TERMS / DATA PRIVACY

TERMS OF USE

Impact Credit Solutions (ICS)

Please read the Terms of Use carefully before using the ICS Site. Each time you access or use the ICS Site, you acknowledge that you have read the Terms of Use and fully accept and agree to abide and be bound by them, as may be modified from time to time.

ICS is registered as a Registered Fund Management Company with the Monetary Authority of Singapore.

The Terms of Use are a binding agreement between you and ICS, and governs your access and use of the ICS Site, which includes any information, data and other content made available on or through (including any requests made by you through) the ICS Site. If you do not accept the terms and conditions stated in the Terms of Use, you are not an authorized user of the ICS Site and should not use the ICS Site.

ICS reserves the right to change, modify, add or remove portions of the Terms of Use at any time for any reason and in our sole discretion. We suggest that you periodically review the Terms of Use for amendments. The Terms of Use were last updated on 6th August 2018.

“ICS”, wherever used, means Impact Credit Solutions Pte. Ltd. and its affiliates, their officers, directors, managing directors, partners and employees. “This website” or “ICS Site” means the website of ICS located at https://impactcredit.solutions and whatever domains owned by ICS that direct the public to the content located at https://impactcredit.solutions.

LIMITATIONS ON USE OF INFORMATION CONTAINED IN THE ICS SITE
Information made available on or through the ICS Site is for your individual use only. Although you may store, display, analyze, and/or print minimal copies of information contained on or made available through the ICS website only for your own use, you are not permitted to publish, broadcast, transmit, repackage or otherwise reproduce or commercially exploit this material – in whole or in part – in any format to a third party without the express written consent of ICS. Any use of the ICS Site’s materials must not alter the original content thereof, including all legal notices and legends. Furthermore, you are not permitted to alter, obscure, or remove any copyright, trademark or any other notices that appear anywhere in conjunction with the information provided in the ICS Site.

ICS reserves the right, at any time and from time to time, for any reason whatsoever, to modify or remove any information in the ICS Site. Your use of this website and these Terms of Use are not intended to, and do not, transfer or grant any rights to you or other party other than the rights set out in these Terms of Use. All rights not specifically granted herein are reserved by ICS, or the third party owners of such rights. When using information provided by third parties, you are required to abide by the terms and conditions not only of this website, but also by whatever terms and conditions are imposed by such third party providers.

Furthermore, you agree that you will not interfere or attempt to interfere with the proper functioning of the website or upload or link malicious content.

MONITORING, COLLECTION, USE AND DISSEMINATION OF DATA BY ICS
Your use of the ICS Site (including any products and service made available on or through the ICS Site) may be monitored by ICS, and any data (whether personal or otherwise) and the resulting information from such use may be collected and used by ICS for its internal business purposes and disclosed or disseminated to third parties (including ICS’s associated or affiliated companies, administrator or other service providers, governmental or other authorities and regulatory and self-regulatory bodies) to the extent required by any law or regulation or for any reason ICS thinks fit.

This website uses Google Analytics, a web analytics service provided by Google Inc. (Google). Google Analytics uses cookies and JavaScript code to enable the analysis of user activity on this website. The data collected is transmitted to and stored on Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. The reports provided by Google Analytics help us understand our website traffic and usage.

To learn more about the data Google collects and how it’s used please refer to Google’s Privacy Policy. You can opt out of Google Analytics if you disable cookies or JavaScript but please be aware that doing so may prevent parts of this website from functioning correctly. Alternatively you can use the opt-out browser plugin provided by Google.

Please note that any personal data or information (“Personal Data”) provided by you to ICS and the administrator in connection with any potential or existing investment may be retained and used for purposes connected to the business of ICS (including, without limitation, collecting and processing data and information on, and for profiling, potential investors). This includes the release of Personal Data to third party service providers for the purposes of providing administrative and other services or conducting identity and other necessary checks, and relevant supervisory authorities for the purposes of compliance with applicable laws and regulations.

ICS is committed to keeping all Personal Data confidential and secure, and to confine the use of such information, in compliance with all applicable laws and regulations, including Singapore’s Personal Data Protection Act 2012. If you wish to amend, or obtain more information on, your Personal Data, please contact ICS at info@impactcredit.solutions.

NO WARRANTIES OR RESPONSIBILITIES
ICS makes no warranty, express or implied, guarantee or assurance concerning the ICS Site or any other website accessible through the ICS Site. The ICS Site, including links to any third party service, is provided at your sole risk on an ‘as is’ basis. Any warranty, including but not limited to warranties regarding the fitness (for whatever use), merchantability or accuracy of the ICS Site, is expressly disclaimed to the fullest extent allowed by law. Any links to third party sites and resources should not be interpreted as approval by ICS of those sites or the information you obtain therefrom.

Furthermore, neither ICS nor any third party provider has any responsibility to maintain the ICS Site, or to ensure its accuracy. Although ICS makes reasonable efforts to update the information on our site, it makes no representations, warranties or guarantees, whether express or implied, that the content on the site is accurate, complete or up to date. ICS does not warrant that any part of the site will operate uninterrupted or that defects will be corrected. ICS has sole discretion as to the continuing availability of the ICS Site or any other website accessible through the ICS Site.

You agree that your use of this website or reliance upon any content thereon is at your sole risk. You further acknowledge that nothing contained on the ICS Site or made available through the ICS Site constitutes investment, legal, tax or other advice, nor is it to be relied upon in making any investment or other decisions. You should seek professional advice or specialist advice before taking, or refraining from, any action or decision on the basis of the content on our website.

NO LIABILITY FOR USE
By using the ICS Site, you agree that ICS has no liability of any kind to you or third parties or any responsibility for your ability (or inability) to access the ICS Site. Furthermore, by using the ICS Site, you agree that ICS shall have no liability, contingent or otherwise, to you or to third parties, for accuracy, correctness, or availability of any information contained in the ICS Site, and you further agree that ICS is not and shall not be liable for any losses or damages of any nature, including but not limited to any direct, indirect, punitive, special incidental or consequential damages, which may at any time result from, or arise in connection with, your access to, use of (or inability to use) or distribution of the ICS Site or from any information, contents, materials, products or other content included thereon or otherwise made available to you through the ICS Site, notwithstanding the fact that ICS may be informed of those facts. Furthermore, you agree that ICS has no responsibility to inform you whether any problems or complaints have resulted from the ICS Site.

NO SOLICITATION OR RECOMMENDATION
The information contained in the ICS Site has been prepared for informational purposes only without regard to any particular user’s investment objectives, financial situation, or means, and ICS is not offering to sell or buy any securities or otherwise soliciting any action or business based upon it. The information contained in or provided through the ICS Site is not to be construed as a recommendation; or an offer to buy or sell; or the solicitation of an offer to buy or sell any security, financial product, or instrument; or to participate in any particular trading strategy in any jurisdiction in which such an offer or solicitation, or trading strategy would be illegal; or as an offer of services or participation. Certain transactions, including (but not limited to) those involving futures, options, and high-yield securities, without or without the use of leverage, give rise to substantial risk and are not suitable for all investors. Although such information may be considered by ICS to be reliable, ICS has not verified this information and does not represent that any such information is accurate, current, or complete and it should not be relied upon as such.

The fact that ICS has made the ICS Site and its content available to you is neither a recommendation that you enter into a particular transaction nor a representation that any product described on the ICS Site is suitable or appropriate for you. The transactions and investments described in the ICS Site involve significant risks, and you should not enter into any transactions unless you have fully understood all such risks and have independently determined that such transactions and investments are appropriate for you. Any transactions listed on the site are included as representative transactions and are not necessarily reflective of overall performance.

Any discussion of the risks contained herein with respect to any transaction or investment should not be considered to be a disclosure of all risks or complete discussion of the risks which are mentioned. You should neither construe any of the information contained herein as business, financial, investment, hedging, trading, legal, regulatory, tax or accounting advice nor make the ICS Site or the information contained therein the primary basis for any investment decisions made by or on behalf of you, your accountants, or your managed or fiduciary accounts, and you may want to consult your business advisor, attorney, and tax and accounting advisors concerning any contemplated transactions and investments.

PASSWORDS
You may receive a password to access certain restricted areas of the ICS Site or certain confidential information relating to ICS or your investment in ICS. You are responsible for maintaining the confidentiality and security of your password. You may not disclose your password to any third party, and you accept full responsibility for any use of your password. You must notify ICS immediately of any actual or suspected loss, theft or unauthorized use of your password. ICS is not obligated to inquire as to the authority or propriety of any use of or action taken using your password. ICS will not be responsible for any loss to you that arises from such use or action or from your failure to comply with these provisions.

NO WARRANTY AS TO SECURITY
Information provided via the internet enjoys varying degrees of security based in part on factors beyond ICS’s control. You therefore agree that ICS is not responsible for the security of your information. Further, ICS makes no warranty of any kind regarding the security of the ICS Site or your information.

NOTICE
If you have any questions about these Terms of Use, you may contact ICS at info@impactcredit.solutions.

GENERAL
Your compliance with these Terms of Use and all other rules, procedures, policies, terms and conditions that govern all or any portion of the ICS Site is a condition to your right to access the ICS Site. Your breach of any provision of these Terms of Use or other rules, procedures, policies, terms and conditions that govern all or any portion of the ICS Site will automatically, without the requirement of notice or other action, revoke and terminate your right to access the ICS Site and you will be fully liable for conversion, misappropriation, trespass to chattels and all other claims and causes, regardless of the identity of claimant or injured party, arising from, or relating to, your continued use of the ICS Site after such breach.

If any provision of these Terms of Use is held by a court of competent jurisdiction to be unenforceable for any reason, the remaining provisions hereof shall be unaffected and remain in full force and effect. These Terms of Use shall for all purposes be governed by and interpreted in accordance with the laws of the Republic of Singapore as those laws are applied to contracts entered into and to be performed entirely in Singapore, without regard to conflicts of law provisions. Any suit or proceeding arising out of or relating to these Terms of Use shall be commenced exclusively in the Republic of Singapore, and you irrevocably submit to the exclusive jurisdiction and venue of such courts or to arbitration administered by the Singapore International Arbitration Centre in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, as may be determined by ICS in our sole discretion.

DATA PROTECTION NOTICE FOR CUSTOMERS

Impact Credit Solutions (ICS)

This Data Protection Notice (“Notice”) sets out the basis which Impact Credit Solutions Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA
As used in this Notice:

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as nric, fin, work permit and birth certificate, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information and financial information.

Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) any other purposes for which you have provided the information;
(h) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) any other incidental business purposes related to or in connection with the above.

We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 7 above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Attention: Data Protection Officer
Email Address: info@impactcredit.solutions
Address: 3 Anson Road #35-02, Springleaf Tower, Singapore 079909

EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 11/04/2019
Last updated : 06/05/2019