The purpose of this document ("Privacy Policy") is to inform you of how Green Link Digital Bank Pte. Ltd. ("GLDB") manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act 2012 ("the Act"). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use, process and disclose your Personal Data.

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to GLDB and its related corporations or affiliates (collectively, the "Companies"), as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "GLDB", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to GLDB in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

GLDB may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, 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 Privacy Policy as updated from time to time on our website [www.glbank.com]. Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data

In this Privacy Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access.    

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you. Such Personal Data may also include that of your shareholders, beneficial owners, directors, employees, guarantors and authorised representatives.

2. Collection of Personal Data

2.1

Generally, we collect Personal Data in the following ways:

a.

when you submit any form, including but not limited to application, declaration, proposal or referral forms;

b.

when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;

c.

when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;

d.

when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events hosted by us;

e.

when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;

f.

when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;

g.

when you are contacted by, and respond to, our marketing representatives and agents and other service providers;

h.

when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;

i.

when you use our electronic services, or interact with us via our websites or use services on our websites;

j.

when we seek information about you and receive your Personal Data in connection with your relationship with us, including for banking products, insurance policies or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or

k.

when you submit your Personal Data to us for any other reason.

2.2

When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not, at our website, automatically collect Personal Data, including your email address unless you provide such information or log in with your account credentials.

2.3

If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, authorized representatives, directors, shareholders and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes. If any such third party withdraws the aforesaid consent, you agree to inform us in writing immediately. As a result of such withdrawal, GLDB may not be in a position to continue to provide our products or services to you.

2.4

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

3.

Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1

Generally, GLDB collects, uses and discloses your Personal Data for the following purposes:

a.

developing and providing banking facilities, products or services (whether made available by us or through us), including but not limited to: (i) executing investments, banking, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions; (ii) carrying out research, planning and statistical analysis; or (iii) analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customisation strategies;

b.

assessing and processing applications, instructions or requests from you;

c.

communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions;

d.

responding to, processing, investigating and handling your complaints, claims, disputes, queries, requests, feedback and suggestions;

e.

verifying your identity;

f.

managing the administrative and business operations of the Companies and complying with internal policies and procedures;

g.

facilitating any actual or proposed transactions (which may extend to any business transfers, restructuring, mergers, acquisitions or asset sales) involving any of the Companies;

h.

matching any Personal Data held which relates to you for any of the purposes listed herein;

i.

requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;

j.

preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks;

k.

managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

l.

project management;

m.

providing media announcements and responses;

n.

organising promotional events, administering benefits or entitlements in connection with our banking relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. We may also recommend you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible;

o.

in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice;

p.

in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

q.

managing and preparing reports on incidents and accidents;

r.

complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities; and/or

s.

any other purpose relating to any of the above.

The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you). These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

3.2

In addition, GLDB collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

a.

If you are a prospective customer:

i

evaluating your financial and banking needs and providing recommendations to you as to the type of products and services suited to your needs;

ii

assessing and processing any applications or requests made by you for products and services offered by GLDB; and/or

iii

any other purpose relating to any of the above.

b.

If you are a business banking customer, private investor, beneficial owner, guarantor, security provider or an appointed representative (including but not limited to a mandate holder or a power of attorney):

i

opening, maintaining or closing of accounts and our establishing or providing banking services to you;

ii

where account or relationship managers or agents have been assigned to service your account or portfolio, using your telephone number(s) to contact you from time to time in order to take your instructions, and/or provide you with information, updates, or recommendations and / or in accordance with the terms and conditions of our agreement with you;

iii

facilitating the continuation or termination of the banking relationship or the daily operation of the services and credit and trading facilities and providing client servicing (including but not limited to responding to individual requests by customers, mailing services, conveyancing services, reporting services, clearing services, reconciliation services and providing customer satisfaction);

iv

carrying out client reviews, for example, annual reviews of your portfolio

v

to establish your financial situation, risk profile, investment experience and investment objectives to help you consider the suitability of the products you have invested or intend to invest;

vi

providing electronic banking services (including but not limited to Internet Banking, Mobile Banking and Phone Banking);

vii

facilitating the transfer of funds within GLDB banking accounts or from GLDB accounts to external banking accounts and vice versa;

viii

ensuring the ongoing credit worthiness of customers;

ix

administering exceptional approvals, fee adjustments or waivers;

x

managing investment products (which include treasury products and foreign exchange, which GLDB may make available from time to time), and providing custody services;

xi

providing offers and promotions in relation to co-branded products and services which you have applied for;

xii

customer outreach and relationship management;

xiii

meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence);

xiv

archival management (including but not limited to warehouse storage and retrievals);

xv

administering credit, debit, and other cards (including but not limited to processing card applications, transactions and credit limit approvals);

xvi

providing loans and overdraft facilities (including but not limited to the evaluation of credit risks and enforcement of repayment obligations);

xix

administering fund services (including but not limited to the maintenance, management and operation of the services, and communication with investors);

xviii

administering and facilitating any offer of or other transactions dealing with securities, derivatives or other instruments or investments, and the execution of such transactions on a trading system or platform; and/or

xix

any other purpose relating to any of the above.

c.

If you are an employee, business partner, sole proprietor, investor , proxy voter, corporate shareholder, guardian, director, nominee director or guarantor, agent or representative of an organisation that is a business banking customer or otherwise has a corporate relationship with GLDB:

i

opening or continuation of accounts and establishing or providing banking services;

ii

facilitating the daily operation of the services, and credit and trading facilities (including but not limited to providing loans, gathering deposits, transferring funds, processing trades, reporting and/or clearing of trades, updating contact details of investors and investees, corporate action processing and entering into ancillary arrangements relating thereto);

iii

facilitating the continuation or termination of the banking relationship (including but not limited to the closing of accounts);

iv

managing investment banking (including but not limited to capital markets, corporate finance services and financing by mezzanine capital services);

v

managing investment products (which includes treasury products and foreign exchange, which GLDB may make available from time to time), and providing custody services;

vi

networking to maintain customer relationship;

vii

providing client servicing (including but not limited to providing customer satisfaction, proxy voting and merchant servicing);

viii

facilitating and carrying out due diligence checks;

ix

administering fund services (including but not limited to the maintenance, management and operation of the services, and communication with investors);

x

complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, or customer due diligence);

xi

processing commission remuneration for sales representatives;

xii

administering corporate / business credit, debit, and other cards (including but not limited to processing card applications, transactions and credit limit approvals);

xiii

providing loans and overdraft facilities (including but not limited to the evaluation of credit risks and enforcement of repayment obligations);

xiv

administering and facilitating any offer of or other transactions dealing with securities, derivatives or other instruments or investments, and the execution of such transactions on a trading system or platform; and/or

xv

any other purpose relating to any of the above.

3.3

In addition, GLDB may also collect, use and disclose your Personal Data for the following purposes:

a.

providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;

b.

matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by GLDB or other third parties;

c.

administering contests and competitions, and personalising your experience at GLDB's touchpoints;

d.

sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or

e.

conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.

3.4

If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, GLDB may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).

3.5

In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1

GLDB will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

a.

GLDB's related corporations;

b.

counterparties and their respective banks in relation to fund transfers, payments, drawing of cheques, and other transactions;

c.

third party recipients of bank reference letters;

d.

companies providing services relating to insurance and/or reinsurance to GLDB;

e.

agents, contractors or third party service providers who provide operational services to GLDB, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to GLDB;

f.

vendors or other third party service providers in connection with promotions and services offered by GLDB;

g.

credit reporting agencies;

h.

any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any business transfers, restructuring, mergers, acquisitions or asset sales) involving any of the Companies;

i.

external banks, credit card companies and their respective service providers;

j.

third party referrers;

k.

our co-brand and other business partners;

l.

our professional advisers such as our auditors and lawyers;

m.

relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority, and the Insolvency and Public Trustee Office, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them, as well as to comply with listing and other requirements or directions of Singapore Exchange Limited and/or any other relevant securities exchange;

n.

surveyors, auctioneers, valuers or other third parties in relation to loans and other credit facilities such as mortgages;

o.

brokerage houses, Central Depository (Pte) Limited, fund houses, registrars, custodians, nominee banks, external banks and investment vehicles in relation to asset management and investment product settlement processing;

p.

Credit Counselling Singapore, and collection and repossession agencies in relation to the enforcement of repayment obligations for loans and other credit facilities;

q.

foreign embassies and foreign credit reporting agencies in relation to credit reviews and the enforcement of repayment obligations for loans and other credit facilities;

r.

external business and charity partners in relation to corporate promotional events;

s.

telecommunications companies, the National Trades Union Congress, Singapore Press Holdings, local town councils and any other billing entities in relation to processing the payment of bills;

t.

any swap repository, trade data repository, reporting agent, clearing house, centralised clearing party (including any clearing member of such clearing house or centralised clearing party), clearing broker, multilateral or other trading facility, system or platform or such other communication network or auction facility; and/or

u.

any other party to whom you authorise us to disclose your Personal Data to.

We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with applicable data protection and privacy laws.

5. Use of Cookies

5.1

When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

5.2

Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.

5.3

Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting(s) on your browser. However, you may not be able to enter certain part(s) of our website.

6. Data Security

6.1

GLDB will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.

6.2

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you use our electronic banking services (which includes Internet Banking, Mobile Banking and Phone Banking services), and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

6.3

If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

7. Third-Party Sites

7.1

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

8.

Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

8.1

You may request access or make corrections to your Personal Data held by GLDB. GLDB may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
If you:

a.

have any questions or feedback relating to your Personal Data or our Privacy Policy;

b.

would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or

c.

would like to obtain access and make corrections to your Personal Data records, you can approach us via the following channels:
Email us at CustomerSupport@glbank.com

8.2

You may also write to our Data Protection Officer as follows:
Data Protection Officer
Green Link Digital Bank
dpo@glbank.com

8.3

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. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, GLDB may not be in a position to continue to provide its products or services to you or administer any contractual relationship already in place. This may also result in the termination of any agreements you have with GLDB, and your being in breach of your contractual obligations or undertakings. GLDB's legal rights and remedies in such event are expressly reserved. Please note that withdrawing 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.

9. Governing Law

9.1

This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.