1. This Privacy Policy explains the rights and responsibilities with respect to personal information disclosed to WealthUp. The capitalised words used in this Privacy Policy shall have the same meanings ascribed in the Website Terms and Conditions unless otherwise defined or required by the context of this Privacy Policy.

    

   Find A Wealth Manager Pte Ltd is committed to the protection of your privacy. We understand keeping your information secure and confidential is critical to earning and keeping your trust. We will not rent, sell or trade your personal information to anyone. This Privacy Policy Statement describes the specific policies and procedures we use to collect, utilize, and disclose and share with others user, consultation recipient, and/or client information provided to us through our marketing partners; the use of our web sites and applications; and other communications with third party agents and other authorized service providers.

   We refer to Find A Wealth Manager Pte Ltd, it’s website, application, and social media platforms collectively as “WealthUp” or “we” or “us”. We refer to those who visit our website and those who use our web and mobile applications collectively as “users”. Together with our Terms of Use, this Privacy & Security Statement governs your use of our services. Security and safety of our clients’ data and information is top priority. We explain here how we handle and protect your information. This was also constructed in accordance to the Laws of Singapore and the Personal Data Protection Act (collectively known as the PDPA).

   By using our website and other platforms, you consent to our use of your personal information in accordance with the terms of this policy.

1. There is an important distinction between what we call ‘personal details’ and simply other information that you provide us. Your ‘personal details’ is information that identifies you. In our case if you use us to search for a Professional Service Firm we ask for your Name, Email and Phone Number to search for a Professional Service Firm. We have to ask you for that so that we can a) tell you who your best-matches are, and b) communicate with you to refine your matches if needed, and c) introduce you to the chosen Professional Service Firms if you choose to pursue that. We are not responsible for the privacy policies, activities and any content provided by Professional Service Firms and their websites, and we would recommend that you read the privacy policies and terms on any external sites you use.

   The rest of your information is anonymised information which by itself is incapable of identifying you. However, we look at all the anonymised data that we collect to work out interesting trends that we think will be of use to our users or to the wealth professional industry. We may publish this analysis. All with the aim of providing useful information to help WealthUp work better – both that of the consumers but also the services offered by the professionals.

   To the extent that your ‘personal details’ are provided through this Website, then we undertake to keep your personal details secure and confidential as per our Website Terms and Conditions and in accordance with this Privacy Policy. More general data we may bulk together and analyse. ‘Personal details’ are never within this.

The law of Singapore applies to these terms and conditions and any disputes will be subject to the exclusive jurisdiction of the Singapore courts.

WEALTHUP AND ITS ASSOCIATED COMPANIES FULLY RESPECT YOUR RIGHT TO PRIVACY. IN ORDER FOR US TO CARRY OUT OUR SERVICES TO YOU IT WILL BE NECESSARY FOR US TO USE YOUR PERSONAL INFORMATION (“INFORMATION”). PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE CONTINUING WITH THIS WEBSITE. YOUR CONTINUED USE OF THIS WEBSITE AND/OR YOUR PROVISION OF YOUR PERSONAL DETAILS OR ANY DATA TO US THROUGH THIS WEBSITE OR ANY OTHER WEBSITES, SERVICES OR MOBILE APPLICATIONS OPERATED BY US SHALL CONSTITUTE YOUR AGREEMENT TO THE PRIVACY POLICY AND ANY CHANGES TO IT. AS WE MAY CHANGE OUR PRIVACY POLICY FROM TIME TO TIME, PLEASE CHECK THIS PAGE REGULARLY.

Your express consent will be sought when collecting your personal details. There will also be instances where your consent for the collection or use of your personal details will necessarily be implied from the circumstances by nature of the task or transaction, including your interaction with us or in the course of signing up for, or accepting, any of our products, services or activities you have requested.

We may collect, store and use the following kinds of personal information about you:

1. Information about your computer and about your visits to and use of this website;
2. Information that you provide to us when registering with our website;
3. Information that you provide when completing your profile on our website;
4. Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
5. Information that you provide to us when using the services on our website, or that is generated in the course of the use of those services;
6. Information relating to any contact you initiate on any product/ services or any other transactions that you enter into through our website or outside it;
7. Information that you post to WealthUp;
8. Information contained in or relating to any communications that you send to us or send through our website (including the communication content and personal data associated with the communication);
9. Information that you provide to us to access personal detail information on third party websites, such as financial institutions, as per the individual policies of each of these third party websites. This information is not limited to your personal details, but could also include security information; and
10. Information from or about the computer, mobile phone, or other devices you use the website, including when multiple users log in from the same device. This may include network and communication information, such as your IP address or mobile phone number, and other information about things like your internet service, operating system, location, the type (including identifiers) of the device or browser you use, or the pages you visit.

The personal information you submit to us through WealthUp will be used for the purposes specified in this policy or on the relevant pages of the website.

1. We may use your personal information to:
   1. personalise WealthUp for you;
   2. enable your use of the services available on WealthUp;
   3. supply to you services purchased through WealthUp;
   4. send you marketing commercial communications (if you have requested them, and you can at any time unsubscribe from marketing communications);
   5. send you email notifications that you have specifically requested;
   6. send your contact information to third parties you have requested to connect with;
   7. send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
   8. send you marketing communications relating to our business (or the businesses of carefully-selected third parties) which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
   9. provide licensed third party operators with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
   10. deal with enquiries and complaints made by or about you relating to our website;
   11. keep our website secure and prevent fraud;
   12. verify compliance with the terms and conditions governing the use of our website;
   13. publish your personal information on the website (if, and to the extent, you request us to do so).
2. Your privacy settings can be used to limit the publication of your information on our website, and can be adjusted using privacy controls on the website.
3. We will not, without your express consent, supply your personal information to any third party or other user for the purpose of their or any other third parties direct marketing.

1. We use the financial account statements and other financial data that you provide to us or authorise us to have access (collectively, your “Personal Financial Data”), in order to deliver the services provided by Find A Wealth Manager Pte Ltd. We will maintain such data as strictly confidential and will not sell, lease or distribute the same to any third party (other than certain trusted third party service providers involved in the operations of our business and performing services on our behalf, with restricted access to customer data and information, on a need-to-know basis only, and in compliance with this Privacy Statement) without your documented approval, unless we are required or requested to do so by law or any regulatory authority for the jurisdiction that we operate in. For the avoidance of doubt, Personal Financial Data for this purpose does not include information that is aggregated with similar data from other users to produce collective data on users of the services of Find A Wealth Manager Pte Ltd as described above in clause 2 and 3, or is otherwise no longer identifiable to any specific WealthUp user.

1. Except as set forth in this Privacy Policy Statement, we don’t share your Personal Information with anyone. We do not share your Personal Information for third party promotional use. We will not sell, rent or trade your Personal Information. We may share your Personal Information:
2. To conduct everyday business: If you have registered to use our services to aggregate your banking and other financial accounts, we will transmit your account credentials from the personal data vault on your device to those third party institutions where you hold accounts to gather and maintain your account balances, transactions and holdings used to provide our services. (Read more about our secure handling of your credentials);
3. We may share your Personal Information with our third party agents for everyday business purposes, i.e. to provide financial insights and advice and improving your user experience.
4. We may disclose your personal information:
   1. To the extent that we are required to do so by law;
   2. In connection with any ongoing or prospective legal proceedings;
   3. In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

We collect and utilize Other Information to optimize, secure and simplify your experience with us. Your Other Information is not disclosed or shared outside of Find A Wealth Manager Pte Ltd. This includes, but is not limited to:

1. Your Browser or Device: Certain information is collected by most browsers or applications, such as your “user agent string”, to help us determine your computing device type, operating system version and Internet browser type and version. We use this information to ensure that our web sites function properly and for security purposes.
2. Your Cookies: Cookies are pieces of information stored directly on the computing device you are using. Cookies we use do not contain or capture Personal Information. Cookies allow us to collect information such as your browser type, time spent on our web sites and which of our pages you visited. We use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience and to recognize authorized devices to secure your use of our services. We also gather statistical information about WealthUp usage in order to continually improve the design and functionality and to assist us with resolving technical support questions. Additionally, we use cookies on our web sites and the sites on which we advertise to track advertising performance and to collect aggregate data on web page viewing and mobile app usage. Cookies may be connected to third-party companies or websites. The privacy practices of the companies placing such cookies are governed by the privacy policies of such third-party companies or websites. Cookies are not used to collect or disseminate any Personal Information.
3. Your IP Address: Your IP Address is a number assigned to the device that you are using by your Internet Service Provider. An IP Address is identified and logged whenever you visit our web sites or applications, along with the page(s) that were visited. We use IP Addresses, individually and collectively, for purposes such as calculating usage levels, helping diagnose technical problems and supporting our web sites and applications. Additionally, we use your IP Address to assist in fraud detection and authentication to better protect your security.

To protect Personal Information from unauthorized access and use, we use security measures that comply with relevant laws and regulations. Beyond this Privacy & Security Statement, we provide additional security measures, such as:

1. Find A Wealth Manager Pte Ltd, through third-party database storage, FireBase, is powered using technologies and practices that many banks and other financial institutions use to protect customer information, such as SSL encryption for data in transit and AES encryption for sensitive data at rest.
2. We do not store your financial institution credentials in our systems or in our applications. These institution credentials are stored on the device you access WealthUp and the other services of Find A Wealth Manager Pte Ltd from, in an encrypted data vault named as Personal Data Vault(“PDV”). Our account aggregation service including the PDV is provided by an industry-leading third-party account aggregation service. That service employs comprehensive financial data security standards and is subject to ongoing multi-agency financial institution regulatory examinations.
3. We will delete your original Personal Financial Data within a reasonable time after the relevant financial information has been extracted and processed into our database for the purpose of generating reports.
4. We will retain your account information for as long as you use the services of Find A Wealth Manager Pte Ltd. If you decide to stop the service, we will delete all such data within a reasonable time after the termination of the service, subject to retention for purposes of complying with applicable laws, resolving disputes, enforcing the terms of our agreement with you and protecting Find A Wealth Manager Pte Ltd’s intellectual property rights.
5. Money Movement: While using WealthUp, you will be able to view financial account balances and transactions, as well as purchase and sell financial products. You can transfer money between accounts, authorize spending or move money from your financial accounts, but such transfers are done at your sole discretion. To the maximum extent permitted by law, Find A Wealth Manager Pte Ltd will not be liable to you for any loss (including loss of information, data, revenues, profits or savings) or damage resulting, directly or indirectly, from any use of, or reliance on WealthUp. You assume sole responsibility for results obtained from the use of WealthUp and the conclusions drawn from such use. You indemnify us against all costs, losses and damages arising from your breach of any of the Agreement and any other obligation you may have to Find A Wealth Manager Pte Ltd.
6. Account Monitoring: WealthUp allows you to monitor all your transactions for accounts linked to Find A Wealth Manager Pte Ltd, providing you with a comprehensive view of all account activities.
7. Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
8. Reviewing and Updating your Personally Identifiable Information: You can view and update the profile and account information we collect for you by going to the “settings” function in our website and in our app. The credibility and relevance of our services depend on your providing us with complete, accurate and up-to-date information about yourself and your accounts, both now and in the future.
9. Email Marketing Opt-out: When we communicate our own marketing offers to you, these communications are SPAM compliant, including the ability for you to opt-out of marketing communications.

1. We will take implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.
2. We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
3. You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
4. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of WealthUp, you are responsible for keeping this password confidential. We ask you to not share your password with anyone.

1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
3. We may notify you of changes to this policy by email or through the private messaging system on our website.

1. You may instruct us to provide you with any personal information we hold about you; we will provide such information subject to the supply of appropriate evidence of your identity.
2. We may withhold personal information that you request to the extent permitted by law.
3. You may instruct us at any time not to process your personal information for marketing purposes. You may also instruct us to amend or delete your personal information by getting in touch with us as provided in this policy. If you do so, we may no longer be able to provide services to you.

1. WealthUp and our website includes hyperlinks to, and details of, third party websites.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.

You may enquire about the personal details that WealthUp hold about you, namely the ways in which your personal data has been or may have been used or disclosed within a year before the request, by sending an email to [email protected]. WealthUp where required or authorised to do so by law, we reserve the right to charge a reasonable administrative fee for this service and/or deny your request for access to your Personal Data.

1. Updating Your Information
   1. The Settings feature in the WealthUp application and other services of Find A Wealth Manager Pte Ltd should allow you to edit or change any personal information.
   2. In case, you need any additional details to be changed, which you have not been able to access using Settings feature, please let us know if the personal information that we hold about you needs to be corrected or updated.
2. Contact Details
   1. This website and application is owned and operated by Find A Wealth Manager Pte Ltd.
   2. We are registered in Singapore under registration number 201225155C.
   3. Our principal place of business is at 24 RAFFLES PLACE #10-05 CLIFFORD CENTRE SINGAPORE 048621.
   4. You can contact us by writing to the business address given above, by using our website contact form, or by email to [email protected].
   5. You may also contact us on any of the social media platforms that is engaged in Find A Wealth Manager Pte Ltd, namely Facebook®, Instagram® and LinkedIn®.