Updated on [17 August 2021]
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.
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:
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:
3. DATA PROCESSING PARTNERS
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.
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