• Privacy Policy

    This privacy was last updated on 01 April 2019

    This Privacy Policy describes the information theAsianIR Pte Ltd (“Company”, “AIR”, “we”, “us” and/or “our”) collects about you, how we use and share that information, and the privacy choices we offer. This policy applies to information (including personally identifiable data (“Personal Data”)) we collect when you register, apply for advances, access or use our website, mobile applications, products, and services, or when you otherwise interact with us (collectively, the “Services”). As used in this Privacy Policy, the term “Site” includes: all websites and all devices or applications operated by AIR that collect personal information from you; pages within each such website, device, or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application; and pages that are associated with each such website, device, or application.


    Your access to and use of the Services is also subject to the Business Services Agreement, when executed, and Mission and Values at www.theasianir.com/missions-and-values. If there is any contradiction between Privacy Policy and another executed agreement you enter into applicable to specific aspects of the Service, the other agreement shall take precedence in relation to the specific aspects of the Service to which it applies.

    As used in this Privacy Policy, the words “you” and “your” refer to you, the user of AIR’s website, device, or applications, as the party agreeing to the Privacy Policy. By visiting and using the Site, you accept the practices described in the Privacy Policy. The use of the word “including” in this Privacy Policy to refer to specific examples will be construed to mean “including, without limitation” or “including but not limited to” and will not be construed to mean that the examples given are an exclusive list of the topics covered.




    1. Collection of information


    AIR may collect personal information (including Personal Data) and other information about you, including but not limited to the following:

    • Registration Information: When you register for a Service, you will be asked for basic registration information, such as an email address and password.
    • Business Information: You may also be asked to provide business information and documentation, including company size, financial statements, business type, organisational documents and business plans.
    • Third-Party Credentials: You may also enter in certain passwords, usernames, account numbers, and other account information for third-party sites and Internet services (“Third-Party Sites”).
    • Information from Third-Party Sites: In order to display information to you or to fulfil your requests for certain products and services through a Service, we may collect, on your behalf, your account and other personal information from Third Party Sites that you register under your account via the Service. We may also collect information about you from mailing list providers, publicly available sources, and other third parties.
    • Information Collected by Cookies and Web Beacons: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files that are stored on your hard drive or in device memory by a website. Among other things, cookies support the integrity of our registration process, retain your preferences and account settings, and help evaluate and compile aggregated statistics about user activity. We may also collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage, and determine whether an email has been opened and acted upon.
    • Technical and Navigational Information: We may collect your computer browser type, Internet protocol address, pages visited, and average time spent on our Site. This information may be used, for example, to alert you to software compatibility issues, or it may be analysed to improve our web design and functionality.
    • Device ID: When you use the mobile versions of our Site, we may collect the unique device identifier assigned to that device by phone makers, carriers, or makers of the operating system (the "Device ID"). Device IDs allow app developers, and others to uniquely identify your device for purposes of storing application preferences and other data.
    • We may, and we may allow third party service providers to, use cookies (as noted above) or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site.

    Our Site currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.


    2. Use of your information


    We may use, save and analyze the information you provide about yourself and about your Third-Party Sites (together “Data Processing”). Such Data Processing is necessary to perform our Services to you, including under the Business Services Agreement and Terms of Service and our legitimate business interests, including:

    • to fulfil your requests for our products, programs and Services and process and analyse your application,
    • to respond to your inquiries about our Services,
    • to provide customer support,
    • to offer you other products, programs, or services that we believe may be of interest to you,
    • to verify the existence and condition of your accounts and conduct due diligence,
    • to fulfil legal requirements,
    • to protect against potentially prohibited or illegal activities,
    • to improve (including through data analytics), monitor and personalise the Services and conduct our business and to provide targeted marketing and advertising,
    • to measure the performance of and improve the Site or mobile application functionality,
    • to manage, administer and protect our information technology infrastructure and Site security generally; and
    • to otherwise assist with a transaction. For example, we may use the account information you provide or that we collect from Third-Party Sites to confirm your accounts are valid and to access funds from your accounts in connection with fulfilment of the Services.

    By providing us with your information (including Personal Data and any data that may be subject a privacy regime of any jurisdictions), you are explicitly consenting to our use, collection, monitoring and processing of it in accordance with this Privacy Policy. You acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of AIR and the authorised third parties referred to herein located in Singapore.


    This Privacy Policy does not apply to any personal information collected by AIR other than personal information collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to AIR through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and not personal information and AIR shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.


    This Privacy Policy applies only to the Services. The Services may contain links to other web sites and services not operated or controlled by AIR. The policies and procedures we described here do not apply to the Linked Sites. The links from the Services do not imply that AIR endorses or has reviewed the Linked Sites, we are not responsible for actions of these Linked Sites. We suggest contacting those sites directly for information on their privacy policies.


    In an ongoing effort to better understand and serve the users of the Services, AIR often conducts research on its customer demographics, interests and behaviour based on the Personal Data and other information provided to us. This research may be compiled and analysed on an aggregate basis, and AIR may share this aggregate data with its affiliates, agents and business or financing partners. This aggregate information does not identify you personally. AIR may also disclose aggregated user statistics in order to describe our services to current and prospective business or financing partners, and to other third parties for other lawful purposes.


    Some of our pages utilise framing or white-labeling techniques to serve content from our partners while preserving the look and feel of our Site. Please be aware that in these instances you may be providing your personal information to these third parties and not to AIR.


    3. Sharing of information


    We may share personal information about you as follows and you hereby consent to such sharing:

    • With our subsidiaries and affiliates for purposes consistent with this Privacy Policy;
    • With our agents, consultants and related third parties to perform certain business-related functions;
    • With third parties (including insurance providers and financing sources) to provide, maintain, and improve our Services, to help us with our business activities (such as performing due diligence and know your customer compliance) and to better understand our users;
    • In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, reorganisation, divestiture, or dissolution of all or a portion of our business;
    • To respond to a request of a governmental entity, subpoenas, court orders, or legal process;
    • To respond to claims that any posting or other content violates the rights of third parties;
    • If required to do so by law or in the good faith belief that such action is necessary to;
      • comply with any legal obligation;
      • investigate, prevent, defend against, or take other action regarding violations of our Terms of Service, our Business Services Agreement, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, Sites or Services;
      • generally, protect against legal liability or otherwise protect our rights; or
      • to protect the health and safety of our Sites' users or the general public in an urgent or emergency; or
      • To any other third party with your consent.

    AIR may use third parties to gather user’s data from financial institutions. By using our service, you grant our third-party providers the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to terms of our third-party provider’s privacy policy.


    We may display personal testimonials of customers on our Site. We may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us by email at [email protected]


    4. Security


    We take reasonable measures, including firewall barriers, SSL encryption techniques, and authentication procedures, to help protect personal information from loss, theft, misuse, and unauthorised access, disclosure, alteration, and destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal information to AIR via the Internet.


    5. Email communications


    We may provide our registered customers with summaries of their account information and email alerts. We may also allow users to subscribe to email newsletters and from time to time may transmit emails promoting AIR or third-party goods or services.


    Subscribers have the ability to opt out of receiving our promotional emails and to terminate their newsletter subscriptions by following the instructions in the emails. Opting out in this manner will not end transmission of service-related emails, such as email alerts.


    6. Changes to your personal information


    You can easily access personal information that you have submitted to us and request the correction of any inaccurate information you have submitted to us, via your user account. Alternatively, you can send an email that includes your contact information to [email protected] to request any corrections, or access, to your personal information.


    You may also email us if you wish to deactivate your account or delete your information. We will however need to retain your information for as long as your account is active or as long as reasonably useful for commercial purposes (including if any amounts, including Specified Amounts (as defined in a Business Services Agreement) are outstanding). We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, collect on amounts owing and enforce our agreements.


    7. Singapore Personal Data Protection Rights


    Section 13 of the PDPC says that an organization shall not, on or after the appointed day, collect, use of disclose personal data about an individual unless –

    a) the individual gives, or is deemed to have given, his consent under this Act to the collection, use or disclosure, as the case may be; or

    b) the collection, use or disclosure, as the case may be, without the consent of the individual is required or authorised under the PDPA Act or any other written law.


    AIR fully abides by the PDPC guidelines and will not disclose personal data about an individual unless in the circumstances mentioned in the PDPC advisory guidelines.


    8. Changes to privacy policy


    We reserve the right, at our discretion, to make changes to this Privacy Policy from time to time without notice, so please review it frequently. You may review updates to our Terms of Service and Privacy Policy at any time via links on www.theasianir.com. You agree to accept electronic communications and/or postings of revised versions of this Privacy Policy on www.theasianir.com and agree that such electronic communications or postings constitute notice to you of the revised version of this Privacy Policy. Changes take effect immediately upon posting. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.


    9. Children


    AIR does not knowingly collect Personal Data from persons under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a person under the age of 18 has provided Personal Data to AIR through the Services, please contact us, and we will endeavor to delete that information from our databases.


    10. Changes to privacy policy


    The laws and regulations in different countries may impose different (and even conflicting) requirements on the Internet and data protection. The servers that make the Site available are located in Singapore. Please note that any information you provide will be transferred to the Singapore, and by using the Site or providing AIR personal information (including Personal Data), you authorise this transfer.


    Got Questions?


    If you have questions or concerns regarding this statement, or if you have any questions or suggestions, please contact [email protected]

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