This Privacy Policy (“Policy”) describes how Jenfi Pte. Ltd., its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “Jenfi”, “we”, “us” or “our”) collect, use, process and disclose your Personal  Data through use of www.jenfi.com (the “Site”) as well as products, features and other services, operated globally by Jenfi (collectively, the “Services”).

This Privacy Policy applies to our customers, agents, vendors, suppliers, partners, contractors, and service providers (collectively “you”, “your” or “yours”).

“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, email address, your image, government-issued identification numbers, biometric data, date of birth, marital status, and financial information.

We typically collect, use, disclose or otherwise process your Personal Data in accordance with this Privacy Policy and in compliance with applicable laws, such as where:

• it is required for us to comply with legal requirements;
• it is required for us to enter into or perform a contract with you; and/or
• for our legitimate interests or the legitimate interests of any other persons, including but not limited to for the purposes set forth in this Privacy Policy.

COLLECTION OF PERSONAL DATA

We collect (and may combine) Personal Data about you in the ways listed below:

You provide your Personal Data to us

We collect your Personal Data when you provide it to us. For example, when you:

• complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
• provide information for us to assess your eligibility to receive services or to become a partner with us;
• interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
• participate in contests or events organised by us (such as the pictures, audio, or videos you may submit, which may include images of yourself);
• verify your identity through various means (such as social media logins, submission of selfie images and videos); or
• provide personal information in surveys.

When our Services are used and/or you visit the Site

Personal Data may be collected through the normal operation or use of our Site and Services. Some examples are:

• device information, your web browser, IP address, time zone, and some of the cookies that are installed on your device;
• feedback and ratings;
• transaction information (such as payment method);
• information about how you interacted with our Site or used our Services (such as features used and content viewed, individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site);
• personal data you enter in messages when you use our in-Site communication features; and
• personal data that may be captured through your interaction with us, our agents, audio and/or video recording onboarding process (such as your image or voice or both, and its related metadata).

We collect device information using the following technologies:

• “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

From other sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources. Such sources include:

• referral programmes;
• our business partners, such as payment providers, accounting software providers, marketing accounts;
• insurance and financial providers;
• credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
• publicly available or governmental sources of data;
• marketing services providers or partners.

USE OF PERSONAL DATA

Jenfi may use your Personal Data for the following purposes set out in the list below. (“Purposes”):

Providing services and features

• create, administer and update your account;
• communicate with you;
• process, manage or verify your eligibility for or application of Services with Jenfi;
• conduct due diligence checks and risk assessments / analysis;
• verify your identity and business information (where necessary);
• validate your process payments;
• personalise your Site experience (such as to recommend products and services relevant to you, identify your preferences or otherwise personalise your experience with Jenfi);
• perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;
• protect the security or integrity of the Services and any facilities or equipment used to make the Services available;
• invite you to participate in our surveys and studies;
• When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or Services;
• screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

User support

We use Personal Data to resolve user support issues. For example, we may:

• investigate and address concerns;
• monitor and improve our user support responses;
• respond to questions, comments and feedback; and
• inform you about steps taken to resolve user support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate development of solutions.

Legal purposes

We may use the Personal Data we collect for legal purposes, such as to investigate and resolve claims or disputes, detect, prevent or aid to prosecute crime, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

• comply with court orders or other legal, governmental or regulatory requirements;
• enforce our Terms of Service or other agreements; and
• protect our rights or property in the event of a claim or dispute.

Marketing and promotions

We may use your Personal Data to send you marketing communications relating to customised products or services (that may be of interest or relevance based on your profile), or Jenfi’s partners’, sponsors’ and advertisers’ products, services, events or promotions. For example, we may:

• send you special offers that may be of interest or relevance to you across all of Jenfi’s service offerings;
• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by various means, where applicable (including by SMS, chat applications (e.g. WhatsApp, Telegram, LINE, Viber, WeChat, Zalo)), push notification, call, and by email).

If you wish to unsubscribe from such marketing communications, you may update your preferences in our Site settings.

DISCLOSURE OF YOUR PERSONAL DATA

With third parties related to your use of Jenfi’s Services

We share your Personal Data with third parties to help us use your Personal Information, as described above. We also use Google Analytics to help us understand how our customers use the Site—you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy.

You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates. The companies in the Jenfi group share resources, such as infrastructure and technology, with each other to provide you with a consistent, relevant and secure experience when you use our Services, and for the Purposes set out in this Privacy Policy.

With Jenfi’s service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

• payment processors and facilitators;
• debt collectors;
• credit bureaus, alternative credit scoring agencies and any other credit reporting organisations;
• background check and anti-money laundering service providers;
• cloud storage providers;
• advertising and marketing partners and platform providers;
• data analytics providers;
• research partners, including those performing surveys or research projects in partnership with Jenfi or on Jenfi’s behalf;
• educational and training institute partners;
• insurance and financing partners; and
• service providers who perform identity verification services.

For example:

If you requested a service through a Site, Jenfi will perform credit bureau check on your credit history.

With our legal advisors and governmental authorities

We may also share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

Business transfers

We may share your Personal Data with other parties, in connection with any acquisitions, sales, mergers, joint ventures, consolidation, restructuring, financing or any other type of business transactions. Your Personal Data will however remain subject to our obligations made in any pre-existing privacy policy that you have agreed to.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at:

http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work

You can opt out of targeted advertising by:

FACEBOOK - https://www.facebook.com/settings/?tab=ads

GOOGLE - https://www.google.com/settings/ads/anonymous

BING - https://advertise.bingads.microsoft.com/en-us/reso...

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at:

http://optout.aboutads.info/

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

RETENTION OF PERSONAL DATA

Your Personal Data will only be kept with for as long as is necessary to fulfil the purpose(s) for which it was collected and for as long as such retention is required under law.  We will not retain your Personal Data as long as it is reasonable for us to assume that the purpose(s) for which your Personal Data was collected is no longer being served by such retention and retention is no longer necessary for legal or business purposes.

PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

AMENDMENDS AND UPDATES

Jenfi may modify, update or amend this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

Such amendments shall be notified to you through the Site and/or other appropriate means at least five (5) business days before the effective date. The updated version will be posted on the website  ://jenfi.com. It is your responsibility to review the Privacy Policy regularly. Your continued use of the Site or Services, or continuing to communicate or engage with Jenfi following the effective date of the modifications, updates or amendments to this Privacy Policy, whether or not reviewed by you, shall constitute your agreement to be bound by such amendments.

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

In accordance with applicable laws and regulations, you may be entitled to:

• inquire about the processing of your Personal Data and be provided with a copy of it;
• in some cases, request the correction and/or deletion of your Personal Data;
• in some cases, request the restriction of or object to the processing of your Personal Data;
• withdraw your consent to the processing of your Personal Data (where we are processing your Personal Data based on your consent);
• request receipt or transmission to another organisation, in a machine-readable form, of the Personal Data that you have provided to us where we are using your Personal Data based on consent or performance of a contract; and
• complain to the relevant data privacy authority if your data privacy rights are violated, or if you have suffered detriment as a result of unlawful processing of your Personal Data.

Please note that choosing not to share your Personal Data with us, withdrawing your consent to our use of it or to your agreement with our Privacy Policy could mean that you are unable to make use of the Site or the Services.

After you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

We will screen and verify all requests beforehand. In order to verify your identity and/or authority to make the request, we may require you to provide supporting information or documentation to corroborate the request. Once verified, we will give effect to your request within the timelines prescribed by applicable laws.

CONTACT US

For more information about our practices or if you have questions, please contact us by e-mail at privacy@jenfi.com or by mail using the details provided below:

Jenfi Pte. Ltd., 32 Pekin St, #05-01, Singapore 048762