Introduction
Ottermise is fulfilled by our licensed partners (“Partners”) and relevant Third Party Vendors we work with. Ottermise is powered by Trunk Tech Pte Ltd, UEN 201705723K, a registered company in Singapore, hereinafter jointly referred to as (“We/Us”).

This Privacy Policy sets out our policy regarding the collection, use, and disclosure of any information you may provide when you access and use our website www.ottermise.co via desktop or mobile application Ottermise (the “Application”) or the services provided by Us. It is intended to be read together with Ottermise’s Terms and Conditions. By accessing and using the Application, you are deemed to have read, accepted, and agreed to be legally bound by the terms of this Privacy Policy and Ottermise’s Terms and Conditions, whether you have registered as a user.

Data Collection
When you access or use the Application or any part thereof, or communicate with Us or any of our officers, employees or agents whether through written, published or electronic means, the telephone or otherwise, We may collect or receive personal or non-personal information or data about, in connection with or from you, including without limitation possibly through cookies, pixel tags, website and data analytics, and other technologies (“Your Information”), in accordance to the Personal Data Protection Act 2012 (“PDPA”).

Personal information or data may include without limitation, your:
• Name
• Age
• Telephone number
• Email address
• Background information

Non-personal information or data may include without limitation, your:
• Browser information
• Internet protocol (IP) address
• How you use the Application or any part thereof
• Aggregated information

We may also collect personal information about someone else from you to provide a better analysis. If you provide personal information to Us about someone else, you must obtain that person’s prior consent for you to provide his/her personal information to Us.

Most web browsers are initially set up to accept cookies. You can choose to block or disable cookies by changing the settings on your web browser. If you choose to block or disable all cookies, including strictly necessary cookies, you may find that certain features on the Ottermise or any part thereof will not work properly.

We will retain Your Information for as long as the purpose(s) for which Ottermise collected it continues. It is then destroyed unless further retention is required to satisfy any legal, regulatory or accounting requirement or to protect our interests.

You can stop all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email at ottermise@trunktech.co.

Automatically Collected Information
In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

Disclosure to Third Parties
We will not sell your Personal Data to any third parties. There may be instances however that we will need to share your Personal Data to certain suppliers, agents or service providers that assist us or that we use for optimising, monitoring or researching the usage, performance and operation of our Application as well as the services we provide through our Application. We only share your Personal Data with such third parties in so far as necessary to perform their services and tasks and we will ensure that these third parties protect your Personal Data in a manner consistent with this Privacy Policy and will not use your Personal Data for any other purposes than those specified by us.

We may provide personal data without express written permission, if allowed under applicable laws, in circumstances that include, but are not limited to:
1. Requests from governmental agencies, subpoenas, court orders or other legal requirements. In these circumstances, Ottermise will make every effort to limit the nature of the disclosure.
2. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
3. With our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

Data Retention Policy, Managing Your Information
We will retain Your Information for as long as you use the Application and for a reasonable time thereafter. We will retain Your information for up to 24 months and thereafter may store it in aggregate. If you would like us to delete Your Information, please contact us at ottermise@trunktech.co and we will respond in a reasonable time. Please note that some or all of Your Information may be required in order for the Application to function properly.

Data Usage
We may use Your Information in accordance to the PDPA:
• to follow up on and to facilitate the processing of your request(s) or application(s) in relation to products and services, and to connect you with third party product or service providers who will provide you with information, or process your request(s) or application(s) about products and services;
• to respond to, address, facilitate or fulfill your inquiries or requests;
• to update our records about you;
• to understand your needs;
• to personalise your experience on the Application and on our other websites by presenting advertising, promotions, offers, products and services tailored to you;
• to allow you to participate in contests and similar promotions, and to administer these activities. There may be additional rules applicable to these activities, which may contain additional information on how We use and disclose your Information;
• to enable you to send messages, or refer the Application, or any part thereof, or any product or service mentioned on the Application, to another person. By using this functionality, you represent and warrant that you are entitled to use and provide Us with that person’s name, email address and other contact details;
• for our business purposes, which will include, without limitation, data analysis, audits, developing new products, improving our Application and their respective contents, improving the products and services offered or distributed by Us, calculating the Application’s usage levels, identifying user behaviour and usage trends, determining and improving the effectiveness of our promotional campaigns, diagnosing server problems, geographic mapping, and administering the Site or any part thereof;
• to conduct background and credit checks and assist other financial institutions to conduct background and credit checks;
• for crime or fraud detection, prevention and prosecution; and
• to comply with any law, regulation, order or legitimate request, to any relevant governmental or other authority or regulatory body.

You agree that in the event you contact us via email, online chat, letters, facsimile, or other written, published or electronic means, We are entitled to keep a record of the relevant correspondence.

Consent to Disclose Information
We understand your need for privacy and will take reasonable care with regards to collecting, safeguarding, transference and usage of all your personal data.

Thus, only authorised employees of the company will be allowed to gain access to your data. Any disclosure of your personal information is strictly subjected to your clear consent via the contact form in our Application, i.e. request for more information, etc.

You are not obligated to provide any personal information or consent the disclosure of your information to us. However, if you disagree to provide the required information or consent, certain services to you may not be available.

Information Protection
All data will be stored in Singapore. If there is a need for Us to transfer Your Information out of Singapore, We will only do so after we have been assured that Your Information will receive a comparable level of protection as laid down in this Privacy Policy and/or the PDPA.

We endeavour to take reasonable steps to protect the confidentiality and security of Your Information in accordance to the PDPA. However, We cannot guarantee the security of any data you transmit by electronic means, as no data transmission over the Internet or by any other electronic means can be guaranteed as totally secure. You accept the inherent security risks of providing information and dealing over the Internet or by electronic means. To the maximum extent permissible under applicable law, We are neither responsible nor liable for any breach of security.

The Internet is not a secure form of communication and sending and receiving information over the Internet carries with it risks including the risk of access and interference by unauthorised third parties. It is your responsibility to maintain the secrecy of any user ID and login password you hold.

Information passing over the Internet may be transmitted internationally (even when sender and recipient are located in the same country) via countries with weaker privacy and data protection laws than in your country of residence. As a result, We do not accept responsibility or liability for the confidentiality, security or integrity of Your Information in connection with its transmission over the Internet.

In order to maintain the security of our systems, protect our staff, record transactions, and, in certain circumstances, to prevent and detect crime or unauthorised activities, We reserve the right to monitor all Internet communications including web and email traffic into and out of our domains.

Links to Other Sites
Our Application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Privacy Policy Periodic Updates
Our goal is continuous improvement and we will make amendments and revisions to our Privacy Policy from time to time as deemed necessary. Any changes and updates that we make shall be made available for viewing here.

We reserve the right to revise our Privacy Policy at any time without any notice. The Privacy Policy will be effective immediately at the time of revision and will supersede any previous Privacy Policy. Thus, please check our Privacy Policy whenever you visit our website. Your usage of our website will constitute as your acceptance of these Terms & Conditions of Use.

Do-Not-Call Registries
In your dealings with Us, you may have provided consents for Us to collect, keep and use your personal data and to contact you for providing health and wellness information and other related purposes. These consents apply even if your mobile or other contact numbers are listed with the Singapore Do-Not-Call registry (or any other similar registries or services), and will override the DNC or similar listings. Your consents apply to all your dealings with Us, including through mobile apps, Internet portals and any other electronic systems or properties.

Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
If you:
• have any questions or feedback relating to your Personal Data or our Privacy Policy;
• would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
• would like to obtain access and make corrections to your Personal Data records;

You may email us at ottermise@trunktech.co. We will try to comply with your request as soon as reasonably practicable. In some cases, we may not be able to remove or change Your Information or any part thereof, including, without limitation, where doing so would be against the law or regulations or any direction by any public or governmental authority. Withdrawal of your consent will automatically limit certain services to you as personal information is required for such services, such as a request for Us or Financial Adviser Representative to contact you.

If your personal data has been provided to us by a third party (e.g. your employer or partner), you should contact that party to make such queries, complaints, and access and correction requests to Us on your behalf.

If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, We may not be in a position to continue to provide its products or services to you, or administer any contractual relationship in place. It may also result in the termination of any agreements with Us, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.

Staying In Contact
If you create an account with us, or if you do not create an account but you do submit your email address we can send you: newsletter updates, account information updates and other Website announcements. If you want to hear more from us you can opt to receive more information which will include messages and content we think would be interesting for you including targeted advertisements and marketing messages from us. As soon as you are no longer interested in these extra mailings, you can choose to unsubscribe from our mailing list by dropping us an email at ottermise@trunktech.co.

Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of Singapore and you agree to be subject to the non-exclusive jurisdiction of the courts of Singapore.

Last Update
This Privacy Policy was last updated and revised on 31 August 2020.