PRIVACY POLICY

1. Scope of Policy

1.1. This data protection policy (“Policy”) has been developed to explain how Smoofy Pte. Ltd., (including its branches, associate offices and affiliates) (trading under the business name “Smoofy”) may collect, retain, process, share and transfer your Personal Data which is subject to the Personal Data Protection Act (No. 26 of 2012) of Singapore ("PDPA").

1.2. This Policy together with our Terms of Use apply to your use of:

(a) our website at https://smoofy.co (the “Site”);

(b) any of the services accessible through the Site (the “Services”).

1.3. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to Smoofy in respect of your Personal Data, and your consents herein are additional to any rights which to Smoofy may have at law to collect, use or disclose your Personal Data.

1.4. We may from time to time update this Policy. Updates will be posted on our Site. By continuing to interact with us, subject to applicable law, you agree to be bound by the prevailing terms of the Policy as so updated from time to time.

2. Introduction to the PDPA

2.1. In this Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time, but excludes "business contact information" as defined in the PDPA.

2.2. By interacting with us, submitting information to us, or engaging our services, you agree and consent to Smoofy, as well as our service providers and third parties appointed by us on your behalf (collectively, "us", "we" or "our") collecting, using and disclosing your Personal Data in the manner set forth in this Policy.

3. Data Protection Officer

3.1. We have appointed a data protection officer (“DPO”). Our DPO has several important responsibilities including:

(a) monitoring Smoofy’s compliance with the PDPA and other data protection laws;

(b) raising awareness of data protection issues, training Smoofy’s staff and conducting internal audits; and

(c) cooperating with supervisory authorities such as the Personal Data Protection Commission on our behalf.

3.2. Please do not hesitate to contact our DPO at:

4. How we collect Personal Data

4.1. Smoofy may collect information about you in various ways, including the following:

(a) when you register to use, or subscribe for any of our Services;

(b) when you establish an account with us;

(c) when you enter into any transaction using our Site, or related Services, we collect information about the transactions you undertake, as well as other information associated with those transactions;

(d) if you use our Services to add value to any of your accounts held with us, or if you ask another user to add value to any of your accounts with us, we may collect Personal Data from you about the other party, or from the other party about you to facilitate such a request;

(e) when you communicate or correspond with us (for example, by email or via the chat functions on our Site and/or relevant messenger apps);

(f) when you provide documentation or information to us (for example, by filing in forms or surveys on our Site);

(g) to the extent permitted by law, from public information sources, search services and other third parties such as merchants, data providers, and credit reference agencies;

(h) when you communicate or interact with us via telephone, letters, fax, face-to-face meetings, the Site, email or other modes of contact. Please note that telephone calls may be recorded;

(i) when you request that you be included in an email or other mailing list, or enter a competition or promotion;

(j) when you submit an employment application or provide documents or information such as your resume, from recruitment agencies and employment references; and

(k) when you submit your Personal Data to us for any other reason.

4.2. If you provide us with any Personal Data relating to a third party, by submitting such Personal Data to us, you also represent to us and must ensure that you have notified the third party of the terms of this Policy and obtained their consent.