Compliance

Upstart Alliance Pte. Ltd. (“Upstart Alliance”, “we”) is committed to the highest standards of privacy and data protection compliance. Upstart Alliance is bound by the Personal Data Protection Act 2012 of Singapore (“PDPA”) and the regulations enacted under it (as may be amended from time to time). We act in accordance with the PDPA and this Privacy Policy.

This Privacy Policy sets out how and why we collect, store, use, transfer and disclose your personal information and how you may access your personal information and correct it. This Privacy Policy also explains the use of cookies on our website.

For the purposes of the PDPA the relevant legal entity is Upstart Alliance Pte. Ltd. and our nominated Data Protection Officer is Tim Coxall who can be reached at tim@upstartalliance.com.

Collection of General Information

Like most website operators, Upstart Alliance collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. We collect non-personally identifying information to better understand how our visitors use our website. The information collected will also help us troubleshoot problems, analyze our resources and improve our services and products. There is nothing in that kind of information that could enable anyone to identify who you are.

Upstart Alliance also collects potentially personal information like Internet Protocol (IP) addresses for logged-in users. Upstart Alliance only discloses logged in user IP addresses under the same circumstances that it uses and discloses personal information as described below in this Privacy Policy.

Collection of Personal Information

We collect personal information in a number of ways, including:

  • when you visit and interact with our website and related software (including any mobile applications);
  • when you sign up for a client account;
  • when you sign up for our newsletter;
  • when you engage in transactions with Upstart Alliance;
  • through cookies and other technologies that allow us to give you a better experience on our website; and
  • when you or a third party contacts us independently of our website, such as by email, phone or in person.

In each case, Upstart Alliance collects such personal information only insofar as is necessary or appropriate to fulfil the purpose of your interaction with Upstart Alliance. Upstart Alliance does not disclose personal information other than as described below in this Privacy Policy.

You may refuse to supply personal information, however this may prevent you from engaging in certain website-related activities and we may not be able to provide our services, products or assistance to you or on your behalf.

You must not provide us with any personal information about another person unless you have first obtained that person’s prior consent to do so and you have told them their personal information will be handled in accordance with this Privacy Policy (including where to find it).

Consent

This Privacy Policy applies to the website you are currently viewing. By visiting our website, using any of our products or services or providing us with your personal information in any other way (or authorising it to be provided to us by someone else), you agree to this Privacy Policy and consent to your personal information being collected, used and disclosed as set out in this Privacy Policy. This Privacy Policy should be read in conjunction with our Website Terms of Use.

You consent to Upstart Alliance posting and using any photographs, content and/or personal information you might upload on our website or have otherwise provided consent to publish on our website, blog, in our marketing material or social media channels, which we may use in order to provide information on our products and services, the marketing of our products and services or for the purpose of our functions and/or activities.

Purpose

We collect your personal information to enable you to receive the benefit of our website and our products and services. Subject to this Privacy Policy, we may use your personal information for the following purposes:

  • to carry out our obligations and to provide you with agreed products and services;
  • to establish, maintain and administer your client account;
  • to notify you about (including changes to) our products and services;
  • to create or distribute promotional and/or marketing material that is relevant to you;
  • for quality assurance and training purposes;
  • to promote and market Upstart Alliance, our products and services and our websites (including any social media pages maintained or operated by us such as LinkedIn, Twitter, Facebook etc.); and
  • any other uses identified to you at the time of collecting your personal information or as reasonably contemplated by this Privacy Policy and our Website Terms of Use,
  • the “Purposes”.

Disclosure of Your Personal Information

Upstart Alliance may disclose your personal information to other entities or individuals for the Purposes including but not limited to:

  • our employees, trusted third parties and other people we work with to provide products and services to you;
  • third party service providers for the purpose of enabling them to provide a service such as (but not limited to) IT service providers, data storage, web-hosting and server providers, debt collectors, payment processing and insurers;
  • any third party partners or entities with whom Upstart Alliance has a commercial relationship;
  • any related entity of Upstart Alliance;
  • prospective sellers or buyers of our business or assets;
  • any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting or when Upstart Alliance believes in good faith that disclosure is reasonably necessary to protect the property or rights of Upstart Alliance, third parties or the public at large; or
  • other entities or individuals, provided you have given your consent.

Accessing Your Personal Information

You may review, edit, correct or delete any personal information you submit to us. On request, Upstart Alliance will, as soon as reasonably possible, provide you with:
personal data about you that is in our possession or under our control; and
information about the ways in which the personal data referred to in paragraph (a) has been or may have been used or disclosed by us during the year preceding the date of the request.

However, we reserve the right not to provide you with your personal data or other related information if providing it could reasonably be expected to:

  • threaten the safety or physical or mental health of another individual;
  • cause immediate or grave harm to your safety, physical or mental health;
  • reveal personal data about another individual;
  • reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity; or
  • be contrary to the national interest.

If you wish to access the personal information we hold about you, you should contact us and we will respond to your request within a reasonable period after the request is made. If we deny you access, we will provide our reason for doing so at the time of your request.
While we do not charge a fee for a request for accessing your personal information, we may charge a reasonable fee (which will be notified to you once you make a request) for time and cost in the following circumstances:
if an extended amount of time is required to collate and prepare material for you; and
if you wish to have your files photocopied for you.

Correcting and Updating Your Personal Information

Please contact us as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date so that we can update your file accordingly. We will process any requested changes as soon as practicable and send the corrected personal data to every other organisation to which the personal data was disclosed during the year preceding the date of the correction, unless that other organisation no longer needs the corrected personal data for any legal or business purpose or you otherwise agree that we do not need to resend the corrected information to any other organisation.

Care of Personal Data

We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, we also rely on you to advise us of any changes to your personal information.

Protection of Personal Data

Upstart Alliance takes reasonable steps to ensure that your personal information is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Our security arrangements include physical measures (such as locked filing cabinets), administrative measures (such as staff training and disaster recovery systems) and technical measures (including encryption technology and passwords).

Although we aim to create a safe, secure environment by trying to limit access to the website to legitimate users, we cannot guarantee that unauthorised parties will not gain access. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your personal information.

Please contact us immediately if you become aware of any unauthorised use of your account by anyone else or any other breach of security.

Retention of Personal Data

Upstart Alliance will cease to retain its documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the Purpose for which that personal data was collected is no longer being served by retention of the personal data, or retention is no longer necessary for legal or business purposes.

Transfer Outside Singapore

Upstart Alliance will not transfer any personal data to a country or territory outside Singapore except in accordance with the requirements prescribed under the PDPA to ensure that organisations provide a standard of protection to the personal data transferred that is comparable to the protection under the PDPA and this Privacy Policy.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Our website uses cookies to help Upstart Alliance identify you from other users, track your usage of Upstart Alliance’s website, and your website access preferences.

We may use the following cookies:

Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

If you do not wish to have cookies placed on your computer you should set your browsers to refuse cookies before using Upstart Alliance’s website, with the drawback that certain features of Upstart Alliance’s websites may not function properly without the aid of cookies.

Business Transfer

If Upstart Alliance, or substantially all of its assets, were acquired, or in the event that Upstart Alliance goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge and agree that if such transfers occur, that any acquirer of Upstart Alliance may continue to use your personal information as set forth in this Privacy Policy.

Use of Personal Information For Direct Marketing

From time to time we may use the personal information we collect from you to identify particular Upstart Alliance products or services that we believe may be of interest to you. We may then contact you to let you know about these products and services, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what’s going on with Upstart Alliance and our products and services.

Direct Marketing from Upstart Alliance generally takes the form of an electronic marketing email. Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or deemed consent. Every directly addressed marketing contact sent or made by Upstart Alliance will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Contact us to make a request.

Links to Third Party Websites

Our website may contain links to and from third party websites. If you click on such links, you do so at your own risk and subject to whatever privacy policy and/or website terms may govern the use of such websites. Upstart Alliance has no control over, and is not responsible, nor liable for, the content, privacy practices or website terms of such websites or any information you provide to them. You should read the privacy policy of these third parties to find out how they handle your personal information when you visit their websites.

Privacy Complaints

If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy please contact us. All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable.

Privacy Policy Changes

Upstart Alliance may change its Privacy Policy from time to time, and in Upstart Alliance’s sole discretion. Upstart Alliance encourages you to frequently check our website at www.upstartalliance.com for any changes to our Privacy Policy. Your continued use of our website, products and/or services, requesting our assistance or the provision of further personal information to us (directly or via an authorised person) after any change in this Privacy Policy will constitute your acceptance of such change.