Last updated: 31/8/2021


Personal Data” has to meaning given to it in the Personal Data Protection Act 2012 of Singapore.

Process” and “Processed” has a meaning analogous to processing.

Processing” has the meaning given to it in the Personal Data Protection Act 2012 of Singapore.

Service Providers” means our third party suppliers, vendors, contractors and business partners, whether in Singapore or elsewhere and whether former, current or prospective.

Services” means our products, services, content, features, technologies or functions offered on websites, applications and services operated by us or our Service Providers.

We”, “we”, “our”, “us”, means ReferReach Pte. Ltd.  (Company Registration No. 202120729N), a company incorporated in Singapore, and its related corporations.

You”, “your” means the persons to whom this Privacy Policy applies.

2. Your Consent

2.1 This Privacy Policy applies to any individual’s personal data which is in our possession or under our control, and shall govern your use of the Services. This Privacy Policy is in addition to the other terms and conditions which may apply in respect of your use of such Services.

2.2 You are deemed to have accepted this Privacy Policy when you provide us with personal data or otherwise sign up for, access or use any of our Services.

2.3 Notwithstanding the foregoing, you may withdraw your consent for us to collect, use or disclose your personal data, but this may affect our ability to provide you with the Services.  We will not be liable for any failure to provide any Services if such failure is due to your consent hereunder being withdrawn or your personal data being erased at your request.


3.1 Data Collected.  We may from time to time collect your personal data in order to provide you with the Services and also to improve your experience.  Such personal data may include:

3.1.1 general identification and contact information (for example, name, address, email address, telephone number, age, date of birth, gender, occupation, username, password, etc);

3.1.2 financial information and account details (for example, wallet addresses, bank account numbers, credit card numbers, assets, liabilities, salary, etc);

3.1.3 information from cookies, pixel tags, web beacons or similar technologies;

3.1.4 images, photographs, closed-circuit television (CCTV) footage, voice recordings and electronic communications;

3.1.5 data about the pages you access, your Internet protocol address, your device unique identifier, your device type, your geo-location information, your mobile network information, referral URL, statistics on page views, other information automatically sent to us by your device or your service provider;

3.1.6 where necessary for our business purpose, sensitive personal data such as your health information, racial or ethnic origins, religious or philosophical beliefs, trade union membership or biometric data; and

3.1.7 other information you may provide us with.

3.2 Collection Methods.  Your personal data may be collected:

3.2.1 automatically (for example, when your device or service provider automatically sends us that data);

3.2.2 from you (for example, when you submit a web form to us, add or update your account information, participate in discussions, chats or dispute resolutions, or correspond with us); and

3.2.3 from third parties (for example, from social media sites).


4.1 Core Business Purpose.  We may collect, use or process personal data for one or more of the following business purposes:

4.1.1 to provide you with the Services; measure the performance of our Services; monitor the Services provided by or made available through us;

4.1.2 process payments made or received by you;

4.1.3 determine your geographic location, provide localized or targeted content, provide you with customized or personalized recommendations or content, determine your Internet service provider, respond to any inquiries, requests, queries or feedback; optimize our selection and recommendation algorithms and delivery;

4.1.4 communicate with you (such as by email, text messaging, online messaging, push notifications) to assist you with operational requests such as password reset requests;

4.1.5 verify your identity; conduct due diligence checks;

4.1.6 prevent, detect and investigate fraud or other potentially prohibited or illegal activities; to detect, prevent and remediate any violations of our policies or terms and conditions;

4.1.7 address or investigate any complaints, claims or disputes;

4.1.8 handle requests for data access or correction;

4.1.9 analyze and understand our users; improve our services (including our user interface experiences); participate in industry exercises and studies;

4.1.10 coach employees and Service Providers; monitor for quality assurance;

4.1.11 enforce any obligations owed to us;

4.1.12 seek professional advice, such as legal advice;

4.1.13 prepare and maintain financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;

4.1.14 enable any actual or proposed assignee, transferee, participant or sub-participant of our rights, business or obligations to evaluate any proposed transaction; negotiate a business transaction, including (but not limited to) any financing, merger, acquisition or liquidation;

4.1.15 manage our infrastructure and business operations (including information technology infrastructure) and complying with internal policies and procedures;

4.1.16 conduct due diligence enquiries and comply with enforcement of tax, sanctions or prevention or detection of money laundering, terrorism financing or other unlawful activities;

4.1.17 comply with all applicable laws, regulations, rules, directions, orders, instructions and requests from any authorities (whether local or foreign), including any regulatory, governmental, tax and law enforcement authorities or other authorities; and

4.1.18 any other purpose specifically provided for in any particulate product or service offered by us or permitted or required by law or the relevant authorities.

4.2 Marketing Purpose.  We may also collect, use or process your personal data to:

4.2.1 offer you our Services (such as special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible), via various modes of communication such as email, short message service (SMS) and push notifications; and

4.2.2 improve and personalize the Services, content and advertisements.

If you do not wish to receive marketing communications from us or to participate in our advertisement personalization program, please let us know.


5.1 We may from time to time disclose your personal data to any of our employees, personnel, our Service Providers or to third parties, whether located in Singapore or elsewhere, in order to carry out the purposes set out above. When we disclose your personal data to such persons, we will request that they also comply with this Privacy Policy.

5.2 We may transfer, store, process and/or deal with your personal data outside of Singapore, in compliance with applicable data protection or privacy laws.


6.1 Your personal data is retained for so long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.


7.1 You may request access, receive, port, restrict processing, seek rectification or make corrections to, or request erasure of your personal data held by us, but we may charge a fee for processing such requests.  All such requests will be processed in accordance with applicable law.

7.2 We will take commercially reasonable steps to verify your identity before granting access to, making any changes to or erasing your personal data at your request.

7.3 There may be circumstances whereby we are unable to provide access, such as where the information contains legal privilege.  If we determine that access should be restricted in any particular instance, we will explain why that determination was made.

7.4 If you believe that any personal data we have of you is inaccurate, out of date, incomplete, irrelevant or misleading, please let us know.  We will endeavour to respond within a reasonable time and, where necessary, promptly correct any personal data found to be inaccurate, incomplete or out of date.


8.1 We will take necessary steps to protect your personal data.  However, no data transmission or storage of personal data can be guaranteed to be 100% secure.  As such, we cannot ensure or warrant the security of any personal data that you transmit to us and you do so at your own risk.


9.1 When you access or use our Services, we may store some data on your device using technologies such as a cookie or other local storage provided by your browser or application (collectively, the “Cookies”).  Such data is stored on your device to enable us to (i) provide the Services; (ii) recognise, identify or authenticate you; (iii) customise our Services for you; (iv) provide advertising; (v) provide our measurements and reporting; and (vi) fulfil the other purposes set out above.

9.2 You are free to decline or block our Cookies (insofar as your browser or application permits), but this may interfere with the provision of our Services and you may not be able to use certain features or functions of our Services.  We will not be liable for any failure to provide any Services to you if such failure is due to our Cookies being declined or blocked.

9.3 We may also use other technologies (such as a pixel tag or web beacon) for the purposes set out above.


10.1 We use third party services to help us improve our products. Accordingly, traffic and user behaviour data relating to our Services may be shared. 


11.1 Our website may contain links or redirects to sites operated by third parties.  Such links or redirections are not an endorsement of these third party sites nor of the third parties operating them.  These third party sites may also have different data protection practices.  We have no control over and do not take responsibility for these third party sites.


12.1 We may from time to time amend the terms of this Privacy Policy by posting a revised version of this Privacy Policy on our website.  The revised version shall take effect from the published effective date and notification will be made through our website or via email.  If you continue to use our Services after the notice period, you will be deemed to have consented to the amendments made in such revised version