CHANGI PAY PRIVACY POLICY

 

This Privacy Policy (this “Policy”) as may be amended, modified or supplemented from time to time, applies to all visitors accessing and/or using the Changi Pay (such persons collectively referred to as “you”) and is meant to help you understand how Liquid Group Pte. Ltd. and its related corporations (“Liquid” or “we” or “us”) collect, use, disclose, transfer and store your personal information so please take time to read it carefully. All capitalised terms used in this Policy shall have the same meaning as those ascribed in the Terms of Use unless otherwise stated or defined herein.

By signing-up as a registered user, accessing or using the Changi Pay, or any of our Services, you are accepting this Policy and consenting to the collection, use and/or disclosure of your information disclosed to us in the manner as explained in this Policy. If you do not agree with this Policy, please do not use or access the Changi Pay.

 

INFORMATION COLLECTION, USE AND DISCLOSURE

The information we may collect includes (but is not limited to) the following:

Information you provide to us: We may collect and store information you disclose to us when you sign up on the Changi Pay as a User (including information which you authorize Changi Airport Group (Singapore) Pte Ltd and its affiliates to disclose to Liquid) and/or access and/or use (whether as a User or otherwise) the Changi Pay. We may ask you for your personal information, including but not limited to, your first name, last name, email address, mobile number, gender and date of birth at the point of signing up or registration. Once you have successfully registered with us as a User, you may not be anonymous to us. We may also collect and store information when you interact with us including, but not limited to, instances when you add or update your User Account details via the Changi Pay, when you upload an image of yourself under your User Account details, when you participate in activities on the Changi Pay, when you add your credit/debit/charge card details to your User Account, or when you correspond with us regarding the Changi Pay. 

Information we collect automatically: When you use the Changi Pay, we may collect information sent to us by your computer, mobile phone or another access device. Such information includes, but is not limited to, details of your page visits or mobile application usage, your computer or mobile devices’ configuration such as (but not limited to) your IP address, location, your transactions executed within the Changi Pay, screens viewed within the Changi Pay, cookie information and the pages you requested.

Locational information: When accessing and/or using the Changi Pay, we may collect and store your locational information if permission has been explicitly granted to the Changi Pay  by you, in order to verify or authenticate transactions as well as to improve your user experience through localized content. The Changi Pay may use technologies available through the devices including but not limited to GPS, WiFi, IP address and cell towers to generate your location, unless you configure your operating system settings to prevent our collection of locational information.

Other information: By taking up any Services (or participating in any promotions or surveys or by completing certain tasks or actions on the Changi Pay, you consent to sharing such information you provide with us and the relevant Third Party Service Providers. We may share this information with our Third Party Service Providers and we may use such information to match offers or provide discounts and services to your profile. The information shared with our Third Party Service Providers may be used at such Third Party Service Providers’ discretion and in accordance with such Third Party Service Providers’ privacy policies. Liquid does not assume liability or responsibility of how the information is used by such Third Party Service Providers. We will share your information, including personal information, locational information, friends list(s), and moments with certain social networking or other third party applications or services, if you choose to connect these to your User Account. Subject to compliance with privacy laws from time to time and without prejudice to the above, we may also use any information we obtain about your activity on the Changi Pay, or in connection with our Services, on an anonymised basis.

Collection, use and/or disclosure of information: We may collect, use and/or disclose information for the following purposes (among others):-

  • to help us further create, develop, operate, deliver, and improve the Changi Pay;
  • to administer, manage and operate the Changi Pay, to provide the Services through the Changi Pay and such other channels as may be available from time to time, and to provide customer service to you;
  • to conduct marketing promotions and to offer discounts and other privileges to you;
  • to help us to verify identity, protect our systems and customers, ensure the integrity and operation of our businesses and systems and for loss prevention and anti-fraud purposes;
  • to send important notices, such as communications about purchases and changes to our terms, conditions, and policies;
  • to offer you tailored content, such as giving you updates on special offers and reward schemes;
  • for internal purposes such as auditing, data analysis, and research to improve the Changi Pay and customer communications;
  • where collected from cookies and other technologies, like pixel tags, to improve your user experience and the quality and scope of our services;
  • to comply with applicable laws, regulations and other requirements (e.g. providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies, cooperating with governmental requests, performing internal audits);
  • to report any activity that we suspect violates any law or regulation to appropriate law enforcement agencies, regulatory authorities and other governmental agencies;
  • to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against any legal claims; and/or
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use, the terms of any Third Party Service Provider, any terms relating to any particular offer, promotion or task, or as otherwise required by law.

We may process your personal information on a server located outside the country where you live.

We may, from time to time, use the services of Third Party Service Providers and other third parties in connection with the Changi Pay. As such, we may share your information with these persons who are working with us to perform functions and process user data on our behalf. Rest assured that such access to your personal information will only be to perform services on our behalf and such third parties are obligated contractually to us not to disclose it or use it for any other purposes. In connection with the foregoing, some of these third parties, such as analytics providers, may collect information about your online activities over time and across different websites or online services when you use our services. We are not responsible for the actions or compliance of third parties, nor are we responsible for any additional information you provide directly to any third parties.

In the event of a potential, proposed or actual sale or disposal of business or interest, merger, acquisition, reorganization or funding exercise relating to Liquid (including negotiations thereof) or any other situation where personal information may be disclosed or transferred as one of our business assets, we will notify you before personal information about you is transferred and becomes subject to a different privacy policy.

Accessing and updating your personal information: When updating your personal information with us, we may ask you to verify your identity before we act on your request. To the extent permitted by law, we may reject requests that are unreasonably repetitive, require disproportionate technical effort, risk the privacy of others, or would be extremely impractical. Whilst we do impose any fees or charges to provide information access and/or make any corrections, we reserve the right to do so where it would require a disproportionate amount of effort on our part. In the event that you choose to close your User Account with us, we may still continue to retain personal information on you in our databases after your User Account has been closed, for legitimate business or legal purposes.

 

MERCHANTS AND THIRD PARTY SERVICE PROVIDERS

We work with Merchants, banks or other Third Party Service Providers to enable them to accept payments from you using Changi Pay. In doing so and in order for us to process your payments via the Changi Pay, we may share information about you with such party, such as your name, contact information, any image or profile picture you upload onto the Changi Pay, date of sign-up, the details of your payment transaction and number of payments you have made. We may also use this information to confirm to that party that you are a User.

We may also work with Merchants, banks or other Third Party Service Providers to enable them to offer their own electronic pre-paid cards, wallets, membership cards or discount cards on our Changi Pay. In doing so, we may share information about you with such party, such as your name, mobile phone number, gender, date of birth or Changi Pay username and any other information that you may disclose to us when you choose to register for and use their electronic pre-paid cards, wallets, membership cards or discount cards on our Changi Pay.

We do not disclose your credit/debit/charge card number number to anyone you have paid using our Changi Pay, except with your express permission or if we are required to do so in order to comply with a court order or other legal process. We do not store your /debit/charge card information that you provide to us on the Changi Pay or your mobile device. Your credit/debit/charge card information is tokenised once successfully verified and accepted by the Changi Pay. Through tokenization, all sensitive data on your credit/debit/charge card will be replaced with a unique identifier that generally cannot be mathematically reversed.

 

INFORMATION SHARING AND DISCLOSURE

We do not distribute your personal information to any third party unaffiliated with Changi Pay or who is not a Merchant or other Third Party Service Provider, except when we have your permission to do so.

In the event of a potential, proposed or actual sale or disposal of business or interest, merger, acquisition, reorganisation or funding exercise relating to Liquid (including negotiations thereof) or any other situation where personal information may be disclosed or transferred as one of our business assets, we will notify you before personal information about you is transferred and becomes subject to a different privacy policy.

You agree that by opting to participate in any promotions, activities or surveys relating to Liquid from time to time, you consent to Liquid sharing all information (including any personally identifiable information) that we collect from you with the relevant Merchant or Third Party Service Providers in connection with the relevant activity, survey or promotion.

 

COOKIES

We may set and access cookies on your computer or mobile device. Our cookies will not store any personal information about you. We use cookies only to identify you as a User.

 

ACCOUNT INFORMATION

We reserve the right to send you certain communications relating to our Services, such as service announcements, administrative messages and service notifications that are considered part of your account with Liquid, without offering you the opportunity to opt-out of receiving them.

You may close your User Account at any time by e-mailing support@liquidgroup.sg and requesting that we close your account. You will not be able to recover, reverse, cancel or ask for any refund of any transaction that is in process once your User Account has been closed. To the extent permitted by law, we reserve the right to use any personal information that may have been collected during your visits to www.liquidgroup.sg or through your use of the Changi Pay even after your account has been permanently closed for aggregated reporting and analysis purposes, or for such other purposes as may be permitted by you or by law.

 

DATA STORAGE

We may store and process your personal information using third party servers located in secure data centers in Singapore or elsewhere or in the cloud. This information is protected by physical, electronic and procedural safeguards in compliance with applicable regulations. We also use computer safeguards such as firewalls and data encryption. We authorize access to personal information only for those employees who require it to fulfill their job responsibilities.

We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing your User Account password with anyone and ensuring that access to your mobile device is password/pin/biometrics-protected.

 

CHANGES TO THIS POLICY

We reserve the right to revise, supplement or update this Policy from time to time by posting the revised version on the Changi Pay or such other method of notification as may be prescribed by Liquid to ensure that it is consistent with any industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on our website www.liquidgroup.sg or the Changi Pay.

 

QUESTIONS

If you have questions or suggestions about the collection, use and/or disclosure of your personal information or this Policy or would like to receive information about the personal information we have in relation to you, to update such personal information or to withdraw any consent you have provided to us previously, please contact us at support@liquidgroup.sg.