AUTUMN PRIVACY POLICY

v4.0 – Last updated 1 July 2022

This Privacy Policy should be read in conjunction with the Autumn Terms of Use and the Schedules (“Terms of Use”). Unless otherwise stated, all other capitalised terms contained in this Privacy Policy shall have the meaning given to it in the Terms of Use and whenever the words “include”, “includes” or “including” are used, they will be deemed to be followed by the words “without limitation”.

Your privacy is important to Autumn and it is our policy to respect and protect your privacy.  

This Privacy Policy outlines how we collect, use, disclose and process personal information (including personal data) relating to you, or that may relate to a third party individual and is provided by you (collectively “Data”), in compliance with Applicable Laws.

It also tells you how you can exercise your privacy rights.

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

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.

1. 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.

2. 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, 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.

Where you provide us with Data relating to other individuals, you warrant that such individuals have consented to us collecting, using, disclosing and processing such Data for the relevant purpose(s) for which you made the disclosure or as was notified to you at the relevant time and/or the relevant purposes as set out in this Privacy Policy.

You warrant that any Data you provide to us is true, current, complete, accurate and not misleading.

3. 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).

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, App and Autumn Materials, including when you use different devices. To learn more, including how to change your cookie settings, please see the third party links listed below, which provide more information, including about what cookies are installed and how to allow, block or remove installation from your computer / device. Depending on which browser you use, you may follow these links:

Learn more about our Cookie Policy here.

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.

4. Data collected or received from others

From time to time, we may collect or receive Data from third party sources to assist us in providing, evaluating and improving the Site, App and/or Autumn Materials and/or for such other purposes as set out in this Privacy Policy, but only where these third parties represented that you gave your consent either or are otherwise legally permitted or required to disclose such Data to us.

5. How do we use Data?

We will only collect, use, disclose and process Data for the purposes set out in this Privacy Policy or which you have been notified of and consented to or for such other purposes which are permitted under Applicable Laws.

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;

  • 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;  

(k)            investigating or preventing possible fraud or other non-compliance or violations of the Terms of Use, this Privacy Policy or such other applicable terms and conditions and/or in connection with possible attempts to harm us and/or our members, visitors, or other third parties.

(l)              Without prejudice to the above and in addition to the purposes set out elsewhere (including the Terms of Use), we and our service providers and agents may additionally collect, use, disclose and process your Data for the following purposes in respect of individual Autumn Materials accessed and/or used by you:

(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.

(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.

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;

(c)            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 such Data only for the purposes disclosed in this Privacy Policy and/or for such other purposes which are permitted under Applicable Laws;

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

(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.

6. 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.

7. 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.

8. 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.

(b)            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” link in the marketing e-mails we send you. To opt-out of or withdraw your consent in respect of other forms of marketing (such as postal marketing), 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 (or such shorter duration as may be prescribed under Applicable Laws) 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, please note that opting out of or withdrawing your consent for marketing communications alone does not mean that we may not continue using and disclosing your Data for other purposes set out in this Privacy Policy.

9. Updates to this Privacy Policy

We may update this Privacy Policy from time to time, including where required by legal, technical or business developments and you acknowledge that your continued access to and/or use of the Site, App and/or any Autumn Materials after such update has come into effect shall be deemed as an agreement by you to the Privacy Policy as so updated. 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.

10. Third party websites and services

Without prejudice to any provision in the Terms of Use, the Site, App and/or Autumn Materials may contain links to third-party websites or mobile applications, including social sharing features and other related tools and the links set out in Clause 3 above. Please be aware that we do not control or operate these third-party linked websites or applications and that this Privacy Policy does not apply to such websites or applications and to any information you provide through these websites or applications. We encourage you to read the privacy policies / privacy statements of any third-party websites or applications that you visit before you provide them with any information.

11. Contacting us

You may contact our Data Protection Officer at privacy@autumn.sg, including for any enquiries, feedback or grievances on our data protection policies and procedures.