1. Introduction
This Privacy Policy (“Policy”) sets out the basis which Landmark Commerce may collect, use, disclose or otherwise process personal data of users in accordance with the Personal Data Protection Act (“PDPA”). This Policy is applicable to personal data in our possession or under our control, including personal data in the possession of third-party organizations which we have engaged to collect, use, disclose or process personal data for our purposes. We may update this Policy from time to time as needed, to ensure its consistency with our business operations, industry trends and regulatory requirements.
For avoidance of doubt, personal data refers to the personal data of an individual users, an individual appointed to act on behalf of a user, an individual connected party of a user or an individual beneficial owner of a user.
2. Consent
By using our services, submitting information to us and registering for an account, you also confirm that you have read this Policy and consent to our collection, use, disclosure and retention of your personal data as described in this Policy and in our Terms and Conditions.
3. How Landmark Collects Your Personal Data
The PDPA defines personal data as “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 the organization has or is likely to have access”.
We collect personal data from you and the devices you use to access our services. You must ensure that all submitted personal data is complete, accurate and true.
4. Types of Personal Data We Collect
The types of personal data we collect about you may include the following:
a) Information collected automatically
We collect information with regards to your interaction with our website and services, advertising, mobile notifications or e-mail communications. This is typically data we receive from your computer or other devices and includes:
device ID or unique identifier, device type, unique device token;
statistics on page views, traffic to and from the sites, referral URL, IP address and web log information; and
b) Information you provide to us when using our services
Such types of information include:
identity-related information required when you register an account, including your full name, date of birth, nationality, residential address, email address, telephone and/or mobile phone number, business seller information, and identity-related information of the directors and executive officers of your corporate body authorized to operate your account;
unique identification number (e.g. NRIC or passport number), as required under applicable law;
financial information such as your bank account information
transactional information based on your activities conducted on our website
any other additional information that we may ask you to provide in order to verify your account or listings.
5. How We Use Your Personal Data
We collect personal data for our core business purposes, and we may use the personal data we have collected about you for one or more of the following purposes:
verifying your identity, including during account creation, password reset process and other actions that require identity verification;
verifying your eligibility to register as a user of the account (including detection and verification of any anti-money laundering, counter-terrorist financing or other unlawful activities) or to legally use any of the features and functions of the account;
providing you with an account and related customer services
managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing and/or remediating fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of our platform and website;
any other legitimate business purposes, such as protecting you and other users with an account from losses, maintaining the security or our systems and services, and protecting any of our other rights and/or properties.
For avoidance of doubt, Landmark may, whether directly or through a third party, collect, use and disclose personal data of an individual without the respective individual’s consent to comply with the requirements of Monetary Authority of Singapore Notice PSN01 – Prevention of Money Laundering and Countering the Financing of Terrorism – Specified Payment Services.
6. To Whom We Disclose Your Personal Data
We may from time to time disclose your personal data to any personnel of our group or to third parties, whether located in Singapore or elsewhere. We may disclose your personal data to:
third-party service providers who provide operational or other services to us; the services they provide to us may include, where approved by applicable laws and regulations, fraud prevention, remittance, currency exchange, data entry, database management, or any other services in connection with Landmark’s business operations;
any other person or entity (including its associated companies or affiliates, employees, directors and officers) who had established or proposes to establish any business relationship with Landmark
law enforcement agencies, government and regulatory authorities or any other organizations to which we are under an obligation to make disclosures under the requirements of any applicable law, regulation or commercial arrangement and
any other party to whom you authorize us to disclose your personal data.
It should be noted that we may transfer, store, process and/or deal with your personal data outside Singapore, but we will ensure that your personal data will be provided a similar standard of protection with applicable laws and regulations, including but not limited to the PDPA.
7. How We Manage Your Personal Data
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. If you wish to withdraw consent, you should give us reasonable advance notice. Your request for withdrawal of consent can take the form of an email or letter to us at the contact details provided below in Section 12 below.
8. How You Can Access and Make Correction to Your Personal Data
You may write in to us, based on reasonable grounds, to: (i) find out what personal data we hold about you; (ii) find out how we have been using or disclosing your personal data within the last year; and (iii) correct an error or omission in your personal data that is in our possession or under our control. We may need to verify your identity before we accede to your request.
For avoidance of doubt, “you” refers to an individual customer, an individual appointed to act on behalf of a customer, an individual connected party of a customer or an individual beneficial owner of a customer.
9. How We Ensure the Accuracy of Your Personal Data
We will take reasonable precautions and verification checks to ensure that the personal data we collect from you is accurate, complete and up-to-date. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. From time to time, we may do a verification exercise with you so as to allow you to update us on any changes to your personal data.
10. How We Protect Your Personal Data
We will take reasonable security arrangements to protect your personal data that is in our possession or control to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Third-parties engaged by us to process and maintain your personal data on our behalf will be bound by contractual information security arrangements we have with them to protect your personal data that is in their possession or control.
11. Cookies and Websites
Our website uses cookies. A cookie is a small text file placed on your computer or mobile device when you visit a website. Cookies collect information about users and their visits, such as their internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website. We use cookies and other technologies to facilitate your internet sessions, offer you products and/or services according to your preferred settings, track your use of our website and to compile statistics about activities carried out on our website.
12. How to Contact Us
If you have any query or feedback regarding this Policy, you may contact our Data Protection Officer at:
Data Protection Officer
10 Collyer Quay, Ocean Financial Centre, Level 37, Singapore 049315
Contact Number: +65 68086227
Email Address: sg_gc@kvbgc.com
13. Governing Law
This Policy is governed by the laws of the Republic of Singapore. You agree to submit to the exclusive jurisdiction of the courts of the Republic of Singapore in any dispute relating to this Policy.
