Date of Last Revision: 3 October 2023
MoneyHero Limited (“MoneyHero”) and its subsidiaries together form MoneyHero Group (collectively “MoneyHero Group”, "we", “us” or “our”), a group of companies that help serve the South-East Asia markets with access to tailored financial products, educational content and signup rewards.
Our corporate website (https://www.moneyherogroup.com) ("Website"), including the content, features, tools, data, software and functions made available by us through the Website, our mobile applications and any other websites or applications we operate (unless those websites or applications have posted separate or additional terms of service) (together, the “Services”) are owned by MoneyHero Group and have been created to provide information to our visitors and users (“you” and “your”) about our businesses.
- Money Hero (Hong Kong) - www.moneyhero.com.hk/en/privacy-policy
- SingSaver (Singapore) - www.singsaver.com.sg/page/singsaver-privacy-policy
- Money101 (Taiwan) - https://www.money101.com.tw/pages/money101隱私政策
- Moneymax (Philippines) - https://www.moneymax.ph/page/privacy-policy
- CompareHero (Malaysia)- https://www.comparehero.my/page/privacy-policy
- Seedly (Singapore) - https://seedly.sg/privacy/
- Creatory (Singapore; all markets) - https://creatory.hyphengroup.io/hubfs/Creatory/Documents/PrivacyPolicy/PrivacyPolicy.pdf
Collection of Information
We collect information about you in three main ways: when you provide it to us, with automatic technologies and when third party sources provide it to us.
Information We Collect
MoneyHero may receive Personal Data of individuals within our former, current and prospective clients, partners, vendors, consultants, investors, shareholders, service providers and any members of the general public who communicate with us or whose Personal Data we receive. While registering for an account and/or using our Services (for example, in order to get comparative quotes for personal loans), your Personal Data may be collected or provided by you to us in various ways.
The following are examples (without limitation) of the circumstances in which we collect Personal Data:
- When you subscribe to receive email alerts from us, we will ask for your email address
- When you contact us by email or telephone, we may ask for your name, email address and/or phone number, so that we can contact you regarding your enquiry
- When you contact us by email or telephone in respect of the provision of services to MoneyHero Group, we may ask for identification documents for onboarding, due diligence purposes and/or corporate administration purposes
- In connection with the performance of a contract, or in order to take steps before entering into that contract, or to comply with our legal obligations.
The information you provide to us may include (without limitation):
- postal address
- email address
- any messages if you write to us using our email address
- passport number, NRIC or other identity documents (where required for AML and/or KYC purposes)
- financial information and, in certain cases, background check information
- bank account information
- tax information
- company/investment vehicle details
- information related to any of the above
Most often, the provision of the above data is on a voluntary basis. However, if you do not provide sufficient information to us, we may not be able to process your request or engage with you further.
Automatic Collection of Computer Data
In addition, when you use the Services, we may automatically collect certain data about how you access and interact with our Services which may, when combined with other information about you, constitute Personal Data. Automated technologies, such as our use of ‘cookies’, web beacons and similar technologies help us achieve our goal of providing you with the best possible service. When you access our Services, our servers will record, or track information sent from the browsers. This can include the following information (without limitation):
- attributes of the equipment or device you are using, such as the operating system, hardware version, device settings, software and device identifiers
- device locations, including specific geographic locations identified through GPS signals or other means
- connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address
- the website from which you have reached the Services
- the Website pages viewed
- details of the products and services on the Services that you look at, information, tools and content available on our Services that you use
- time spent on the Services
- links from our Services that you click on
- information related to any of the above.
- provide you with a more personalized experience on our Services. It allows us to remember you when you revisit our Services. You can also access your previously saved quotes
- study browsing habits on the Services. The more we understand what products you are interested in, the greater our ability to offer you customized solutions and targeted advertisements and other marketing materials; and
- obtain information regarding the number of visitors to the Services and the pages viewed.
In most cases, cookies are deleted when you close your browser; these are referred to as session cookies. However, persistent cookies stay on your browsing device either until such time as you delete them, or they expire. By using the Services, you consent to us using cookies. Such use of data does not disclose any of your Personal Data, and we will not collect, process or use any of your Personal Data in this regard.
You can alter your computer browser settings to block or delete cookies. If you opt to block or delete cookies of the Services, you may not be able to access certain products or services and this could have an effect on the performance of the Services on your system (for example, banner ads may not display properly). If you have registered an account with us, you may be required to re-enter your password more frequently during your use of our Services if you choose to disable cookies.
Information Provided to us by Third-Party Sources
Finally, depending on your usage of the Services, we may also receive information about you from other third parties we have engaged such as compliance service providers, business associates, subcontractors, analytics providers, platform providers and/or search information providers.
MoneyHero may also receive Personal Data about you from other entities within the MoneyHero Group.
Accuracy and Retention of Personal Data
By providing us with your Personal Data, you warrant that such data is true and accurate, and undertake to notify us as soon as practicable of any change or alteration to the same. Any loss or damage caused to the Services or to the person responsible for the Services or to any third person through the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility. If for any reason you are concerned as to whether you are permitted to provide us with another person’s information, please contact us at the email address listed below before sending us anything.
We may retain customer and/or user Personal Data as reasonably necessary for us to provide or offer our services to you and/or your organization; as long as we consider necessary for to fulfil the purposes we collected it for (further detailed in the "What do we use your Information for?" section below), including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When we have no ongoing legitimate business need to process your Personal Data, we may either delete it, pseudonymise it or anonymize it.
What do we use your Information for?
We use the information we collect about you for our legitimate business interests to operate the Services, to conduct our business and to provide support to the business activities of entities within MoneyHero Group. Depending on the nature of your relationship with us, we may use your Personal Data for some or all of the following purposes:
- to answer your queries and to communicate with you, for example, providing you with updates, information, alerts and/or notifications about our business and/or performance
- to perform compliance related checks including KYC and sanctions screening through our trusted partner(s), in order to verify your identity and/or comply with our legal obligations
- to maintain accurate records and registers of our shareholders, owners and/or service providers
- to diagnose and prevent service, security or technical issues affecting the Services
- to monitor, detect and prevent fraud or abuse of the Services
- to protect the safety, integrity and/or rights of our users or any third party
- to comply with our legal and regulatory obligations; and
- to enable us to provide services related to the above and/or otherwise related to your use of the Services.
In some circumstances we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
How do we Disclose your Information?
We are committed to keeping your Personal Data and other information shared with us confidential. We do not sell Personal Data. There are, however, certain circumstances in which we may disclose or transfer your Personal Data to certain third parties without further notice to you, as set forth below:
- Related Companies: We may share your Personal Data with our subsidiary entities within MoneyHero Group that provide services to or share services with us.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of, or in preparation for, a change of control, merger, acquisition, restructuring, dissolution or similar event, we may disclose or transfer Personal Data to a third party.
- Agents, Consultants and Other Service Providers: We rely on service providers to help support our business and the Services, for example (without limitation) our third-party website hosting providers, data storage providers, IT service providers, back-office support, auditors, tax-advisors, business consultants, legal service providers, corporate administration providers, compliance service providers and other sub-processors. When we engage another entity to perform a function of this nature, we only provide them withthe information that they need to perform their specific function.
- Legal Requirements: We and/or any of the third parties listed above may also be required to disclose your Personal Data to any court, law enforcement body, government department, regulator or industry body of any country where required by the laws of Singapore or any other jurisdiction, or in response to a lawful request in Singapore or elsewhere. We may also need to disclose your Personal Data in order to (i) identify, contact or bring legal action against any person who may be causing damage to or interfere with our and/or any third party's rights or property (whether intentionally or otherwise) and/or (ii) to help with anti-money laundering and counter-terrorist financing requirements of our third parties service-providers.
By using our Services, you consent to the use, transfer and disclosure of your Personal Data as set out above.
Keeping you Updated Regarding our Services & Direct Marketing
Provided you have subscribed to receive our communications, we may use your Personal Data to contact you with investor relations updates.
If you have any questions or concerns about the communications you are receiving from us, you can get in touch with us at any time, free of charge (see "Your Rights" below).
We are fully committed to safeguarding the privacy of our customers, online and otherwise, and the success of our business depends on our ability to maintain the trust of our clients and customers. We apply Defense in Depth approach in securing Personal Data entrusted to us by our customers and continuously improve those measures to address security risks. We use Amazon Web Services, Inc (“AWS”) as our technology infrastructure service provider to power the main core of our Services. Data we collect is stored in data centres operated by AWS which offer best-in-class security. For more information, please visit: https://aws.amazon.com/security/
Despite our security precautions, we cannot fully guarantee the security of your Personal Data because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Data over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Data on a secure device within a secure environment.
Use of the Services by Minors
The Services are not directed to individuals under the age of eighteen (18), and we request that these individuals do not access or use our Services.
Improving our Service
You have the right to check whether we hold Personal Data about you and to require access or correction of your Personal Data. You can also unsubscribe from receiving our email alerts newsletter and other promotional communications from us at any time by clicking on the unsubscribe link in our email to you. You are also entitled to opt out of receiving direct marketing emails from our affiliates and any of our Partners.
If you wish to exercise any of your above-mentioned rights, or you have any inquiries or complaints in respect of your Personal Data, please kindly address your enquiries to:
MoneyHero Legal Team
22/F, East Exchange Tower, 38 Leighton Rd, Causeway Bay, Hong Kong
When you submit a request, we may need to obtain information about you or your request to verify your identity before we can process your request. You may submit requests through an authorised agent, in which case we will need to verify the agent’s identity, your identity, and their authority to act on your behalf before we can process the request.