Privacy Policy

Last updated: 16 October 2024

Independent Reserve SG PTE. LTD (“Independent Reserve”, “we”, “us” or “our” or us) works together with banks and financial institutions that are required by law to take steps to prevent fraud, money-laundering and terrorist-financing. Given the nature of our core business, we take the privacy and security of an individual’s personal information very seriously.

This Privacy Policy has been drafted solely in accordance with the laws of Singapore and the Personal Data Protection Act (PDPA). We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction. The PDPA governs the way in which we may collect, use and disclose personal data about any individual (you). This Privacy Policy sets out the manner in which we comply with our obligations under the PDPA.

Privacy & Personal Data Protection Policy

We are committed to protecting your personal information and your right to privacy.

If you have any queries or concerns about our policy or our conduct pertaining to your personal information, please contact us.

This Privacy Policy governs the privacy policies and practices of this website (“the Site”).

Please read our Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.

Personal Data Protection of your Personal Information

“Personal Information” shall mean personally identifiable information relating to yourself that Independent Reserve shall require from time to time in order to comply with its “Know Your Client/Client Due Diligence” policy and/or any relevant law, regulation, notice or guideline issued by any competent authority, relating to money laundering and the prevention of terrorist financing.

You expressly acknowledge, agree and understand that we shall retain your Personal Information on our electronic database and in respect of which, you expressly agree as follows:

• that the Personal Information may be made available to employees, representatives and/or any affiliates of Independent Reserve.
• that we, our employees, representatives, affiliates and/or subcontractors shall be entitled to use your Personal Information to enable us to conduct our due diligence measures on an ongoing basis as prescribed by prevailing Anti-Money Laundering and Terrorist Financing laws and regulations both within and outside Singapore, and that such Personal Information may be shared upon request by relevant regulatory, government and law enforcement agencies.
• that we, our employees, representatives, and/or affiliates shall be permitted to transfer and retain your Personal Information to our centralised electronic database and use it for the purposes as aforementioned, for so long as we shall provide the Services contemplated herein, and for 7 years thereafter, in accordance to relevant record retention requirements.

That we, our employees, representatives, and/or our affiliates shall, insofar as shall be necessary to enable the Personal Information to be utilised in accordance with the clause above, be released from any and all laws and regulations in Singapore, related to our legal and professional secrecy obligations in connection with such Personal Information, in so far as we, our employees, representatives and/or any of our affiliates protect your Personal Information in accordance to the same standards as that accorded under the Personal Data Protection Act 2012.

Data Protection

We understand and acknowledge that to the extent that performance of our obligations hereunder involves or necessitates the processing of your Personal Information we shall, and shall procure that our employees, representatives, affiliates and/or subcontractors, if any, shall act only on instructions or directions received from us (or, in the case of processing by our subcontractors, directions from us) and shall comply promptly with all such instructions or directions received from us from time to time and shall take and implement, and procure the taking and implementing by subcontractors of, such reasonable security procedures and measures as may be necessary or appropriate to preserve the security and confidentiality of such Personal Information processed and to protect such Personal Information against unauthorized or unlawful access, processing, accidental loss, destruction or damage. We may from time to time transfer Personal Information that we process under these terms of services outside Singapore for processing either by our affiliates, subcontractors and/or third parties, and you the user acknowledge that you are aware of such proposed data transfers in respect of all data processing activities by Independent Reserve and our employees, representatives, affiliates and/or subcontractors under the Personal Data Protection Act 2012.

We will notify you as soon as reasonably practicable upon becoming aware of any adverse event involving the use of your Personal Information, including but not limited to, events which may disrupt normal operations leading to potential prolonged service failure or disruption and breaches of confidentiality.

Collection, use and disclosure

We collect personal data from customers for identity verification purposes under anti-money laundering and fraud prevention laws and for establishing your account in accordance to your preferred usage, which may involve telegraphic transfers, SWIFT, FAST and PayNow.

We only use and disclose personal data collected in this manner insofar as necessary in order to provide our services to you, which may involve (amongst others) integration with identity verification and related services, establishing a payment gateway account for you, or as otherwise required by law, including compliance with the laws governing transfers of virtual assets to unhosted wallets and/or hosted wallets with third party Virtual Asset Service Providers.

There are also a few limited circumstances in which we may collect personal data directly from you. This is limited to circumstances where you make direct contact with us by telephone or in writing, or via our website at independentreserve.com/sg. We will only use personal data collected in this manner for the purpose of communicating with you (and/or your elected secondary users) or otherwise in accordance with the purpose for which you provided your personal data.

The personal data we collect

The type of personal data which we may collect from customers includes your name, current and previous addresses, date of birth, telephone number, National Registration Identity Card (NRIC) number, driver licence number, passport number and any other data which may be relevant for the purposes of accurately verifying your identity. We require our third party providers and corporate customers to comply with all relevant privacy and data protection laws (including, where necessary, obtaining the appropriate express or implied consent from you at the time your personal data is collected) in order for such information to be lawfully used for identity verification and related purposes.

We do not collect, use or disclose any sensitive data about any person beyond that which has been accorded for within this Privacy Policy. This includes a person’s racial or ethnic origin, political opinion, political association (except in so far as this constitutes you being deemed a Politically Exposed Person), religious belief or affiliation, philosophical belief, trade union or association, sexual preference or health information.

We do not use or adopt as our own identifier any individual identifier assigned by any other organisation.

Security

We take all reasonable steps (including the employment of appropriate security systems and procedures) to ensure all data held by us is safe and secure. Such security measures include physical protection and electronic encryption to prevent any unauthorised access.

Quality

We take all reasonable steps to ensure that any personal information that we collect and use is accurate, complete and up-to-date.

Access and correction

You have a right to access your personal information, subject to some exceptions allowed by law. If you wish to access your personal data, you should contact us via the Support screen. We reserve the right to charge a fee for searching for and providing access to your information.

Destruction

Where we determine, acting reasonably, that personal data held in respect of an individual is no longer needed for our functions or the services we provide, we will permanently destroy or de-identify that data, subject to prevailing record retention periods as prescribed under applicable regulatory requirements in Singapore.

Cookies

We collect anonymised data, through the use of "cookies". Cookies are small pieces of information which are sent to your browser and stored on your computer’s hard drive. We may use cookies to recognise you as a customer and user of Independent Reserve’s Service, to customise our services and advertising, and to collect information in order to alleviate the risk of fraud and illegal conduct.

We may also utilise cookies to assist in delivering targeted advertising campaigns at certain times through third party sites. Personally identifiable data is not captured by the cookies used for advertising.

How to opt-out

You may opt-out of receiving targeted advertising by visiting the NAI and AdChoices opt-out pages.

Amendments to the policy

We may update this Privacy Policy from time to time. Please check our website regularly for an up-to-date version of our Privacy Policy.