to provide you with, the Site, App and/or Autumn Materials and the services you request for or access through the Site, App and/or Autumn Materials.
Types of Data we may collect or receive include:
(a) your name, NRIC, country of residence, contact information (including but not limited to email address and phone number) and such other personal information as retrieved from the MyInfo platform;
(b) payment and/or billing information (including but not limited to credit card number and billing address);
(c) your financial information (including but not limited to your bank balance information, investment portfolio, property information), information relating to your financial services providers (including but not limited to your bank account provider and type of bank account, your insurance policies and premiums), financial preferences and objectives (e.g. financial objectives and goals); and
(d) such other information which you provide via the Site, App and/or Autumn Materials or otherwise provided or made available by you.
Without prejudice to the above, in respect of the Health Module, Autumn may additionally collect the following Data:
(i) your height, weight, sex and date of birth; and
(ii) such other information which you provide directly or via any third-party fitness tracker you permit to disclose data to us regarding your quality of life, including but not limited to smoking and drinking habits.
You warrant that any Data you provide to us is true, current, complete, accurate and not misleading.
- Other Data we collect or receive
3.1 Data collected automatically through your access and/or use of the Site, App and/or Autumn Materials
We log usage data when you visit or otherwise access and/or use the Site, App and/or Autumn Materials, such as but not limited to when you view or click on content or ads (whether on or off the Site and/or App), request for services provided by third parties or our service providers, perform a search, browse and install or update the App on your device(s). Specifically, the information we collect automatically may include information such as but not limited to 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 the Site, App and/or Autumn Materials, including the pages accessed and links clicked.
We may also collect precise geolocation data pertaining to your device(s), 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 data we collect automatically as mentioned in this Clause 3.1 enables us to better understand the users accessing and/or using the Site, App and/or Autumn Materials (including visitors who come to the Site and/or App), where they come from, and what content on the Site, App and/or Autumn Materials is of interest to them. This enables us to improve the quality and relevance of the Site, App and/or Autumn Materials to users (including visitors).
3.2 Metadata, anonymised data and aggregated data
We (including our service providers and agents) may collect the following types of data from your access and/or use of the Site, App and/or Autumn Materials, 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); and
- anonymised data and aggregated data (anonymised data aggregated with anonymised data from other users) may be used for providing, maintaining and supporting the provision of the Site, App and/or Autumn Materials, compiling statistical reports, performance tracking, conducting market research to understand user behaviour, preferences and trends, transaction categorisation and merchant identification services.
- Data collected or received from others
If you use our Investment Advisory Services, your Execution Broker and Custodian may share your Autumn Portfolio transactions details with us.
- How do we use Data?
We will not sell, rent or trade Data to third parties for commercial purposes without your consent.
We (including our service providers and agents) may collect, use, disclose and process Data for purposes including but not limited to the following:
(a) providing, evaluating and improving the Site, App and/or Autumn Materials, including but not limited to providing you with any Autumn Materials and/or any other products and services as subscribed to or requested by you;
(b) processing and administering your access to and/or use of the Site, App and/or Autumn Materials, including creating your account, facilitating your login to your account and to access and/or use the Site, App and/or Autumn Materials;
(c) accessing and analysing your financial information as requested by you;
(d) processing your applications for Autumn Materials and/or any other products and services, effecting payments from and to you, processing transactions and completing instructions or requests (including processing and administering requests to join our mailing list);
(e) providing customer service, customer support and technical support, including in relation to product updates;
(f) conducting market research and surveys with the aim of improving the Site, App and/or Autumn Materials;
(g) marketing purposes, including but not limited to organising and inviting you to promotional events, competitions and lucky draws;
(h) complying with and monitoring compliance with legal and regulatory requirements which apply to us and/or our affiliates and/or related corporations anywhere in the world, voluntary codes, internal policies (including that of our affiliates and/or related corporations), contractual obligations (including between us and our affiliates and/or related corporations) and other requirements;
(i) complying with requirements, directions or requests of any government authority with jurisdiction over us or our affiliates and/or related corporations anywhere in the world, including providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies and performing internal audits;
(j) maintaining the security of the Site, App and/or Autumn Materials, including verifying your identity;
(i) in respect of the Investment Module: providing and administering the Investment Advisory Services, including performing customer due diligence and for the purposes of account opening. This is in accordance with the Investment Module Terms.
(ii) in respect of the Health Module: providing you with health-related information, including to calculate a health status / index for you, in order to help you to improve your overall health. This is in accordance with the Health Module Terms.
Where you provide us with Data, such Data may be disclosed or transferred to:
(a) our affiliates and related corporations anywhere in the world, including any officer, employee, agent or director of any affiliate or related corporation;
(b) your financial services providers, in order to access your financial information as requested by you;
(d) our professional advisers and service providers in order to provide administrative, financial, legal, accounting, information technology, authentication, research or other services. We may also process your personal data where it is in our legitimate interests to seek professional advice, including, in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending legal rights;
(e) a merchant or a member of a card association where the disclosure is in connection with use of a card; and
(f) any person or entity authorised by you, as specified by you or in any contract with you;
(g) any person or entity to whom disclosure is required or permitted under Applicable Laws;
(h) any person or entity we consider necessary to facilitate requests for services or applications for products with our related corporations and/or affiliates; and
(i) any person or entity we consider necessary in order to provide the Site, App and/or Autumn Materials.
If you request Investment Advisory Services, your name, sex, date of birth, national ID, nationality and other personal data will be shared with Refinitiv Limited via their proprietary World-Check One system to perform due diligence and other screening activities in accordance with Applicable Laws. World-Check One stores customer data on AWS cloud located in Dublin, Ireland and London, UK. Please click here for the Refinitiv World-Check privacy statement.
- Data security
We use appropriate technical and organisational measures to protect the Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing such Data.
We monitor our systems for possible vulnerabilities and attacks. However, we cannot guarantee 100% security of any Data that you send us. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your Data arising from such risks.
Data may be transferred to, or stored at, a location outside of Singapore or your country of residence, which may not have data protection laws.
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 Data is transferred, we take all steps reasonably necessary to ensure that such Data is kept securely.
- Data retention
We retain Data 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. Where the Data constitutes personal data, we will cease to retain such Data when we no longer require such personal data for the purposes for which it was collected and for any business or legal purposes.
- Your rights
You have data protection rights, including:
(a) If you wish to access, correct, update or request withdrawal of consent for your Data, you can do so by contacting the Data Protection Officer.
- Third party websites and services
- Contacting us
You may contact our Data Protection Officer at firstname.lastname@example.org, including for any enquiries, feedback or grievances on our data protection policies and procedures.