Lucy Holdings Pte. Ltd. (“we” or “us”) are committed to protecting and respecting your privacy.
Scope of policy
- This policy together with the General Terms of Service apply to your use of:
- our website at http://www.welucy.com (the “Site”) including, without limitation, the Lucy Home Screen;
- the Lucy Mobile App (“App”) once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”); and
- any of the services accessible through the App or the Site (the “Services”).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed and used by us. We strive to ensure that our practices regarding personal data of our users comply with the various personal data protection and privacy laws applicable to us.
By using any of the Services, you accept our practices and processes as set out in this policy. If you do not agree to any part of this policy, please do not use any of the Services.
DATA PROTECTION OFFICER
We have appointed a data protection officer (“DPO”). Our DPO is based in Singapore and may be contacted directly via email ([email protected]) or through Customer Support using the in-App support. When contacting the DPO, please provide as much information as possible that is specific to your enquiry (including geographical or location information where relevant).
Our DPO has a number of important responsibilities, including:
- Monitoring Lucy’s compliance with the Personal Data Protection Act 2012 (“PDPA”), and other data protection laws;
- Managing personal data protection related queries and complaints;
- Raising awareness of data protection issues, training Lucy staff and conducting internal audits; and
- Cooperating with applicable supervisory authorities such as the Personal Data Protection Commission (“PDPC”) in Singapore on our behalf.
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us or our DPO via [email protected] or our in-App support.
You have the right to make a complaint at any time to the PDPC in Singapore. We would, however, appreciate the chance to deal with your concerns before you approach the PDPC, so please contact us in the first instance.
So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
- Always keep your data safe and private.
- Never sell your data.
- Allow you to manage and review your marketing choices at any time.
- Only collect, manage, transfer and use your data for the purposes set out in this policy.
Information we collect about you
- We will collect and process the following data about you:
- a) Information you give us – “Submitted Information”: This is information you give us about you by filling in forms on the App and/or the Site, or by corresponding with us (for example, by e-mail or via the chat functions on the App and/or the Site). It includes information you provide when you register to use the App, download or register the App, subscribe to any of our services, enter into any transaction on the App or the Site (such as a Top Up, Manual Transfer, Automatic Transfer, Lucy Bank Transfer), participate in discussion boards or other social media functions on the App or the Site, enter a competition, promotion or survey and when you report a problem with an App, the Services, or the Site. If you contact us, we will keep a record of that correspondence. The information you give us may include your names (including aliases), address, date of birth, e-mail address, phone number, the Device’s phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the long number, relevant expiry dates and CVC, identification document numbers, copies of identification documents (for example, passport, identification card, work permit, residency permit, driving license and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
- b) Information we collect about you and your device. Each time you visit the App or our Site we will automatically collect the following information:
- technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting – “Device Information”;
- information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services 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), methods used to browse away from the page, device information;
- transaction information including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used.
- information stored on your Device, including if you allow Lucy access contact information from your address book, login information, photos, videos or other digital content, check ins (Content Information). The App will periodically recollect this information in order to stay up-to-date;
- details of your use of our App or your visits to our Site including transaction details relating to your use of our services, including who you have sent money or electronic money to, foreign exchange transactions you have entered into, the time, date and location of the place the transaction was entered into.
- c) Location Information. We use GPS technology and your IP address to determine your location – this may be used when the App is running in the foreground and the background of your Device. This is used to prevent fraud, for instance if your mobile phone is saying that you are based in Singapore but your card is being used to enter into an ATM Withdrawal or point of sale purchase in Spain, we may not allow that transaction to be processed. Our card protection and fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the Lucy App within your device settings – “Location Information”
(d) Information to help us deliver our service to you. We work closely with third parties in order to help us deliver our Service to you. These third parties are business partners (such as those we partner with to offer additional Lucy Services), sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, fraud prevention agencies, customer service providers and developers. Information we may collect about you from such parties can include credit search information, information which helps us to verify your identity or information relating to your payment transactions. Please see the ‘Disclosure of your Information’ section for more information.
(e) If you allow us to, we will collect friends lists from Facebook and similar information from other third parties such as Twitter and Google – the App will periodically re-collect this information in order to stay up-to-date. You will always have the opportunity to opt-out later through our in-app chat.
Uses made of the information
4.1 Below is a summary of the key types of data that we make use of as part of the Lucy Services. For more information on how these types of data are used and for which purposes then please see the table below.
4.2 We use information held about you in the following ways:
- a) Submitted Information: We will use this information:
- to carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Manual Transfers, Automatic Transfers, Lucy Bank Transfers, ATM Withdrawals and Lucy Card Purchases and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you (where you have consented to such third-party marketing as per paragraph 5.6 below). Please see the section on ‘Third Party Services’ below for more information.
- to identify you and verify your identity, protect against potential fraud, comply with applicable anti-money laundering and countering the financing of terrorism laws and to confirm your eligibility to use our products and services;
- to notify you about changes to our service;
- to facilitate social interactions through our services and to make you aware if any of your contacts who are Lucy Users and have location services enabled, are in the same area as you. You can switch off location services in relation to this feature in the privacy settings of the payments section of the Lucy App;
- to make you aware if any of your contacts who are Lucy Users have utilised any of Lucy’s products or features. You can ask us to stop sending you marketing pushes at any time by adjusting your marketing preferences via the privacy section of the Lucy App;
- to comply with our regulatory obligations, e.g. requests from competent authorities (such as regulatory requests or Production Orders); and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- b) Device Information: We will use this information:
- to administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our Site and the App to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our Site and the App safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to help market and provide new products and services to engage you and acquire new users;
- to identify you and verify your identity, protect against potential fraud, comply with applicable anti-money laundering and countering the financing of terrorism laws and to confirm your eligibility to use our products and services; and
- to comply with our regulatory obligations, e.g. requests from competent authorities (such as regulatory requests or Production Orders).
- c) Location Information: We will use this information:
- to deliver relevant advertising to you, for example, information on nearby merchants;
- to protect against potential fraud; and
- to make you aware if any of your contacts, who are Lucy Users and have location services enabled, are in the same area as you. You can switch off location services in relation to this feature in the privacy settings of the payments section of the Lucy App.
- d) Third Party Information: We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information:
- to help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Lucy Account;
- to process applications for products and services available through us including making decisions about whether to agree to approve any applications;
- for the purposes set out above (depending on the types of information we receive).
4.3 We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
4.4 If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in a particular geographical location). In some instances, we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
4.5 We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so.
4.6 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us via in-App support if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|What we use your information for||Type of Information||Legal Bases|
|To provide the Lucy Services: To provide the Lucy Services: To carry out our obligations arising from any transactions you enter into with us, for example Top Ups, Instant Transfers, Lucy Bank Transfers, ATM Withdrawals and Lucy Card Purchases and to provide you with the information, products and services that you request from us.||Submitted Information||Fulfilling contracts: Being efficient about how we fulfil our legal and contractual duties.
Our legal obligation: Complying with regulations that apply to us.
|To combat against fraud: To verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services; and To help us better understand your financial circumstances and behaviour so that we may make decisions about how we manage your Lucy Account.||Submitted Information
Third Party Information
|Our legal obligation: (i) Developing and improving how we deal with financial crime and complying with our legal duties in this respect; and (ii) Complying with regulations that apply to us.|
|To help market and provide new products and services to engage you and acquire new users: To provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about; To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; To make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them; and To process applications for products and services available through us, including making decisions about whether to agree to approve any applications.||Submitted Information
Third Party Information
|Your opt-in consent, so that we may: (i) Develop products and services for existing customers and any applicable fees in relation to them; and (ii) Define types of customers for new products or services.
Fulfilling a contract: Being efficient about how we fulfil our legal and contractual duties.
|To keep the Lucy Services up and running: To administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer; To allow you to participate in interactive features of our service, when you choose to do so; To notify you about changes to our service; and As part of our efforts to keep our Site and the App safe and secure.||Submitted Information
|Fulfilling a contract: being efficient about how we fulfil our legal and contractual duties.
Our legal obligation: Complying with regulations that apply to us.
|Facilitate social interactions: To facilitate social interactions through our services and to make you aware if any of your contacts who are Lucy Users and have location services enabled, are in the same area as you; and To make you aware if any of your contacts who are Lucy Users have utilised any of Lucy’s products or features.||Submitted Information
Information Location Information
|Fulfilling a contract: Being efficient about how we fulfil our legal and contractual duties.|
|To provide location-based Services: To deliver relevant advertising to you, for example, information on nearby merchants; To protect against fraud; and To make you aware if any of your contacts, who are Lucy Users and have location services enabled, are in the same area as you.||Location Information||Fulfilling a contract: Developing products and services
Our legal obligation: Complying with regulations that apply to us.
What do we mean when we say:
- Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Our Legal Obligation: this means processing or retaining (even after termination of the business relationship) your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
5.1 We want to make it crystal clear how we use your data for marketing purposes and how you can ‘opt-out’ from receiving any marketing communications from us whenever you want.
5.2 When we use social media for marketing purposes, your information may be shared with the social-media platforms so that they can check if you hold an account with them. If you do, we may ask the advertising partner or social-media provider to:
- Use your information to send our adverts to you, because we think that you might be interested in a new Lucy product or service;
- Not send you our adverts, because the marketing relates to a service that you already use; or
- Send our adverts to people who have a similar profile to you, for example, if one of our services is particularly useful to people with similar interests to the ones on your social-media profile, we may ask our advertising partner or social-media partner to send our adverts for that service to those people. An example of how we may use social media for marketing purposes is through Facebook’s “Custom Audience” or “Lookalike Audience” tool.
The legal basis for such marketing would be opt-in consent.
PROMOTIONAL OFFERS FROM US
5.3 We may use your personal data (such as your Submitted Information, Location Information or transaction information) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
5.4 You will receive marketing communications from us if you have signed up to and/or utilise the Lucy Services and, in each case, you have not opted out of receiving marketing notifications.
5.5 We will obtain your express opt-in consent before we share your personal data with any company outside the Lucy group of companies for marketing or promotional purposes.
5.6 You can ask us or third parties to stop sending you marketing messages at any time by contacting up through the support function on our App or by following the unsubscribe links on any marketing message sent to you.
Disclosure of your information
DATA PROCESSING PARTNERS
6.1 We will disclose the data we collect from you to certain third parties who use personal data in delivering their services to us, they use data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Lucy.
6.2 We send personal data to the following sets of data processors in order to perform the Lucy Services:
- a) Fraud prevention agencies
- This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services;
- b) Cloud storage providers
- This is in order to safely and securely store your data with Lucy;
- c) Banking and financial services partners
- Financial services providers that help us provide the Lucy Services including banking partners, banking intermediaries and international payments services providers;
- d) Credit reference agencies
- For the purpose of assessing your credit score, in order to identify you or to prevent fraud
- e) Card manufacturing/personalisation and delivery companies
- For the purpose of creating your personalised Lucy card and delivering this to you at your requested address;
- f) Advertisers and analytics providers
- If we decide to engage advertisers to promote our products and services, the advertisers and their advertising networks may require anonymised personal data to serve relevant adverts to you and others. We will never disclose identifiable information about individuals to advertisers, but we may provide them with aggregate information about our users. We may also use such aggregate information to help our advertising partners provide a tailored and targeted campaign, relevant for a sub-section of our users (for example, women in Paris). In some instances we may use personal data we have collected from you to enable our advertising partners to display their advertisement to their target audience;
- We also use analytics and search engine providers that assist us in the improvement and optimisation of our site;
- g) Companies within the Lucy group
- In order to provide a unified service across all of our products and services, we may disclose your personal information to any member of the Lucy group, which means any of Lucy Holdings Pte Ltd’s subsidiaries or our related entities. Companies in the Lucy group will be acting as joint controllers or processors in order to provide the Lucy Services.
6.3 We may also disclose your personal information in the following circumstances:
- If Lucy or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- In order to:
(i) enforce or apply the General Terms of Service and/or the Business Terms and/or any other agreements between you and us or to investigate potential breaches; or
(ii) protect the rights, property or safety of Lucy, our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
THIRD PARTY PARTNERS
6.5 From time-to-time, we may partner with certain third parties in order to offer you co-branded services or promotional offers. In order to provide these services to you and to allow us and any associated third party to optimise their/our offering to you, we will share some of your personal data with such third parties. We will obtain your express opt-in consent before we share your personal data with any company outside the Lucy group of companies for these purposes.
6.6 You can withdraw your consent at any time after giving your explicit opt-in consent by contacting support and letting us know.
Storage security & International Transfers
7.1 The data that we collect from you may be transferred to, processed, and stored at, a destination outside Singapore. As we provide an international service, your data also may be processed outside Singapore in order for us to fulfil our contract with you to provide the Lucy Services. We will need to process your personal data in order for us, for example, to action a request made by you to execute an international payment, process your payment details, provide global anti-money laundering and counter terrorist financing solutions and provide ongoing support services. We will take all steps to ensure that your data is treated securely and in accordance with the PDPA.
7.2 All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology or a secure virtual private network. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and/or our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
7.3 Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
7.4 Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
Retaining your data, documents and information
Lucy is obligated under the PDPA to retain personal data about you and your Lucy Transactions for such time until the retention of your personal data is no longer necessary for any business or legal purpose. In particular, we are required, by using the electronic money licence of an entity who subject to the regulatory supervision of the Monetary Authority of Singapore (“MAS”), to retain data, documents and information we collect as part of complying with our anti-money laundering and countering the financing of terrorism (“AML/CFT”) obligations (which may include your personal data, documents and information) for at least five years after the termination of business relations with you or the completion of transactions you undertake with or through us.
Your legal rights
You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you. If you require this, then please reach out to our support team via the in-App chat function. Please note that Singapore law allows us to refuse your request for access for various reasons, including where the burden or expense of providing such access would be unreasonable to us or disproportionate to your interests.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via the in-App chat function. Please note that Singapore law allows us to refuse your request for correction for various reasons, including where your personal data is contained in a document that is related to a prosecution if all proceedings related to the prosecution have not been completed.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request. As an MAS-regulated entity, the electronic money licence holder that we work with is required to retain data, documents and information we collect as part of complying with our AML/CFT obligations (which may include your personal data) for at least five years after we terminate business relations with you or the completion of transactions you undertake with or through us. Please note that these retention requirements supersede any right to erasure requests under applicable data protection laws.
Object to processing of your personal data. You have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling grounds to process your information which override your rights. As part of our contractual agreement with an MAS-regulated firm, Lucy is under certain obligations to process and retain certain data for compliance purposes. Please note that these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data then we may not be able to provide the Lucy Services and it is likely we will have to terminate your account.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- a) if you want us to establish the data’s accuracy;
- b) where our use of the data is unlawful but you do not want us to erase it; or
- c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you (including the Lucy Services). In this case, we may have to cancel your use of the Lucy Services but we will notify you if this is the case at the time.
Request the transfer of your personal data to you or to a third party. We will provide to you, your personal data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you require this then please reach out to our support team via the in-App chat function.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Lucy Services to you. We will advise you if this is the case at the time you withdraw your consent.
No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you fail to provide personal data Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Lucy Services). In this case, we may have to cancel your use of the Lucy Services but we will notify you if this is the case at the time.
- Take a look at our data related FAQs;
- Take a look at some helpful guidance on the PDPC’s website which can be found here https://www.pdpc.gov.sg/Legislation-and-Guidelines/Personal-Data-Protection-Act-Overview; and
- Contact Lucy support via our in-App support function.