Data Protection Notice for customers
This Data Protection Notice ("Notice") sets out the basis which Plover Tech Pte Ltd ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
Personal data
1. As used in this Notice:
- (a) "customer" means an individual who: (i) has contacted us through any means to find out more about any goods or services we provide; or (ii) may, or has, entered into a contract with us for the supply of any goods or services by us; and
- (b) "personal data" means data, whether true or not, about a customer who can be identified: (i) from that data; or (ii) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction(s) with us, some examples of personal data which we may collect from you include name, identification numbers such as NRIC no. and FIN no., work permit and birth certificate, residential address, email address, telephone number, gender, date of birth, marital status, financial information, credit card information, and technical information (including the Internet Protocol ("IP") address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and similar information). Where you elect to use our optional "Schedule of Assets" feature, we may also collect financial information and other personal data for the purpose of helping the executor of your will identify and locate your assets, including but not limited to the names of the institutions with which you hold bank accounts, investment accounts and insurance policies (and the type and nomination status of those policies); details of any properties you own (including address and ownership type); your loan arrangements; and contact details of your financial advisor(s).
Collection, use and disclosure of personal data
3. We generally do not collect your personal data unless:
- (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your "authorised representative") after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes; or
- (b) collection and use of personal data without consent is permitted or required under applicable laws.
4. We may collect and use your personal data for any or all of the following purposes:
- (a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- (b) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- (c) managing your relationship with us;
- (d) direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you), which we will obtain your specific consent for this purpose;
- (e) receiving from or transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- (f) where you elect to use our optional "Schedule of Assets" feature and provide your personal data to us for this purpose, to compile and generate a list or "Schedule" of your assets and information and details of your finances, which will be used to assist the executor of your will in identifying, locating and distributing your assets. For the avoidance of doubt, the Schedule of Assets does not form part of your will, is optional, and is not required to generate a valid will.
5. You agree we may disclose your personal data to:
- (a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Singapore Companies Act 1967;
- (b) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);
- (c) our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
- (d) the appointed executor for the purpose of estate administration;
- (e) persons under a duty of confidentiality to us;
- (f) persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
- (g) actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.
Withdrawing your consent
6. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
7. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. We will inform you if we require more time to process your withdrawal request.
8. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you as a result of such withdrawal of consent. In such circumstances, we shall notify you of the foregoing before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 6 above.
9. Please note that your withdrawal of consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
Access to and correction of personal data
10. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
11. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
12. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.
Protection of personal data
13. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks and the loss of any storage mediums or devices on which personal data is stored, we have introduced reasonable and appropriate administrative, physical and technical measures such as encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. We ensure that our employees, service providers and agents are subject to contractual confidentiality obligations. We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
14. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of personal data
15. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing at the contact details provided below.
Retention of personal data
16. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
17. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Transfers of personal data outside of Singapore
18. We may transfer your personal data to, and store such personal data in, countries outside Singapore. By providing your personal data to us, you agree to the transfer, storing and/or processing of your personal data outside Singapore. Where we transfer your personal data outside Singapore, we will do so in accordance with applicable laws and ensure that your personal data is provided a standard of protection comparable to Singapore's data protection laws.
Automated systems / processing and artificial intelligence
19. We may use automated systems, including Artificial Intelligence ("AI"), to process certain types of personal data to improve our business operational efficiency, enhance our services and turnaround time, and enhance our customer support service.
20. While these AI systems may assist in analysing data and providing recommendations, any final decisions that significantly affect you or your account will not be made solely by automated means without appropriate human oversight, unless permitted by applicable laws.
21. We respect your privacy. We do not use your personal data to train, develop, or test our own foundational AI models, nor do we share your personal data with any third-party AI providers for the purpose of training their models. Third-party AI tools are used strictly as service processors to assist us in delivering our services to you.
22. We use AI and automated tools to make our services more efficient and helpful (like using chatbots). We do not use your data to train AI models, we do not let third parties use your data to train their models, and important decisions about your account still involve human oversight.
Data Protection Officer
23. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO: Alvinraj Gill
Email Address: [email protected]
Registered Address: 175A Bencoolen Street, Singapore 189650
Effect of notice and changes to notice
24. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
25. We may revise this Notice from time to time without any prior notice to you by posting the updated policy on our Site. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Cookies
26. Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
27. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.
28. We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
29. We use the following cookies:
- (a) Strictly necessary cookies — These are cookies that are required for the operation of our Site.
- (b) Analytical/performance cookies — They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it.
- (c) Functionality cookies — These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences.
- (d) Targeting cookies — These cookies record your visit to our Site, the pages you have visited and the links you have followed.
30. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.
31. We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests.
Third-party sites
32. Our Site, our App and/or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have and are governed by their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices or policies of any third-party websites.
Governing law and jurisdiction
33. This Notice shall be governed by, and construed in accordance with, the laws of Singapore. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Notice, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the Courts of Singapore.
Effective date: 01 June 2020 — Last updated: 06 July 2026