<p>
  Genwealth 8 Privacy Policy
</p>
<p>
  <strong><em>Last Updated: 17 October 2019</em></strong>
</p>
<ul>
  <li>
      Introduction
  </li>
</ul>
<ul>
  <ul>
      <li>
          In this Privacy Policy (the "<strong>Policy</strong>"):
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              "<strong>Account</strong>" means the membership or
              non-membership account opened by you with us;
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              "<strong>Act</strong>" means the Singapore Personal Data
              Protection Act 2012 as amended, revised or re-enacted from time
              to time;
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              "<strong>Personal Data</strong>" has the meaning given to it in
              the Act;
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
"<strong>Terms</strong> <strong>of</strong>                <strong>Service</strong>" means the terms of use found on our
              website, as amended from time to time.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              any reference to "<strong>you</strong>", "<strong>your</strong>"
              and words of similar import means any individual who may have
              provided any Personal Data to us for any purpose and any online
              users and visitors to our website or software applications that
              run on smart phones, tablets and other devices which provide
dedicated non-browser-based interaction (the “<strong>apps</strong>”); and
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
any reference to the “<strong>Company</strong>”, "<strong>we</strong>", "<strong>us</strong>" or "                <strong>our</strong>" and words of similar import means the
              Genwealth 8 Pte. Ltd., its subsidiaries, affiliates, successors
              and assigns.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          This Policy sets out our policy regarding the collection, use and
          disclosure of your Personal Data to us when you access and use our
website, apps or other services provided by us (the “<strong>Services</strong>”). Our Policy is to be read together with
          our Terms of Service. By accessing our Services, you consent to the
          collection, use and disclosure of your Personal Data to us and
          agree to be bound by the following terms and conditions of this
          Policy and our Terms of Service.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          You must be at least 18 years of age to use our Services. By using
          our Services, and by agreeing to these terms and conditions, you
          warrant and represent that you are at least 18 years of age.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          If you do not agree to the terms and conditions of this Policy,
          please discontinue the use of and refrain from using our Services.
      </li>
  </ul>
</ul>
<ul>
  <li>
      Collection and Use of Personal Data and Other Information
  </li>
</ul>
<ul>
  <ul>
      <li>
          Personal Data
      </li>
  </ul>
</ul>
<p>
  <br/>
  As a general rule, we will only collect and use your Personal Data through,
  including but not limited, cookies, pixel tags, website and data analytics,
  and other technologies in accordance with the Act, solely for the purposes
  notified to you. Such information includes but is not limited to the
  following:
</p>
<ul>
  <ul>
      <ul>
          <li>
              Account information upon registration of an account to use our
              services such as your personal particulars for example name,
              address, date or birth, gender, profession, marital status,
              nationality.
          </li>
          <li>
              Contact information that allows us to communicate with you.
              This information is obtained upon registration for our services
              on our Services including your name, address, telephone number,
              e-mail address and other means of communication which you may
              be contracted online or offline.
          </li>
          <li>
              Payment information related to your financial relationship with
              us such as the services we provide to you, your payment
              information such as credit or debit card details and your
              payment history.
          </li>
          <li>
              Product / service usage information such as how you use your
              device to access our Services.
          </li>
          <li>
              Third party partner information related to how you engage our
              third-party partners.
          </li>
          <li>
              Communications with us by e-mail, electronic messages, social
              media and other electronic and non-electronic means.
          </li>
          <li>
              Networks and connections made available to us, depending on the
              permissions you have granted, from your mobile or desktop
              devices address book contacts, Facebook friends list and other
              social media such as Linkedin, Instagram, Pinterest and
              Twitter.
          </li>
          <li>
              Device and settings information from or about the computers,
              mobile devices or other devices where you access our Services
              depending on the permissions you have granted to us. Such as
              the make and model of your mobile device, operating system,
              hardware version, device setting, file and software names and
              types, device identifiers, device locations through GPS,
              Bluetooth or WiFi Signals or such other connection information
              of your service provider or ISP, browser type, language and
              time zone, mobile phone number and IP address.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Aggregate Data
      </li>
  </ul>
</ul>
<p>
  For each visitor to our Services, our server automatically recognises
  information regarding your domain name (or that of the visitor’s access
  provider) but not the email address or other information that allows you to
  be identified (unless you choose to interact with us through activities
  such as subscribing to our mailing list or signing up for an event). We
  also collect aggregated information regarding user access or visits to our
  Services. Information collected automatically and aggregated information do
  not identify you personally and will only be used by use for analytical and
  statistical purposes, such as determining the countries from which our
  visitors originate.
</p>
<ul>
  <li>
      Handling of Personal Data
  </li>
</ul>
<p>
  Only authorised staff have access to your Personal Data. Our authorised
  staff are required to abide by their contractual obligations to maintain
  the confidentiality and privacy of your Personal Data at all times.
</p>
<ul>
  <li>
      Disclosure of Personal Data
  </li>
</ul>
<p>
  <br/>
  We do not sell any Personal Data in our possession to anyone or any third
  party for any purpose. Your Personal Data will not be published on our
  website. We will only disclose your Personal Data in circumstances that:
  you have expressly or implicitly consented to, or deemed to have consented
  to; that have been specifically notified to you; are necessary for the
  operation of our Services; or otherwise only in limited circumstances such
  as to government departments, statutory boards, regulatory or law
  enforcement agencies or in accordance with the applicable laws.
</p>
<ul>
  <li>
      Compliance by Third Parties
  </li>
</ul>
<ul>
  <ul>
      <li>
          In the event that we may be required to share your Personal Data
          with any third party we will notify you beforehand and obtain your
          consent.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          We may have outsourced one or more services or facilities offered
through our Services to third party service providers (“<strong>Vendors</strong>”). In such cases, we may provide some of
          your Personal Data, or you may be required to provide your Personal
          Data, directly to the Vendors. These Vendors are subject to
          confidentiality and data protection obligations and other legal
          restrictions that prohibit their use of the information we provide
          them for any other purpose except for the specific outsourced
          operation. Where the Vendor collects Personal Data directly from
          you, you will be notified accordingly and all information that you
          provide to them and their use of the information will be strictly
          between you and the Vendor. If you provide Personal Data directly
          to a Vendor, then their use of the Personal Data that you provide
          to them will be governed by their applicable privacy policy.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Without prejudice to the foregoing, our Services may contain links
          to other internet sites which are outside our control and are not
          covered by this Policy. If you access other sites using the links
          provided, the operators of these sites may collect information from
          you which will be used in accordance with their privacy policy,
          which may differ from ours.
      </li>
  </ul>
</ul>
<ul>
  <li>
      Security Measures in Place to Protect Personal Data
  </li>
</ul>
<p>
  <br/>
  To protect and safeguard the confidentiality of your Personal Data and to
  ensure that they are safe, secure and private, we adopt the following
  systems security and monitoring measures:-
  <br/>
</p>
<ul>
  <ul>
      <ul>
          <li>
              Firewalls, anti-virus protection and intrusion detection
              systems to detect and prevent any forms of illegitimate
              activities and/or illegal intrusions of our network systems;
          </li>
          <li>
              Regular security reviews of our systems;
          </li>
          <li>
              Vigilant monitoring to detect any suspicious online activities
              at our website.
          </li>
      </ul>
  </ul>
</ul>
<p>
  We are committed to monitoring our security system constantly for potential
  situations that could compromise the security or the privacy of our
  customers, online users and visitors to our website and to exploring new
  technology continually to enhance our security system. Nevertheless, we do
  not warrant the security of your Personal Data transmitted to us using our
  website and internet and online services. This is because you accept the
  risks that any of your Personal Data transmitted to or received by us using
  our website and internet and online services may still be accessed and/or
  disclosed by unauthorised third parties.
</p>
<p>
  Your responsibility in safeguarding your Personal Data
</p>
<ul>
  <ul>
      <li>
          If you wish to access our website, the best way is to directly
          enter our website address in the browser address bar and not via
          hyperlinks within emails (unless those emails are sent by us).
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Clear your browser’s cache and history after each session. Default
          files on a computer, sometimes called "cache" files can retain
          images of Personal Data or otherwise sent to or received by us at
          our website, making them a potential target for a system intruder.
          Therefore, we strongly advise that you clear your browser’s disk
          cache and history after each visit to our website.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Do not use a shared computer or an Internet cafe; computer to
          access our website because such computers may be installed with
          certain software which could capture your Personal Data or
          otherwise without your knowledge.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          If you have installed or downloaded any software which claims to
          speed up your internet connection or other software, games,
          screensavers etc, you should be aware that they may be spyware
          which has the ability to track your internet sessions and/or gain
          access to your Personal Data and Internet browsing history. We
          recommend that you uninstall such spywares.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Do not leave your personal computer unattended during your online
          session whereby your Personal Data may be viewed by unauthorised
          persons.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Ensure that your personal computer has the latest anti-virus,
          anti-spyware and firewall software and updates to guard against new
          viruses. Make sure that your computer’s operating system and
          browser software are updated with the latest security patches.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          If you wish to access our app, the best way is to directly download
          our app from the Google Play Store or the Apple Store on your
          personal mobile device.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Do not use the app or log into your account on a device that does
          not belong to you.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Do not leave your personal devices which have the app downloaded
          and your account logged in unattended.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Ensure that your devices, including your mobile phone, tablet or
          otherwise, have the latest anti-virus, anti-spyware, anti-malware,
          anti-ransomware and/or firewall software and updates to guard
          against cybersecurity threats.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Update us whenever you have changed your contact details in order
          for us to contact you in a timely manner on any issues or matters
          relating to your access to our website.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Contact us should you notice something suspicious or encounter any
          issues, difficulties or irregularities in accessing our website.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Do not open email attachments from strangers, install software or
          run programs from unknown sources or origins.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Delete junk or chain emails.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Email messages sent to us over the Internet containing your
          Personal Data cannot be guaranteed to be completely secure and you
          assume all risks arising or in connection thereto.
      </li>
  </ul>
</ul>
<p>
  It is important that you do your part to ensure that any Personal Data
  provided to us via our Services or email or any other channels of
  communication are done in a safe and secure manner. We will not be liable
  to you for any losses, damages, expenses, costs (including legal costs) and
  charges (whether direct or indirect, foreseeable or unforeseeable, special
  or consequential or economic loss) incurred or suffered by you arising out
  of you sending email messages containing your Personal Data to us over the
  Internet or for any error, fraud, forgery, system failure or anything
  beyond our control or in connection with your failure to adhere to the
  terms and conditions herein and the terms and conditions of access to our
  website under and/or your failure to follow the above recommended security
  measures.
</p>
<ul>
  <li>
      Access to Personal Data
  </li>
</ul>
<p>
  <br/>
  Under the Act, you have the right of access to your Personal Data in our
  possession or under our control or information which may have been used or
  disclosed by us within a year before the date of your request. Your request
  to us for access must be made in writing and subject to payment of any fees
  that we may prescribe.
</p>
<ul>
  <li>
      Correction of Personal Data
  </li>
</ul>
<p>
  <br/>
  If you have any reasons to believe that any Personal Data which you have
  provided to us is inaccurate, incorrect, incomplete or not updated, you may
  write to us. We will, after using reasonable efforts to verify the
  authenticity of the request, promptly update your records accordingly
  within seven (7) working days from the date of receipt of your request.
  <br/>
</p>
<ul>
  <li>
      Retention of Personal Data
  </li>
</ul>
<p>
  <br/>
  Your Personal Data will be retained by us for as long as the original
  purposes or the legal or business purposes for which your Personal Data was
  collected continues. If retention is no longer necessary, we will use
  reasonable efforts to delete, destroy or de-identify your Personal Data
  unless retention of the same is required to satisfy legal or regulatory
  requirements or to protect our interests or in accordance with our
  policies.
</p>
<ul>
  <li>
      Ways in which Personal Data may be collected
  </li>
</ul>
<ul>
  <ul>
      <li>
          Personal data may be collected from you through our website in a
          variety of ways, including but not limited to the following:
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              for the purpose for which the information was provided;
          </li>
          <li>
              when you visit, access or use our Services;
          </li>
          <li>
              when you communicate with us electronically and through other
              means;
          </li>
          <li>
              when you respond to surveys or feedback forms we might ask you
              to complete;
          </li>
          <li>
              when you open an Account with us;
          </li>
          <li>
              when you register on our Services as a user, whether to sign up
              for exclusive online features, or for any other purpose
              available through registration;
          </li>
          <li>
              when you interact with us through social media websites and
              other websites and apps;
          </li>
          <li>
              when you share content on our Services with other parties; and
          </li>
          <li>
              to conduct due diligence checks on you in accordance with all
              applicable laws and for us to comply with all legal and
              regulatory obligations, including Anti-Money Laundering and
              Countering the Financing of Terrorism.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          We may also collection information through automatic data
          collection and tracking technologies which include:
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              Personal data may also be collected from you through the use of
              cookies. Cookies are small data text files stored in your
              computer, laptop or mobile device that send information about
              your previous visits to and activities on our website. These
              cookies will not give us any personal information about you. We
              reserve the right to use the cookies to recognise your browser
              and thereby customise and optimise our website to your
              preferences. You can accept or delete cookies, however please
              note that if you do erase or block the cookies, you may not be
              able to utilize some features on the Services. In such
              situations, we shall not be held liable for any loss or damage
              resulting from your inability to use those features. These
              cookies are categorised into four categories:
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <ul>
              <li>
                  Strictly necessary cookies. These cookies are essential for
                  the function and operation of our Services.
              </li>
              <li>
                  Performance cookies. These cookies collect anonymous
                  information on the users of our websites and apps to enable
                  us to improve the operation of our websites and apps. For
                  example, by ensuring that users are able to use custom
                  features.
              </li>
              <li>
                  Functionality cookies. These cookies retain choices you
                  make such as user ID, email ID and other preferences in
                  order to personalise our Services for you as you navigate
                  through our Services.
              </li>
              <li>
                  Targeting cookies. These cookies record your browsing
                  habits to allow us to provide advertising relevant to you
                  and your interests. We may share this information with
                  third parties for this purpose on an anonymous basis.
              </li>
          </ul>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              Information may also be collected through the use of web
              beacons which may be contained in our website, apps or e-mails
              that permit us to, for example, count users who have visited
              the pages or opened an e-mail and collect other related website
              and app statistics.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              Log files may also be used to capture your activity on our
              Services, such as the content engaged and the frequency or
              duration of such activity.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Use of Personal Data collected through our Services:
      </li>
  </ul>
</ul>
<p>
  Without prejudice to any other provision of this Privacy Policy, any
  Personal Data collected through our Services will be used and/or disclosed
  by us for any one or more of the following purposes:
</p>
<ul>
  <ul>
      <ul>
          <li>
              to process and, where necessary, respond to your requests and
              queries;
          </li>
          <li>
              to verify and process your personal particulars and to ensure
              you are eligible to access and use the services provided;
          </li>
          <li>
              to process your registration on the website and in connection
              with your usage of the Services after such registration;
          </li>
          <li>
              to process your subscription to the E-newsletter and for
              purposes related to your subscription;
          </li>
          <li>
              to process any online purchases or donations made by you,
              including effecting payment;
          </li>
          <li>
              to communicate with you;
          </li>
          <li>
              to enforce our legal rights and remedies under this Privacy
              Policy and the Terms of Service;
          </li>
          <li>
              for marketing research, user profile and statistical analysis;
          </li>
          <li>
              to send you information, promotions, updates and marketing and
              advertising materials in relation to our products and services
              and those of third party organisations;
          </li>
          <li>
              complying with applicable laws and regulations, the requests of
              law enforcement and regulatory officials, or orders of court;
              and
          </li>
          <li>
              for any other purpose including the disclosure of such
              information to third parties for commercial/business reasons.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          Your usage of any services provided by us through our Services is
          also subject to our Terms of Service which are incorporated by
          reference into this Privacy Policy. If there is any conflict,
          inconsistency or ambiguity between this Privacy Policy and the
          Terms of Service, this Privacy Policy will prevail.
      </li>
  </ul>
</ul>
<ul>
  <li>
      Notifications
  </li>
</ul>
<ul>
  <ul>
      <li>
          We may send you notifications from time to time. You may not opt
          out of receiving certain service-related notifications when using
          our Services. You are deemed to have consented to the receipt of
          all such notifications, updates, marketing or otherwise, through
          the use of our Services. Such notifications include but are not
          limited to:
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <ul>
          <li>
              Necessary elements of your transactions on our Services or any
              service we may provide, such as confirmations of particular
              actions you have taken or confirmation of particulars;
          </li>
          <li>
              Are required for legal or security purposes;
          </li>
          <li>
              Meant to inform you of changes to our policies, operations or
              services;
          </li>
          <li>
              Information updates issued by us;
          </li>
          <li>
              User surveys or other requests for user feedback;
          </li>
          <li>
              Seminars, talks or courses available; and
          </li>
          <li>
              Marketing offers from us or sent on behalf of third parties
              through our Services.
          </li>
      </ul>
  </ul>
</ul>
<ul>
  <li>
      Customer Service and Enquiries
  </li>
</ul>
<ul>
  <ul>
      <li>
          You may at any time withdraw your consent to the collection, use or
          disclosure of your Personal Data by giving reasonable notice to us.
          If you withdraw your consent, we will inform you of the expected
          consequences of your withdrawal.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          If you have any queries, concerns or complaints relating to the
          collection, use or disclosure of your Personal Data, please email
          us at <strong>admin@genwealth8.sg</strong>. We will attend to your
          queries, concerns or complaints as expeditiously as possible.
      </li>
  </ul>
</ul>
<ul>
  <ul>
      <li>
          We may record, and/or monitor any communication(s) (including
          telephone calls or other electronic communications) between you and
          us. We may do so in order to resolve queries in the future and/or
          for the purpose of ensuring security, staff training and complying
          with its legal and/or regulatory responsibilities.
      </li>
  </ul>
  <li>
      Amendments to the Policy
  </li>
</ul>
<p>
  <br/>
  We may amend this Policy from time to time and will make available the
  updated Policy on our Services. By continuing to access our Services you
  agree to be bound by the terms and conditions of the Policy, as amended
  from time to time. The effective date of the Policy is the “Last Updated”
  date identified at the top of the page. You are responsible for ensuring we
  have an up-to-date and deliverable e-mail address and/or phone number for
  you and for periodically visiting our Policy to check for any changes.
</p>
<ul>
  <li>
      Governing Law and Submission to Jurisdiction
  </li>
</ul>
<p>
  <br/>
  This Policy is governed by Singapore law and you agree to irrevocably
  submit to the exclusive jurisdiction of the courts of Singapore.
</p>