This Privacy Policy, as may be amended, modified or supplemented (this “Policy”) applies to all visitors accessing and/or using the UTU App and/or UTU Website (Users and Members, as defined in the UTU General Terms and Conditions governing UTU App and UTU Website, or “You”) is meant to help you understand how UTU Pte. Ltd. and its affiliates (“UTU” or “we”) collect, use, disclose, transfer and store information disclosed to us, so please take time to read it carefully. All capitalised terms used in this Policy shall have the same meaning as those ascribed under the UTU General Terms and Conditions Governing UTU App and UTU Website unless otherwise stated or defined herein.

INTRODUCTION

Thank you for choosing UTU. By accessing, signing up on and/or using the UTU App and/or UTU Website, you are accepting this Policy and consenting to the collection, use and/or disclosure of your information disclosed to us in the manner as explained in this Policy. If you do not agree with or accept any terms of this Policy, please do not access and/or use the UTU App and/or UTU Website.

INFORMATION COLLECTION, USE AND DISCLOSURE

The information we may collect includes (but is not limited to) the following:

Information you provide to us: We may collect and store information you disclose to us when you sign up on the UTU App and/or UTU Website and/or register as a UTU Member and/or access and/or use (whether as a UTU Member or not) the UTU App and/or UTU Website. We may ask you for your personal information, including but not limited to, your first name, last name, email address, mobile number, gender and date of birth at the point of signing up or registration. Once you have successfully registered with us as a UTU Member, you may not be anonymous to us. We may also collect and store information when you interact with us including, but not limited to, instances when you add or update your UTU Member Account details via the UTU App or through the UTU Website, when you participate in activities on the UTU App and/or UTU Website, when you add your credit / debit card details to your UTU Member Account, or when you correspond with us regarding the UTU App and/or UTU Website.

Information we collect automatically: When you use the UTU App and/or UTU Website, we may collect information sent to us by your computer, mobile phone or another access device. Such information includes, but is not limited to, details of your page visits or mobile application usage, your computer or mobile devices’ configuration such as (but not limited to) your IP address, location, your transactions executed within the UTU App, screens viewed within the UTU App, cookie information and the pages you requested.

Locational information: When accessing and/or using the UTU App and/or UTU Website, we may collect and store your locational information if permission has been explicitly granted to the UTU App and/or UTU Website by you, in order to verify transactions as well as to improve the user experience through localized content. The UTU App and/or UTU Website may use technologies available through the devices including but not limited to GPS, WiFi, IP address and cell towers to generate your location, unless you configure your operating system settings to prevent our collection of locational information.

Other information: By registering your information on the UTU App, participating in any promotions or surveys or by completing certain tasks or actions on the UTU App and/or UTU Website, you consent to sharing such information with UTU and the relevant Third Party Service Providers. We may share this information with our Third Party Service Providers (whether in Singapore or overseas) who have a need to have such information in order to provide the services on the UTU App. As part of the process before you undertake a transaction through the UTU App, you will be provided with a virtual card account number issued by UTU’s preferred partner. You consent that the information you provided when you registered your information on the UTU App will be shared with such issuing party. [The information shared with our Third Party Service Providers may be used only for the purposes of managing, administering and providing the services provided in the UTU App.] We will share your information, including personal information, locational information, friends list(s), and moments with certain social networking or other third party applications or services, if you choose to connect these to your UTU Member Account. Subject to compliance with privacy laws from time to time and without prejudice to the above, UTU may also use any information it obtains about your activity on the UTU App, or in connection with UTU’s Services, on an anonymised basis. Third Party Service Provider” means a party other than UTU and/or any of its related corporations which provides any function or service accessible through or on the UTU App and/or UTU Website;

Collection, use and/or disclosure of information: We may collect, use and/or disclose information for the following purposes (among others):-

• to help us further create, develop, operate, deliver, and improve the UTU App, UTU Website and/or New Services;
• to administer, manage and operate the Tax refund, to provide services through the UTU App, UTU Website and such other channels as may be available from time to time, and to provide customer service;
• to conduct marketing promotions;
• to help us to verify identity, protect UTU’s systems and customers, ensure the integrity and operation of UTU’s businesses and systems and for loss prevention and anti-fraud purposes;
• to send important notices, such as communications about purchases and changes to our terms, conditions, and policies;
• to offer you tailored content, such as giving you updates on special offers and reward schemes;
• for internal purposes such as auditing, data analysis, and research to improve the UTU App and/or UTU Website and customer communications;
• where collected from cookies and other technologies, like pixel tags, to improve your user experience and the quality and scope of our services;
• to comply with applicable laws, regulations and other requirements (e.g. providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies, cooperating with governmental requests, performing internal audits);
• to report any activity that we suspect violates any law or regulation to appropriate law enforcement agencies, regulatory authorities and other governmental agencies;
• to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against any legal claims; and/or
• to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of UTU’s General Terms and Conditions Governing UTU App and UTU Website, the terms of any Third Party Service Provider, any terms relating to any particular offer, promotion or task, or as otherwise required by law; and/or

We may process your personal information on a server located outside the country where you live.

We may, from time to time, use the services of Third Party Service Providers and other third parties in connection with the UTU App and/or UTU Website. As such, we may share your information with these persons who are working with us to perform functions and process user data on our behalf. Rest assured that such access to your personal information will only be to perform services on our behalf and such third parties are obligated contractually to us not to disclose it or use it for any other purposes. In connection with the foregoing, some of these third parties, such as analytics providers, may collect information about your online activities over time and across different websites or online services when you use our services. We are not responsible for the actions or compliance of third parties, nor are we responsible for any additional information you provide directly to any third parties.

UTU does not distribute or sell personal information of UTU Members to any third party unaffiliated with UTU or who are not a Third Party Service Provider, except when we have such UTU Members’ permission.

In the event of a potential, proposed or actual sale or disposal of business or interest, merger, acquisition, reorganization or funding exercise relating to UTU (including negotiations thereof) or any other situation where personal information may be disclosed or transferred as one of our business assets, UTU will notify you before personal information about you is transferred and becomes subject to a different privacy policy.

We may make user information available on an aggregated level to the Third Party Service Providers in the form of reports. Information contained in such reports will not contain personally identifiable information of the UTU Members. However, you agree that by opting to participate in the activities, surveys or promotions on the UTU App and/or UTU Website from time to time, you consent to UTU sharing all information (including any personally identifiable information) that we collect from you with the relevant Third Party Service Providers.

Where you disclose personal data of other individuals to us, you warrant that such individuals have consented to us collecting, using or disclosing such personal data for the relevant purpose for which you made the disclosure or as was notified to you at the relevant time and/or the other purposes as described in this Policy.

COOKIES

UTU may set and access UTU cookies on your computer or mobile device. UTU cookies will not store any personal information about you. We use cookies only to identify you as a user and UTU Member.

ACCOUNT INFORMATION

You may change your notification options at any time by contacting UTU or the in-app settings of the UTU App. You have control over what notifications you want us to send you.

We reserve the right to send you certain communications relating to the UTU App and/or UTU Website, such as service announcements, administrative messages and service notifications that are considered part of your account with UTU, without offering you the opportunity to opt-out of receiving them.

You may close your account on the UTU App directly by cancelling your account on the UTU App.

We will be retaining the your profile and your account details in the event of such cancellation for 90days in order to validate transactions and provide cashback for any pending Tax-free transaction.

SECURITY

As privacy of your personal information is important to us, we will make every effort to protect it including:-

• encrypting personal information through HTTPS; and
• restricting access to personal information to only employees that require the information to process it.

All your credit/debit card information provided to us is encrypted and tokenised upon successful verification and acceptance of your credit/debit cards on the UTU App. Tokenisation is the process of replacing sensitive data with unique identification symbols that retain all the essential information about the data without compromising its security. Thereafter, we will only use tokenised information to identify your registered credit/debit cards on the UTU App. Tokenisation is generally not reversible by third parties.

POLICY AMENDMENTS

UTU reserves the right to revise, supplement or update this Policy from time to time by posting the revised version on the UTU App and/or UTU Website or such other method of notification as may be prescribed by UTU from time to time, which you agree shall be sufficient notice for the purpose of this clause. Such revised version shall automatically be effective upon its posting on the UTU App and/or UTU Website and we will notify you about any significant changes in the way we treat personal information by sending a notice to the email address specified in your Registration Details or by placing a prominent notice the UTU App and/or UTU Website. By continuing to access and/or use the UTU Website and/or UTU App after being notified of such amendments, you are agreeing to be bound by this Policy (including the amendments thereof) and your use and/or access shall constitute an affirmative acknowledgement by you of this Policy (including the amendments thereof) and agreement by you to abide and be bound by this Policy (including the amendments thereof). If you do not agree to be bound by the amendments, you shall immediately cease all access and/or use of the UTU App and/or UTU Website.

QUESTIONS AND SUGGESTIONS

If you have questions or suggestions about the collection, use and/or disclosure of your personal information or this Policy or would like to receive information about the personal information we have in relation to you, to update such personal information or to withdraw any consent you have provided to us previously, please contact us at the following contact details:

Data Privacy Officer

UTU POINTS PTE. LTD.

Email:  inquiry@UTU.global |  Phone: 65 6817 4252