Personal Data Protection Policy

1. Introduction

Best Licensed Moneylender Pte Ltd (referred to as “the Company”) is committed to upholding the principles and standards set forth in Singapore’s Personal Data Protection Act 2012 (PDPA). We understand the significance of the personal data entrusted to us by our customers, employees, and third parties. This Personal Data Protection Policy (“Privacy Policy”) outlines our commitment to responsibly managing and safeguarding personal data. 

2.Purpose

This policy governs the collection, use, and disclosure of personal data obtained from employees, customers, and third parties. It elucidates our procedures for gathering and managing individuals’ personal information, ensuring compliance with the stipulations of the Personal Data Protection Act 2012 of Singapore and its associated regulations (“PDPA”). 

3. Responsible

The Company has appointed a Data Protection Officer (DPO) who is responsible for updating and maintaining this Personal Data Protection Policy in accordance with evolving legal and technological landscapes, market trends, and regulatory requirements.

4. Scope

This policy encompasses all activities of Best Licensed Moneylender Pte Ltd concerning the handling of personal data obtained from employees, customers, and third parties.

5. Consent

Best Licensed Moneylender Pte Ltd will collect, use, or disclose personal data for legitimate business purposes and employment matters only with the explicit consent of the individual, unless such collection, use, or disclosure is authorized or required by law.

Consent is obtained through various channels such as application forms, loan contracts, or explicit customer declarations indicating consent to the Privacy Policy.

6. Collection of Personal Data

6.1 Personal Data Collected from Customers

6.1.1 Purpose and Scope

This policy serves to inform and assist our customers in comprehending how we gather, utilize, retain, dispose of, transfer, disclose, and/or process their personal data.

We solely collect personal data from customers to better understand their financial requirements and evaluate their loan applications, as mandated by law. Such personal data is obtained through various means including online application forms, face-to-face interviews, email, text message correspondence, or telephone discussions. Information collected from customers will only be utilized or disclosed for the purposes explicitly stated herein or as required by applicable laws.

Our collection, retention, processing, utilization, communication, and/or disclosure of personal data adhere strictly to the guidelines outlined in this policy. In instances where a party acts as an intermediary for a third-party individual or provides information about such individuals (e.g., friends, colleagues), the intermediary party confirms their authorization as a representative or agent of the third-party individual. They also ensure that all necessary consents for the collection, processing, use, and disclosure of personal data by us have been obtained from the concerned individual. If personal data is collected from a third party, the intermediary party commits to informing the individual about the contents of this policy by providing them with a copy.

The collected personal data is used for:

• Submission to Moneylenders Credit Bureau (MLCB): We may collect personal data for the purpose of submitting it to the Moneylenders Credit Bureau to produce credit reports.

• Submission to the Registry of Moneylenders: Personal data may be collected and submitted to the Registry of Moneylenders as required by law.

• Conducting Online Searches: We may conduct online searches via web portals such as “Singapore Commercial Credit Bureau Pte. Ltd” if necessary, to assist in our operations.

• Understanding Financial Needs: Personal data is used to understand our customer’s financial needs and to customize and deliver loan packages that are of interest to them.

• Assessing Loan Applications: Personal data is collected to assess loan applications and ensure compliance with Singapore laws.

• Operation and Legal Obligations: Personal data enables us to carry out our operations, fulfill legal obligations, and customize loan plans for our customers.

• Debt Recovery: In the event of debt recovery, personal data may be disclosed to engage law firms, third-party debt collection agencies, or approved debt collectors.

• Auditing and Accounting: We may disclose personal data for auditing and accounting purposes to third-party accountants or auditors.

Personal data is only used for the specified purposes and disclosed to authorized third parties as necessary.

6.1.2 Types of Personal Data Collected

The following personal data may be collected from customers:

• Full Name

• Personal Identification Number (NRIC, FIN, or Passport)

• Nationality

• Date of Birth

• Gender 

• Contact Information

• Marital Status

• Address

• Employment Information

• Photograph

• Emergency contact

6.2 Personal Data Collected from Employees

6.2.1 Purpose and Scope

Personal data collected from employees is used for employment-related purposes such as evaluation, management, and HR administration. This includes recruitment, performance assessment, and benefits administration.

6.2.2 Types of Personal Data Collected

Personal data collected from employees may include:

• Full Name

• NRIC/FIN/Passport Number

• Nationality

• Date of Birth

• Contact Information

• Address

• Email Address

• Employment History

• Bank Account Information

6.3 Personal Data Collected from Third Parties

6.3.1 Purpose and Scope

The Company may share your personal data with third parties to support its operations, in alignment with the purposes outlined to you, only when individual consent or deemed consent is obtained, or when mandated by law. Any third parties engaged by us will be contractually obligated to maintain confidentiality of the information.

Additionally, we may disclose your personal data to our affiliates, but only when it is essential to fulfill the purposes for which you provided the personal data, as communicated to you. These purposes may include:

• Debt collection

• Accounting procedures

• Employment matters

• Legal obligations

• Audit requirements

• Any other disclosures necessitated by law

7. Disclosure of Personal Data

7.1 Personal Data of Customers

7.1.1 Purpose and Scope

We adhere to strict policies regarding the disclosure of personal data to third parties. Our commitment is to safeguard customer information and only share it under specific circumstances as outlined below:

• Legal Obligations: Personal data may be disclosed when required by law.

• Consent: We will obtain consent from individuals before sharing their personal data with third parties unless deemed unnecessary or implied.

• Engagement with Third Parties: In certain cases, we may engage third parties to assist with activities such as debt recovery, accounting, and auditing. These parties are contractually bound to maintain confidentiality.

• Moneylenders Credit Bureau (MLCB): We may disclose personal data to the Moneylenders Credit Bureau (MLCB) to obtain credit reports as mandated by law. This information may also be accessible to other licensed moneylenders when they request a credit report.

When sharing personal data with third parties or the MLCB, we take the following measures:

• Data Accuracy: We ensure the accuracy of the data by verifying it against original documents or information extracted from reliable sources such as Singpass. Verification is conducted against the latest information available, up to three months prior.

• Communication Channels: Personal data is shared through secure communication channels such as email, post, or electronic submission to maintain confidentiality and integrity.

By adhering to these principles, we strive to uphold the privacy and security of our customers’ personal information while fulfilling legal obligations and necessary business functions.

7.1.2 Types of Personal Data Disclosure

Personal data disclosed may include:

• Full Name

• Personal Identification Number

• Date of Birth

• Nationality

• Address

• Contact Information

• Employment information

• Loan Details

7.2 Personal Data of Employees

7.2.1 Purpose and Scope

Personal data of employees is not disclosed to third parties except as required by law or for specific company activities such as training or HR functions.

7.2.2 Types of Personal Data Disclosure

Personal data disclosed may include:

• Full Name

• NRIC/FIN/Passport Number

• Address

• Contact Information

• Employment Details

8. Access to and Correction of Personal Data

Best Licensed Moneylender Pte Ltd facilitates requests for access to and correction of personal data in accordance with PDPA requirements. Customers, third parties, and employees may request access or correction via specified channels.

9. Withdrawal of Consent

Requests for withdrawal of consent are typically processed in 14 business days. Upon receipt of such requests, individuals are informed of the potential consequences of withdrawing consent. Best Licensed Moneylender Pte Ltd ceases data processing accordingly, unless compelled by legal obligations.

10. Accuracy of Personal Data

Best Licensed Moneylender Pte Ltd ensures the accuracy and currency of personal data collected by verifying against original documents or trusted sources (eg. Singpass) .

11. Security and Protection of Personal Data

The Company employs industry-standard measures to safeguard personal data against unauthorized access, use, or disclosure.

12. Retention of Personal Data

Under regulation and law, Best Licensed Moneylender Pte Ltd is required to retain information pertaining to loans, including customer personal data, for a minimum of 5 years following the termination of the loan. Subsequently, Best Licensed Moneylender Pte Ltd will discontinue the retention of personal data when it is deemed reasonable to assume that the purpose for its collection is no longer being served and when such retention is no longer necessary for legal or business purposes.

In the case of employee-related information, Best Licensed Moneylender Pte Ltd will retain it indefinitely for review and record-keeping purposes, ensuring compliance with relevant regulations and internal policies.

13. Privacy on Our Websites

This Policy applies to personal data collected via our websites. Cookies may be used for website functionality, and visitors have the option to decline cookies.

14. Notification

Best Licensed Moneylender Pte Ltd notifies stakeholders of policy changes in advance and publishes updates on the website. Notification channels may include email, text, or written notice.

15. Data Protection Officer

For inquiries or concerns regarding personal data, individuals may contact the Data Protection Officer at admin@bestlicensedmoneylender.com.sg.