Sleek Business Account Privacy policy

Updated on [17 August 2021]

*This notice does not supersede our global privacy policy and should be read in conjunction.

This Privacy Notice applies to your creation, access and use of the Sleek Business Account services (“Wallet”) provided for by Sleek Tech Pte Ltd (‘Sleek’) within our existing Sleek Platform (“Platform”). The Wallet is operated by multiple providers for Sleek. This notice sets out how we may collect, use, disclose and otherwise process your Personal Data for the purposes in relation to our Wallet services as enumerated below. 

For the purpose of this Privacy Notice, Personal Data will have the same meaning as our global privacy policy.

Some terms used in this Privacy Notice but not defined here shall have the meaning ascribed to them in our Terms and Conditions. All references to “we ,” “us,” or “our” shall refer to Sleek as operator of the Wallet. “You” and “your” shall refer to the User who has completed registration of the Wallet account and thus have been authorized to use the Wallet services. 

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We will collect and process the following data about you:

• Information you give us – Information obtained when (1) you register with Sleek as a general user of Sleek platform, and (2) you register as a user of the Wallet, including your name, date of birth, gender, address, telephone number, email address, (collectively, ““Submitted Information”).
• Information obtained (directly or indirectly) during your use of the Wallet, including account holder’s name, bank account numbers, transaction data, information from bank statements (collectively, “Account Information”).
• Where necessary, in order to prevent your account or assets from being compromised, or to comply with laws and regulations regarding the “Know-Your-Client” processes, we may also collect your ID documents such as resident ID card, passport or other documents, as well as your address proof and/or other information that can be used to identify you (collectively, “KYC Information”).  
• Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Sleek Services), sub-contractors in technical, payment and financial services. The providers that help us provide you with our Wallet Services include banking partners, banking intermediaries and international payment service providers.
• Combination, derivation or updated versions of the above Information, Registration Information, Account Information, KYC Information or such other information may be accessed or collected (automatically or manually) during your registration as a user of the Wallet and/or in the course of your use of the Wallet.

We have taken steps to ensure that we do not collect more information (whether or not such information constitutes Personal Data) from you than is necessary for us to provide you with our services, to serve the purposes set out in this notice, to protect your account, to comply with our legal obligations, to protect yours and our legal rights, and to operate our business

2. DISCLOSURE OF YOUR INFORMATION

We will use and disclose information about you for the following purposes:

• For the purposes of which you have already consented to as part of our global privacy policy;
• To carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, International Transfers, Virtual Card Issuance, Virtual Card Transactions and any other transactions that you request from us as part of our Wallet services.
• To comply with our regulatory obligations, e.g. requests from competent authorities.

3. DATA PROCESSING PARTNERS

• We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Sleek.
• We send personal data to the following sets of data processors in order to perform the Wallet services:

Identity verification providers

This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;

Banking and financial services partners

Financial services providers that help us provide the Sleek wallet services including banking partners, banking intermediaries and international payments services providers;

Companies within the Sleek group

In order to provide a unified service across all of our products and services, we may disclose your personal information to any member of the Sleek group, which means any of Sleek tech Ltd’s subsidiaries or our related entities. 

• We may also disclose your personal information in the following circumstances:
• If Sleek or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to: (i) enforce or apply the General Terms of Service and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or (ii) protect the rights, property or safety of Sleek, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4. THIRD  PARTY SERVICES

We may share your data in order to provide certain services to you upon your request. For example, we may share your data with one of Sleek’s financial partners so that we can provide the wallet services to you. Your data will only be sent across in these instances once you have requested to utilise the wallet service. The Wallet may provide links or logos to other websites and services (operated by third parties) for your convenience and information. These services and websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review before you use any of their services or conduct any activities on those websites. To the extent that any linked websites you visit are not owned or controlled by us, we are not responsible for their contents, their privacy practices and the quality of their services. 

5. INTERNATIONAL DATA PROCESSING

The data that we collect from you may be transferred to, processed, and stored at a destination outside Singapore. As we provide an international service, your data also may be processed outside Singapore in order for us to fulfil our contract with you to provide the Wallet services. We will need to process your personal data in order for us, for example, to action a request made by you to execute an international payment, process your payment details, adhere to global anti-money laundering and counter terrorist financing regulations and provide ongoing support services. We will take all steps to ensure that your data is treated securely and in accordance with the PDPA.

6. RETAINING YOUR DATA, DOCUMENTS AND INFORMATION

Pursuant to the PDPA, Sleek is allowed to retain personal data about you and your Sleek Transactions for such time until the retention of your personal data is no longer necessary for any business or legal purpose. In particular, we are required, as an entity subject to the regulatory supervision of the Monetary Authority of Singapore (“MAS”), to retain data, documents and information we collect as part of complying with our anti-money laundering and countering the financing of terrorism (“AML/CFT”) obligations (which may include your personal data, documents and information) for at least five years after the termination of business relations with you or the completion of transactions you undertake with or through us.

7. YOUR LEGAL RIGHTS

You have rights under data protection laws in relation to your personal data. Please refer to our global privacy policy to find out more about these rights. All questions relating to data and your privacy are welcomed and should be addressed to [email protected].