DATA PROTECTION POLICY

Updated: 1 December 2017

This Privacy Policy is effective immediately upon publication.

Zero Mobile Pte. Ltd., Zero Technologies Pty Ltd and any other related entity, known together as Zero SG ("we," "us,"), respect your privacy and are committed to protecting it through our compliance with this Privacy and Data Protection Policy (“Privacy Policy”), the Personal Data Protection laws in Singapore and any other applicable laws or regulations. Any information we collect, use or disclose is in accordance with the Personal Data Protection Act, the relevant regulations and this Privacy Policy.

We will collect your personal information to provide our services to you. We may also collect your personal information to improve our services to you or to simply communicate with you.

We understand the value of your personal information and the need for keeping it safe. We take every effort to ensure the safety your personal information.

CONSENT
You consent for us to collect, use or disclose your personal information and accept that the information we collect in accordance with this Policy is reasonably required for us to provide our service(s) to you.

You will be deemed to have provided your consent if you provide us with any information voluntarily in order to provision our service(s) to you. You also accept that by continuing to use, or attempting to use, our service(s) would be deemed as your acceptance of this Policy.

WHY DO WE COLLECT YOUR PERSONAL INFORMATION
We may collect your personal information:
i. To provide you with the product of service(s) you have requested, including billing you for services;
ii. To provision, manage or otherwise provide any support relating to your service(s);
iii. To conduct research and improve our products and services, including the user experience;
iv. To provide you with relevant content, advertising, deals, offers, marketplace products and services or any for any other purpose required to enable the delivery of your product or services;
v. When required by law to do so;
vi. To prevent and minimise fraud;
vii. To prevent any unlawful activity or any activity that may be deemed unlawful;
viii. To ensure safety and security of our digital platforms, network and any other property;
ix. Or for any reason related to the provision, management and continuing delivery of our products and services.

WHAT PERSONAL INFORMATION DO WE COLLECT
The scope of information we require to efficiently and effectively provide you with the products and services that you have require varies. In general, you give us your consent to collect:
i. Your legal name;
ii. Your date of birth;
iii. Your address and any other documentation required to establish the validity of your address;
iv. NRIC Number, 11B, Passport, Work Permit, Employment Pass, or any other form of government issued identification, whether issued by the Government of Singapore or not, as well as your bank card, debit card and credit card or any other relevant document to establish you identity;
v. Your contact numbers;
vi. Your email address;
vii. Details on any services you have acquired from us and any other details related to your accounts;
viii. Information related to any communication between you and us;
ix. Your Call Detail Records (CDRs) including the numbers you have called or received calls from, including the call duration, the numbers you have sent text messages to or received text messages from, your mobile internet usage history, your web browsing history, location of your mobile device or any other usage on the network;
x. Your device information, including your device type, model, operating system, software, IMEI, or any other device related information required by us to provide our service;
xi. Information about your preferences related to any products, services, advertising, offers or anything else that is required for us to provide our service to you;
xii. Information related to your credit worthiness from any third party organisation in order to determine our ability to provide you with ongoing credit;
xiii. Information that is required for us to fulfil our legal obligations from any other lawful source.

HOW WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal information from:
i. Our website – from the information that you provide us and also using cookies;
ii. Various software applications or platforms that we operate and you interact with;
iii. Our mobile application;
iv. Any other source where you have provided the information voluntarily.

CORRECTION TO PERSONAL INFORMATION
As part of our obligations, we ensure that any personal information we hold about you is accurate. As a significant amount of this information is provided directly by you to us, you should inform us of any inaccuracies in any of your information we hold.

You can request your personal information that we hold or send in a request to correct any inaccuracies you find by contacting the Data Protection Officer. We will review your request and respond within 30 days.

Data Protection Officer
Zero Mobile Pte. Ltd.

dpo@zeromobile.com.sg

DATA PROTECTION
We are committed to protect the information that you have provided us with. We use various policies and internal measures to ensure that your information is protected. These measures include providing information on a need-to-know basis, safeguards against security breaches, and various precautions to prevent unauthorised access to your information.

DATA RETENTION
We will not retain any personal data or remove the means by which you may be personally identified – thereby anonymising the personal information – when the business need for which this data was collected no longer exists, unless required by law to continue retaining it.

DATA SHARING
As part of fulfilling our contractual obligations to you, you consent to us sharing your information with:
i. Any related corporations to us in Singapore, or Overseas, in accordance with our obligations under the Personal Data Protection Act (2012) and any other applicable laws. We will ensure that any personal data transferred, if any, will be done at the standard of protection that applies to us in Singapore, or at a higher standard, to ensure the protection of your personal information;
ii. Third party vendors, service providers or software companies;
iii. Payment service providers or other financial institutions;
iv. Credit reporting agencies;
v. Any other organisation or agency as required by law.

CHANGES TO THIS POLICY
In order to provide a better service, we may review and change this policy from time to time. If any significant changes are made, we will notify you via the Zero App or email. All changes made will be published on our website.

We recommend that you review this Policy from time to time. You agree that by continuing to use our service, you are deemed to have provided your consent to any updates to this Policy, unless such a consent will be in contravention of any applicable laws.

CONSENT WITHDRAWAL
You may withdraw your consent for us to collect your personal information at any time. However in doing so, it may not be possible for us to providing you access with any of our products and services anymore.

Please note that if you choose to withdraw your consent, we will still continue to hold any of your personal information as required by law.

To withdraw your consent, please contact the Data Protection Officer.

Data Protection Officer
Zero Mobile Pte. Ltd.

dpo@zeromobile.com.sg

CHILDREN’S PRIVACY
We not knowingly collect personal information from children under the age of 16. If we learn that we have personal information on a child under the age of 16, we will delete that information from our servers.

GOVERNING LAW
This Privacy Policy and the use of our services are governed by the laws of the Republic of Singapore. The parties undertake to first try to resolve the dispute with by negotiation. If the parties fail to reach an amicable resolution through negotiation within 30 days, we agree to submit the dispute to the competent Court of Singapore.