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Privacy policy

This Privacy Policy is based on the Dutch “Wet Bescherming Persoonsgegevens” (which implements the Data Protection Directive 95/46/EC), the Singapore Personal Data Protection Act 2012 (“PDPA”) and all associated regulations and guidelines as may from time to time be issued by the legislation authorities. It sets out the basis on which any personal data Nederlandsche Betaal&Wissel Maatschappij N.V. and/or Clarency Singapore Pte. Ltd. (collectively, “the Group”, “us”, “we” or “our”) collects from the Client and/or prospective Client, or that the Client and/or prospective Client provides to the Group, will be disclosed, used and/or processed by the Group.

Unless otherwise defined in this Privacy Policy, capitalised terms used in this Privacy Policy shall have the meaning ascribed to them in the General Terms and Conditions (the “Terms”) made available in the document center on the Group’s websites and here .

By visiting or using the Website and/or any of the Services the Client and/or prospective Client is deemed to agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully prior to visiting or using any such pages or otherwise providing any personal data.

If the Client and/or prospective Client (hereinafter collectively referred to as “Client”) wishes to opt-out of this Privacy Policy, amend or remove any personal data in the Group’s possession, it may refer to the paragraph entitled “Amendments to Personal Data / Opt Out” below for the required procedure.

COLLECTION OF PERSONAL DATA

Personal data refers to data about an individual who can be identified from either that particular data, or from that data and other information which the Group has or is likely to have access to. Such personal data shall also refer to the data which is already in the Group’s possession or the data to be collected by the Group. This Privacy Policy supplements but does not supersede nor replace any other consent that the Client may have previously provided to the Group, nor does it affect any right that the Group may have at law in connection with the collection, use, disclosure and/or retention of the Client’s personal data.

The Group only collects personal data which is knowingly and specifically supplied to it by the Client for the purpose as specified prior the supply by the Client, that is necessary to provide the Services or that is necessary for compliance with a legal obligation. Without limitation, this can occur during or before the Client:

sets up an Account;

uses our Services;

provides any feedback or complaints with regard to the Services through the Website;

uploads or submits any material through the Website; and/or

participates in any marketing activity held by the Group.

Commonly collected personal data may include the following:

the Client’s name, email and postal addresses, telephone number, country of residence, nationality, age, gender, date of birth, copy of passport, business information, bank account information and other payment information;

details of any transaction the Client makes using the Services; and/or

details of any correspondence, queries, or any other forms communication (i.e. telephone, email etc.) the Client makes with the Group regarding the Services.

In addition to personal data provided to the Group, certain information related to the Client that is not considered personal data may also be collected. The Group collects this information to improve its Website and Services. Such non-personal data may include information such as details of the Client’s operating system, domain name, IP address, the internet browser used, details of the Client’s interaction with the Website and the details of any website the Client has linked from to the Website.

Use of Cookies

 

The Services and Website may use data collection devices such as “cookies” and other technologies such as pixel tags and web beacons to personalize a Client’s online experience. Please read our Cookie Policy for more information.

USE OF PERSONAL DATA

Using your personal data

 

The Group collects personal data from existing and prospective clients and employees for various reasons. Any personal data will not be further processed in a manner that is incompatible with the purpose as stated before processing, for the performance of the Services, or to comply with a legal obligation. Without limitation, these purposes can include:

confirming the Client’s identity during creation of his/its Account and to ensure the Client’s eligibility to use the Services provided;

communicating with you and responding to your queries;

improving the Services and the Client’s experience on the Website;

providing you with information and updates on selected products and services that the Group thinks may be of interest to you;

administering and processing credit transactions in connection with the Client’s use of the Services;

analyzing the effectiveness of our advertisements and promotions;

customising the Client’s Website experience, as well as evaluating statistics on Website activity, such as what time you visited it, whether you have visited it before and what website referred you to it;

conducting required anti-money laundering checks;

notifying you of any changes to the Services that may be relevant to you;

conducting surveys, research and statistical analysis with the aim of helping the Group monitor and improve the Services;

supplying the Client with information that is relevant to the Client’s existing relationship with the Group; and/or

any other purposes as permitted by applicable laws.

Where the Group collects personal data for a specific purpose, the Group will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons.

Sharing your personal data

The Group takes securing your personal data and preserving your privacy very seriously. The Group will not offer, publish or share your personal data with third parties, without seeking the Client’s explicit permission, unless the Group expressly states otherwise elsewhere in this Privacy Policy, the Terms or the agreement between the Group and the Client, or the Group is obliged by law. The Group will never sell your data.

If agreed upon, or based on law, the Group may process, use and disclose your personal information with third parties. Such third parties may be based abroad and may include but are not limited to the following:

regulatory authorities and enforcement agencies;

any court of law or any relevant party in connection with any claim or legal proceeding;

contractors, service providers, consultants, auditors and advisors on a need to know basis;

advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions;

our subsidiaries, parent company or related companies;

professional service providers;

third parties required to process the Services for you or otherwise provide any Services to you;

web analytics tool providers, such as Google.

We may share your personal data for the following reasons:

reasons provided under ‘using your personal data’;

to enforce any provision of the Terms and/or Agreement;

to protect the rights or property of any member of the Group (including but not limited to any intellectual property rights);

to conduct investigations in respect of any possible breach of applicable laws (only if legally obliged); and/or

to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate (only if legally obliged).

In situations where a third party under contract with the Group collects and/or receives personal data about you, the Group will require the third party to act according to laws regarding personal data and to exercise reasonable care in protecting your information.

You are responsible for providing accurate and complete information about yourself and any other person whose personal information you provide us, and to notify us (either by the Website or by letter) if there are any changes to your personal information.

SECURITY

The Group endeavours to take all reasonable steps to protect your personal data and to store it securely. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While security cannot be guaranteed, the Group strives to protect your personal data and are constantly reviewing and enhancing our security protocols to ensure that your personal data is not subject to unnecessary risks. In using he Services, you accept the inherent security implications of engaging in transactions online over the internet and you agree that you will not hold the Group responsible for any breach of security unless we have been grossly negligent or in willful default.

AMENDMENTS TO PERSONAL DATA / OPT OUT

If you wish to access, correct (including update) and remove the personal data held by the Group or you do not want your personal data to be shared according to this Privacy Policy, you may contact us as follows:

If you are a resident in Singapore

by e-mail to: support@clarency.com

or by postal mail to: The Data Protection Officer in Singapore

Dutch Payment & Exchange Company Pte Ltd

1 Wallich Street, #14-01

Guoco Tower

Singapore 078881

If you are a resident in the EEA

By email to: info@nbwm.nl

 

Or by postal mail to: The Data Protection Officer in the EEA

Nederlandsche Betaal&Wissel Maatschappij N.V.
Beursplein 5
1012 JW Amsterdam

You may also decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive.

RIGHTS TO AMEND THIS PRIVACY POLICY

The Group reserves the right to update this Privacy Policy at any time to take into account any changes in law or for any other reason. If we update this Privacy Policy, we will post a new version on the Website. We will also post a notice of the changes on our Website or notify you by email (sent to the email address specified in your Account). We encourage you to periodically review this page for the latest information on our privacy practices.

Your continued use of the Website and Services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided. If there is a conflict between two versions of the Privacy Policy to which you have agreed or been deemed to agree, the more recent version shall take precedence unless it is expressly stated otherwise.

MISCELLANEOUS

Complaints
The Group aims to provide its Clients with the highest standard of service regarding our Services, the Privacy Policy etc. However, in the rare occasions where our services has not met your expectations, please send an email to compliance@nbwm.nl if you are a client of Nederlandsche Betaal&Wissel Maatschappij N.V. or LegalSG@clarency.com if you are a client of Clarency Singapore Pte. Ltd. We will provide information on the taken action and we will provide you again with the highest standard of service. If you remain unsatisfied with our response, you have the right to lodge a complaint with a supervisory authority.

 

However, we encourage our Clients to lodge a complaint with the Group before lodging a complaint to the supervisory authority. We will always fully investigate your complaint.

 

Policy concerning Children

Individuals under the age of 18 are not eligible to use the Services offered by the Group without adult supervision. Please obtain your parents' or guardians' permission before you send any information about yourself (your name, address, e-mail address, etc.) to us or anyone else over the internet. We encourage parents to get involved with their children's use of the Internet and to be aware of the activities in which they are participating.

Governing law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with:

the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the courts of the Republic of Singapore, if you are a resident in Singapore; or

the laws of the Netherlands and you agree to submit to the exclusive jurisdiction of the courts in the Netherlands, if you are a resident in the EEA.

 

CONTACT US

If you wish to communicate with us about anything related to this Privacy Policy, you may contact us by email at info@nbwm.nl or support@clarency.com.