Privacy Policy

1.    OVERVIEW

1.    Fairfield is committed to protecting and respecting your privacy.

2.    This Privacy Policy applies to all persons and entities that access the Platform. By accessing and / or using the services available on or through the Platform, you hereby acknowledge that you have read and agree to the terms of this Privacy Policy.

3.    The Privacy Policy is designed to assist you to understand how we collect, use, disclose and/or process the Personal Data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your Personal Data.  Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

2.    DEFINITIONS

1.    “Personal Data” means information or data which can be used to directly or indirectly identify an individual who is a natural person including:-
 

a.    full name;

 

b.    identification number (for example, identification card, passport or social security number);

c.     date of birth;

d.    correspondence address;

e.    the type of Service and/or Product utilised;

f.      banking and financial record; and

g.    your personal details from Third Party Sites for e.g. Facebook.

2.    “Selected Third Parties” refers to the third parties set out at section 4.5 below.

3.    INFORMATION COLLECTION

1.    From time to time, Fairfield may collect information and data about you, including information and data:

a.    that you provide or is provided to by any person authorized by you;

b.    in relation to each of your visit to our Platform; and

c.     from such other third parties authorized by you and publicly available sources.

2.    Through you, Fairfield may also collect information and data about your family members, friends and other individuals (collectively all of the foregoing who are natural persons, (“Relevant Individuals”).

3.    In this regard, Fairfield may collect the following information and data stated at section 3.1 and 3.2 as follows:

a.    Any information or data about you and/or such Relevant Individual(s) that can identify you or such Relevant Individual(s), including but not limited to name, date of birth, passport, national identity card number or other identification number or particulars, address, email address, phone number, contact details, financial and credit card information, personal description and photograph, products and services portfolio information, transaction patterns and behaviour, financial background, educational background and demographic data;

b.    Any information and data about you and/or such Relevant Individual(s) generated and/or provided to us in the course of accessing our Platform and undertaking any activity on our Platform. For example, your registered username for the Platform, search results and history for Service and Product within our Platform, Service and Product Submissions history, records of transactions for Service and Product provided via our Platform, records of participation in any Interactive Service on our Platform, and your answers to questions intended for security verification;

c.     Any information and data about you and such Relevant Individual(s) generated and/or provided to us in the course of maintaining the relationship between us and you including account review reports and records of correspondence with you over the phone or via email;

 

d.    Any information and data about you collected in relation to each of your visit to our Platform including:

1.    technical information, including the Internet protocol (IP) address used to connect your computer or Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

2.    site visit information, including the full Uniform Resource Locators (URL) click stream to, through and from our Platform (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and

3.    Information and data from Cookies or other technologies deployed on our Platform. For detailed information on such Cookies and technologies and the purposes for which we use them see our Cookie Policy.

e.    Any information and data about you collected by us when you participate in events organized by us, such as functions, seminars, contests or reward programs, which may include photographs, videos and voice recording of you;

f.      Any information and data about you which we receive if you use any of the other websites operated by us, our Affiliates or the other services provided by us, our Affiliates. In such a case, we will have informed you and obtained your consent for the collection of such information or data about you by the relevant Privacy Policy contained from such other websites operated by us.

g.    Any information and data about you which we receive from Selected Third Parties (set out at section 4.5 below);

4.    Information and data about you and such Relevant Individual(s) which are referenced above at section 3.3 shall collectively form part of Personal Data.

 

4.    Use and Disclosure of Personal Information and Data

1.    Where deemed necessary and appropriate by Fairfield and in accordance with applicable laws, rules, regulations, Personal Data may be used and disclosed by Fairfield and/or the Fairfield Group for the following purposes to:

1.    grant you access and facilitate the use of our Platform and to ensure that the Site Content, Service, Product, Interactive Services, User Content, Third Party Content and Third Party Sites are presented in the most effective manner for you and for your Device;

2.    provide you with information, Site Content, Service, Product, Interactive Services and User Content that you request from us and access to Third Party Sites and Third Party Content;

3.    carry out our obligations arising from any contracts entered into between you and us;

4.    provide you with information about other Service and Product we offer that are similar to those that you have already purchased or enquired about;

5.    Provide you, or permit Selected Third Parties to provide you, with information about Service and Product that we feel may interest you. If you are an existing User, we will only contact you by email, SMS or phone with information about Service and Product similar to those that you had previously considered, booked, registered, subscribed, scheduled or purchased. If you are a new customer, and where you consented to the disclosure of your Personal Data to Selected Third Parties, we (or such Selected Third Parties) may contact you by email or SMS with information about Service and Product;

6.    notify you about changes to our Site Content, Service, Product, Interactive Services, User Content, Third Party Content and Third Party Sites;

7.    administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

 

8.    improve our Platform to ensure that the Site Content, Service, Product, Interactive Services, User Content, Third Party Content and Third Party Sites are presented in the most effective manner for you and for your Device;

9.    allow you to participate in Interactive Services and any other interactive features of our Platform, Service and Product, should you choose to do so;

10.  implement and review safety and security measures on our Platform so as to keep our Platform safe and secure;

11.  measure or understand the effectiveness of our advertising and third party advertising on our Platform and on other third party websites, and to deliver relevant advertising to you;

12.  make suggestions and recommendations to you and other Users of our Platform about Service, Products or third party products and services that may interest you or them;

13.  make decisions relating to the opening or continuation of User Account and the establishment, provision or continuation of Service and Product otherwise maintaining accurate “know your customer” information and conducting anti-money laundering, credit and background checks;

14.  provide, operate, process and administer User Account, Service and Product or to process applications for User Account, Service and Product, any transactions (including remittance transactions), and to maintain service quality and train staff;

15.  undertake activities related to the provision of User Account, Service and Product, including the provision of articles, education materials, research reports or similar materials;

16.  provide Product-related services and support, including without limitation, provision of processing or administrative support or acting as an intermediary / nominee / agent in connection with your participation in Product;

17.  provide or grant access to Product-related materials;

18.  fulfill foreign and domestic legal, regulatory and compliance requirements applicable to Fairfield and the Fairfield Group under any Applicable Laws (including anti-money laundering and tax obligations applicable to Fairfield and the Fairfield Group, and disclosure to any court, governmental authority, supervisory authority or any other authority or regulator pursuant to relevant guidelines, regulations, orders, guidance or requests from such organisations);

19.  verify the identity and/or authority of your representatives who contact Fairfield or the Fairfield Group or may be contacted by Fairfield or the Fairfield Group and to carry out or respond to requests, questions or instructions from verified representatives or other parties pursuant to our prevailing security procedures;

20.  to carry out data processing and perform statistical, trend analysis and planning, for present and future reference;

 

21.  monitor and record calls and electronic communications with you for record keeping, quality, training, investigation and fraud prevention purposes;

22.  detect, prevent, investigate and prosecute crime and fraud including to aid in any criminal investigation by the relevant authorities of you, such Relevant Individuals or any other person;

23.  enforce (including, without limitation, collection of such outstanding amount(s) owed to Fairfield and/or the Fairfield Group) or defend the rights of Fairfield or the Fairfield Group, contractual or otherwise;

24.  perform internal management to operate control and management information systems and to carry out internal audits or enable the conduct of external audits;

25.  comply with contractual arrangements by or between industry self-regulatory, industry bodies, associations of industry providers or other institutions similar to Fairfield or the Fairfield Group;

26.  to manage Fairfield’s relationship with you, which may include providing information to you or a Relevant Individual, about Fairfield or the Fairfield Group’s products and services, including without limitation, Service and Product, where specifically consented to or where permissible under applicable laws and regulations;

27.  for marketing products or services by various modes of communication including mail, telephone call, SMS, fax, electronic mail, internet, market research, and designing or refining any similar products or services including by conducting market research, data analysis, and surveys; and

28.  to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within Fairfield or the Fairfield Group and any other use of data and information in accordance with any Fairfield Group programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities.

2.    We may combine any information and data, regardless of how such information and data were provided to us or collected by us, and use the combined information or data for the purposes set out at section 4.1 above.

3.    We may also use and disclose Personal Data for any other purposes relating to any of the above set out at sections 4.1 and 4.2, which a reasonable person would consider appropriate in the circumstances.

4.    As the purposes for which we may collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose(s) may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent for the collection of such Personal Data, unless processing of your Personal Data without your consent is permitted by law.