Privacy Policy
This privacy policy (“Privacy Policy”) sets out how Ledger 23 uses and protects any information that you have provided in compliance with the Singapore Data Protection Act 2012. Ledger 23 is committed in ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our website and/or the Service, then you can be assured that it will only be used in accordance with this privacy statement. Ledger 23 may change this policy from time to time by updating this page.
If you have any questions about this Privacy Policy, please contact our DPO at contact@ledger23.com.
The data protection provisions in the PDPA (parts III to VI) generally do not apply to:
a. Any individual acting in a personal or domestic basis.
b. Any employee acting in the course of his or her employment with an organisation.
c. Any public agency or an organisation in the course of acting on behalf of a public agency in relation to the collection, use or disclosure of the personal data. You may wish to refer to the Personal Data Protection (Statutory Bodies) Notification 2013 for the list of specified public agencies.
d. Business contact information. This refers to an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his or her personal purposes.
This Privacy Policy also forms part of, and should be read in conjunction with, the terms and conditions governing the use of the website (the Terms of Use), available at Terms of Use, which is maintained and operated by Ledger 23. (referred to as "Ledger 23", "We", or "Us", as appropriate), any other agreement or document which refers to this Privacy Policy and your relationship with Infinitude Life and its related corporations or parties. Terms defined in the Terms of Use and Terms of Service have the same meaning in this Privacy Policy unless otherwise stated.
Ledger 23’s rights under this Privacy Policy shall be without prejudice to other rights of collection, use and disclosure available pursuant to any such terms and conditions or under the law and nothing herein is to be construed as limiting any of these other rights.
1. Purpose of Collection and use of Personal Data
1.1 From time to time, we may collect Personal Data from you in various ways, including, but not limited to, when you visit our website, register on our website, respond to a survey, fill out a form, and in connection with other activities, services, resources or features we make available on our website. All such personal information is collected only if you voluntarily submit such information to us. You may refuse to supply such personal information, save that it may prevent you from engaging in certain activities and/or receiving the Services from us.
1.2 Information we may collect include but not limited to, full name, NRIC copy, passport or other identification document copy, job title, contact information including email address, residential address and phone number, demographic information such as preferences and interests and other information relevant to customer surveys and/or offers, photo or video of yourself, signature and other personal information as required by the government agencies.
1.3 We may use the Personal Data provided by you for the following purposes (the Purposes):
a. to provide access to the Services and/or Third Party Software to you or to make available any other Services to you;
b. to evaluate any Service Agreement to be entered into between us and you and to perform Ledger 23’s obligations (if any) thereunder;
c. to conduct background checks;
d. to facilitate transactions through the Third Party Software or in connection with the Services;
e. to contact you to send you information about the Services or any other service(s) offered or provided by Infinitude Life, and to notify you about changes or updates to such services when necessary;
f. conducting checks with the Do Not Call Registry;
g. for the marketing, promoting or advertisement of products and services (including any co-branded products or services) which you may be interested in;
h. to detect, prevent and investigate fraud, crime, offences, money-laundering, counter-terrorist financing and bribery or other illegal activity where we believe it is reasonable and appropriate to do so;
i. to comply with any regulation, notice, judicial order or decree;
j. to investigate of any claim or dispute arising out of this Privacy Policy or in connection with you;
k. for our internal research and development purposes; and
l. for purposes reasonably related to the aforesaid.
1.4 We may retain Personal Data for so long as one or more of the Purposes for which it was collected remain valid, where required by regulation or law (national or international), or as required by its own record retention policies or own business purposes.
1.5 By submitting comments or feedback regarding the website, you consent to Ledger 23 using such comments or feedback in any manner, including without limitation, in any marketing or advertising materials.
2. Accuracy of Personal Data
2.1 Should you provide Ledger 23 with any Personal Data of any individual:
a. you represent and warrant to us that (i) each individual whose Personal Data has been provided to us, has been notified of the purposes for which data will be collected, processed, used or disclosed; and (ii) such individual’s consent for the collection, processing, use and disclosure of such Personal Data by Ledger 23 has been obtained and authorised by such individual.
b. you shall notify us immediately upon becoming aware of any withdrawal by any individual of your consent to the collection, processing, use and/or disclosure by Ledger 23 of your Personal Data provided to us. The withdrawal of such consent may affect the services which we are able to provide to you.
c. you shall ensure at all times that any information provided (including any Personal Data) to us is correct, accurate and complete, and that any consent given in relation to Personal Data shall, subject to all applicable laws and regulations, survive death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of any account in connection with the use of the Services.
3. Disclosure of information
3.1 By entering into any Service Agreement (or any other agreement or document with us to which this Privacy Policy is referred) or using any service provided by Ledger 23, you acknowledge, consent and agree that Ledger 23 may from time to time also disclose Personal Data to any of the following parties (whether inside or outside of Singapore):
a. any agent, contractor, consultant, advisor, auditor or third party service provider who provides certain functions and/or services related to the business of Ledger 23, which will have access and use of such information to the extent necessary to allow them to perform the services they provide to us;
b. any person or entity employed by or on behalf of Ledger 23 or is a part of or related to any group of companies which Ledger 23 forms part of or is affiliated to;
c. any actual or proposed assignee of Ledger 23 or transferee of Ledger 23’s rights in respect of all or any part of the assets or business of Ledger 23;
d. any corporate or institution with whom you have a commercial relationship with;
e. any person or entity to whom Ledger 23 is under an obligation or otherwise required to make disclosure pursuant to any applicable laws and regulations, including disclosure to courts, tribunals, supervisory authority and/or legal, regulatory, tax and government authorities and stock exchanges.
4. Access to and correction of information
4.1 You may access or make corrections to any of your Personal Data held by Ledger 23. To do so, please contact Ledger 23 at contact@ledger23.com. Ledger 23 reserves the right to charge such fees as it may, in its sole and absolute discretion, deem appropriate for the grant of such access and to correct any Personal Data.
4.2 You may withdraw your consent for the continued collection, use, disclosure, transfer and processing of their information at any time by contacting Ledger 23 at contact@ledger23.com. Withdrawal of consent may affect the services which Ledger 23 is able to provide to you. Notwithstanding any such request, Ledger 23 may be entitled to continue retaining your personal data in accordance with applicable laws and regulations.
5. Acknowledgements and Disclaimers
You acknowledge that any Personal Data that is transmitted to Ledger 23 at your own risk. You may contact Ledger 23 immediately if they become aware or have reason to believe there has been any unauthorised use of your Personal Data.
6. COOKIES
We may use cookies to distinguish you from any other users of the Services. Cookies are small data files stored in your electronic devices that recognises and identifies your device which allows us to remember you or other data about you for future use. The cookies placed by our website are readable only by us and cookies cannot access, read or modify any other data on an electronic device. For the avoidance of doubt, Ledger 23's cookies do not collect information that personally identifies you and Ledger 23 does not use cookies to obtain such information.
7. Definitions
7.1 Unless the context otherwise requires and, in addition, the following terms shall have the respective meaning corresponding to them:
“Terms of Service” means the terms and conditions in respect of the Services which are agreed or to be agreed by you.
“Terms of Use” means the terms and conditions in respect of the Website and Third Party Software which are accepted or to be accepted to by you.
“Personal Data” means data which enables an individual and/or organisation to be identified including, but not limited to:
a. information such as names, contact details, addresses, and other identification details of users who access the website or any of the Services;
b. device data such as the carrier operating system such as the device and connection type, unique device identifier (i.e. device’s IMEI number, MAC address of the device’s wireless network interface, or the mobile phone number used by the device (if applicable), mobile network information, IP address, mobile payment methods;
c. location information; or
d. information from third-party services.
7.2 Capitalised terms in this Privacy Policy have the meaning given to them in the Terms of Use and Terms of Service.
7.3 Unless a contrary indication appears, any reference in this Privacy Policy to:
a. the words includes and including shall mean, including without limitation;
b. a person includes any person, firm, company, corporation, government, state or agency of a state or any association, trust or partnership (whether or not having separate legal personality) or two or more of the foregoing;
c. a regulation includes any regulation, rule, official directive, request or guideline (whether or not having the force of law) of any governmental, intergovernmental or supranational body, agency, department or regulatory, self-regulatory or other authority or organisation;
d. a provision of law is a reference to that provision as amended or re-enacted;
e. the masculine gender shall include the feminine or neuter genders and vice versa;
f. a time of day is a reference to Singapore time; and
g. words importing the singular number include the plural number and vice versa.