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Doo Financial: Privacy Policy

1.

Introduction

1.1

This Privacy Policy sets out the regulations and policies of Personal Data processed by Doo

Financial Holding Pte. Ltd. (“Doo Financial”, “we” or “us”) in accordance with the Personal Data

Protection Act 2012 of Singapore.

1.3

Doo Technology Singapore Pte. Ltd. acts as the provider and manager of information

technology services, including but not limited to the management of application infrastructure,

system maintenance, as well as the entity responsible for the registration and distribution of the

application through the Google Play Store and Apple App Store.

1.4

By accessing Doo Financial’s Application, you undertake that you have read, understood and

accepted the terms of the Privacy Policy. Your usage or ongoing usage of Doo Financial’s

services shall also be taken as your consent to be legally bound by this Privacy Policy.

1.5

You acknowledge that Doo Financial reserves the right to amend or update this Privacy Policy

2.1

Throughout this Privacy Policy, unless the context otherwise requires, the following words and

expressions shall bear the following meanings:

(a)

“Doo Financial” means Doo Financial Holding Pte. Ltd. (Company Registration No.

201930035D) whose registered office is located at 18 Howard Road, #10-05 Novelty

Bizcentre, Singapore (369585).

(b)

“PDPA” means the Personal Data Protection Act 2012 of Singapore and its respective

published amendments.

(c)

“Personal Data” means “data, whether true or not, about an individual who can be

identified:

be ignored when construing the meaning of any provision of this Privacy Policy.

3.

Personal Data Collected

3.1

We collect your Personal Data from the following methods:

(a)

client on-boarding or application or other forms;

(b)

communication with Doo Financial via telephone, fax, email or other forms of electronic

communication;

(c)

Doo Financial’s associates or related companies;

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3.2

Personal Data collected by Doo Financial includes but not limited to the following:

(a)

your personal details, e.g. name, telephone number, email address;

(d)

information about your income and wealth including details about your assets and

liabilities, account balances, trading statements, tax and financial statements;

(e)

profession and employment details;

(g)

your use of products and services, including but not limited to the pages you have

visited; and

(h)

technical information, including but not limited to your devices, type and version of the

operating system, time zone.

you can disable Cookies and still access our Application normally.

4.

Purpose of Personal Data Collected

4.1

You consent and allow Doo Financial in processing the Personal Data:

(a)

to perform Doo Financial’s contractual obligations in providing products and services;

(b)

to comply with applicable laws, regulations and directions from regulatory authorities;

(c)

to verify your identity;

(d)

to update company information with Accounting And Corporate Regulatory Authority

verification of instructions;

(g)

to monitor and record calls for business analysis, training or service improvement

(j)

any other purposes that we notify you at the time of obtaining consent;

(k)

any other purposes incidental or relevant to the above

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5.1

Doo Financial may disclose your Personal Data to third parties:

(a)

under any requests and orders from regulatory authorities;

(b)

to meet our legal and regulatory obligations;

(c)

in compliance with any requests made by legal and regulatory authorities;

(d)

if it is necessary to perform Doo Financial’s contractual obligation, including but not

(a)

relevant regulatory authorities when we are required to do so;

(b)

your appointed auditors and professional advisors;

(c)

your appointed agents, representatives or advisers;

(d)

our third party service providers who are necessary to perform our contractual

obligations to you;

(e)

banks or other financial institutions;

(f)

our advisers or agents where it is necessary for us to obtain their advice;

our business;

(k)

other third parties who are necessary to perform our contractual obligations with you.

6.

Retention Period

6.1

Doo Financial shall retain your Personal Data in accordance with Section 25 of the PDPA. We

shall cease to retain your Personal Data as soon it is reasonable to assume that:

(a)

the purpose for which that personal data was collected is no longer being served by

retention of the personal data; and

7.2

Doo Financial train our employees and provide internal educational trainings to the employees

handling Personal Data to respect the confidentiality of customer information and the privacy

of individuals. Furthermore, Doo Financial implemented procedures to safeguard Personal

Data where employees are only given access to your Personal Data if it is necessary to perform

Doo Financial’s contractual obligation.

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and fraudulent acts committed by third party beyond Doo Financial’s control provided that Doo

Financial has taken all reasonable commercial standard of care and has not been negligent in

safeguarding your Personal Data.

8.

Client’s Right

8.1

Under the PDPA, you retain the right to:

(a)

access your Personal Data;

(e)

object against Personal Data processing for direct marketing purposes; or

(f)

demand Doo Financial to delete and erase your Personal Data.

8.2

You acknowledge that Doo Financial may need your Personal Data to fulfil its contractual

obligation with you, and as such your demand for deletion of your Personal Data may result in

termination of all products and services provided by Doo Financial.

9.

Jurisdiction