Privacy Policy

Introduction

Your privacy is important to us, so we have developed a Privacy Policy that covers how we collect, use, disclose, transfer and store your information. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information.

Definitions, Description, and Interpretation. Headings and subheadings are inserted for convenience only and do not affect the construction or interpretation of these Privacy Policy. Words denoting the singular shall (where appropriate) include the plural and vice versa, and words denoting a gender include every gender. The words “including” and “include” are not words of limitation. References to persons shall be construed to include bodies incorporated or unincorporated.

In this Privacy Policy, unless the context otherwise requires, the following definitions shall apply:

“Cards” – including the virtual account and/or the physical and/or Cards which are provided to you upon sign-up through Subtra website and completion of a Know-Your-Customer (KYC) process with us. The Cards are regarded as a stored value facility/debit under Country laws, and different types of payment products and services may be available to you from time to time.

“Country” means the country or territory where you are residing.

“Subtra” – “We”, “Us”, “Our”, “Ourselves” refers to Mobikon Asia Pte Ltd, together with its employees, directors, affiliates, successors, and assignees or its partner/s acting on behalf of Subtra. Mobikon Asia Pte Ltd is a company duly established and operating under the laws of Singapore, has its registered office at 435 Orchard Road, 11th Floor, Wisma Atria, Singapore 238877.

“Subtra app” – refers to wallet application on mobile devices, our Subtra websites or portals that you can access from mobile devices or computers. Subtra is a mobile and web application-based money and card management platform, owned and offered to you by Mobikon Asia Pte. Ltd..

“You”, “Your”, “Yourself” refers to the Subtra users whether in their capacity as Senders, Recipients, or visitors to any of Subtra’s website and/or its applications on mobile devices.

By completing the sign-up process, you accept this Privacy Policy and consent to the collection, use or disclosure of personal data about you by us when you voluntarily provide the personal data to sign up for, access, or use any products, services, content, features, technologies or functions offered on Subtra app. We reserve the right to amend this Privacy Policy at any time and for any reason we may deem proper, and any such amendment shall be effective upon notice to you by publication or other means of communication, electronic or otherwise. You are advised to check this Privacy Policy available on Subtra website from time to time for any updates or changes that may impact you. This is unless you object to those amendments by manifesting the intention to terminate your membership in writing within five (5) days from notice of the amendment. Your failure to notify us about this intention to terminate your membership as provided, and your continued use of Subtra and related services, or both, shall be taken as acceptance by you of the amendments.

Introduction

How information about you is collected

When you visit the Subtra website, download and use Subtra app or use our related services, we collect information sent to the operating system by your computer, mobile phone or other access devices. The information sent to us includes data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Subtra web log and application data includes the browser type and/or mobile devices you are using and traffic to and from the Subtra app and/or Subtra website. When you visit the Subtra website, use Subtra app or use our related services, we also collect information about your transactions and your activities.

In addition, if you open a Subtra website, Subtra app or use our related services, we may collect the following types of information:

  • Contact information, such as your name, address, mobile number, email and other similar information.
  • Detailed personal information such as your date of birth or national ID number.
  • Connection information such as the name of the ISP or mobile operator through the Platform is accessed, browser type and IP address.

We may also obtain information about you from third parties such as credit bureaus and identity verification services.

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your Subtra Cards, application and authorizing us to have access to this information, you agree that we may collect, store and use this information in accordance with this Privacy Policy.

In order to help protect you from fraud and misuse of your personal information, we may collect information about your use and interaction with the Subtra website or Subtra app provided by us. For example, we may evaluate your computer, mobile phone or other access devices to identify any malicious software or activity.

We may also collect additional information from or about you in other ways, such as through contact with our customer support team, results when you respond to a survey, from interactions with other websites & sites (automatically collected) and any other data, information & services offered by us by whatever means of communication.

How Cookies are used

When you access Subtra website, your Subtra application on your mobile devices or use our related services, we (including companies we work with) may place small data files on your computer or other devices. These data files may be cookies, pixel tags, cache, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively “Cookies”). We shall use these technologies to; recognize you as a customer; customize Subtra, Cards and related services, content, and advertising; measure promotional effectiveness; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across Subtra app and our services.

We use both session and persistent Cookies. Session Cookies expire and no longer have any effect when you log out of your account or close your browser or your Subtra application on your mobile devices. Persistent Cookies remain on your browser or application until you erase them or they expire.

We encode our Cookies so that we can interpret the information stored in them. You are free to decline those Cookies if your browser or browser add-on permits, but doing so may interfere with your use of the Cards website and our related services. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling Cookies.

You may encounter Subtra app or Subtra website’s cookies or pixel tags on websites or mobile devices that we do not control. For example, if you view a web page/link created by a third party or use an application developed by a third party, there may be a cookie or pixel tag placed by the web page or application. Likewise, these third parties may place their own cookies or pixel tags that are not subject to our control and this Privacy Policy does not cover their use.

Personal Information

How personal information is protected and stored

Throughout this policy, we use the term “personal information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific user.

We store and process your personal information on our computers in the US, Asia, Europe and elsewhere in the world where our facilities are located. We shall protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards are firewalls and data encryption, physical access controls to data centers, and information access authorization controls.

How the collected personal information is used

The primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. Your personal information may be used to:

  • provide Subtra, Cards and related services and customer support;
  • process transactions and send notices about your transactions
  • resolve disputes, collect fees, and troubleshoot problems;
  • prevent potentially prohibited or illegal activities, and enforce the Terms and Conditions;
  • customize, measure, and improve Subtra, Cards and related services and the content, layout, and operation of our websites and applications;
  • deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
  • contact you at any telephone number, by placing a voice call or through text (SMS) or email messaging, as authorised by the Subtra Terms and Conditions;
  • compare information for accuracy and verify it with third parties.

Marketing

We shall not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize Subtra, Cards and related services, content, and advertising.

We may call or send a text message (SMS) to you at a mobile phone number that you have provided.

If you do not wish to receive marketing communications or participate in ad-customization programs, simply indicate your preference by following the directions that may be provided within the communication or advertisement.

How personal information is shared with other Subtra, Cards, users

To process your payments or other transactions, we may share some of your personal information, including your contact information, date of sign-up, and the number of transactions you have conducted, with the person or company that you are conducting transactions with. In addition, this and other information may also be shared with third parties when you use these third parties to access and use Subtra, Cards and related services. Unless you have agreed to it, these third parties are not allowed to use this information for any purpose other than to enable Cards and related services.

If you are buying goods or services and pay through Subtra or Cards, we may also provide the Merchant with your shipping and billing address to help complete your transaction. The Merchant is not allowed to use this information to market its services to you unless you have agreed to it. If an attempt to pay your Merchant fails, or is later invalidated, we may also provide your Merchant with details of the unsuccessful transactions.

How personal information is shared with other parties

We may share your personal information with:

  • Our subsidiaries, affiliates and partner/s – to provide joint content, products, and services (like registration, transactions and customer support), to help detect and prevent potentially illegal acts and violations of policies, and to guide decisions about products, services, and communications. Our subsidiaries, affiliates and partner/s shall use this information to send you marketing communications only if you have requested their services.
  • Service providers under contract who help with our business operations such as fraud prevention, bill collection, marketing, and technology services. These contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
  • Financial institutions that we partner with to jointly create and offer a product. These financial institutions may only use this information to market Cards-related products unless you have given consent for other uses.
  • Credit bureaus and collection agencies to report account information, as permitted by law.
  • Companies that we plan to merge with or be acquired by. (Should such a combination occur, we shall require that the new combined entity follow this privacy policy with respect to your personal information. If your personal information could be used contrary to this policy, you will receive prior notice).
  • Law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other legal processes or requirements applicable to us or one of our affiliates; when we need to do so to comply with any law and/or rules; or when we believe, at our sole discretion, that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of the Terms and Conditions.
  • Other third parties with your consent or direction to do so.

We shall not sell or rent any of your personal information to third parties for their marketing purposes and only share your personal information with third parties as described in this Privacy Policy.

How you can access or change your personal information

You can review and edit your personal information at any time by logging into your account and reviewing your account settings and profile or by calling the customer care number provided on our website from time to time. You can also close your account by calling the Customer Care number. If you close your Cards and Subtra account, we shall mark your account in our database as “Closed” but may retain personal information from your account as required by laws and/or to collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud, enforce the Terms and Conditions, or take other actions as required or permitted by law.

Security

Security Guidelines

Your role in safeguarding your Personal Data and Account Information

You are responsible for keeping your account information and password confidential. Failure to do so exposes you to the risks of fraud and loss. Subtra will not be responsible for losses suffered by customers as a result of:

  • Input errors or misuse of Cards and Subtra services;
  • Negligent handling or sharing of your Password;
  • Leaving a computer or mobile device unattended during an online session.
  • Failure to immediately report known incidents of unauthorised account access.

We strongly recommend that you observe the following best privacy and security practices at all times:

  • Managing your Personal Data and Account Information and Password. Your Personal Data and Account Information and Password identify you when you use our services. If any of these become invalid or ceases to be effective, it is imperative that you inform us by calling the customer care number for the respective services.
  • Ensure that no one can see your Password when you log into our system.
  • Ensure that you keep your Password confidential at all times and do not divulge it to anyone.
  • Do not allow anyone (without exception) to use your Personal Data and Account Information and Password, as you are responsible for all transactions undertaken with your Personal Data and Account Information and Password.
  • Do not base your password on your Personal Data and Account Information such as your telephone number, birth date or the like.
  • Memorize your Password and do not record it anywhere.
  • Change your Password regularly
  • Do not use the same character more than twice for your Password.
  • Do not recycle your recently used Password.
  • Change your Password IMMEDIATELY if you suspect that someone knows it.
  • The same Password should not be used for different websites, applications or services particularly when they relate to different entities.
  • Do not select the option on your browser for storing or retaining username and Password.

Take precautions against your security code keystrokes being captured.

Exercise the necessary precautions to protect your personal computer against viruses and other malicious programs. Aside from damaging and/or destroying data, viruses and malicious programs can capture your Password keystrokes and other personal information and send them to another person without your consent. Precautions that you can take include the following:

  • Ensure that you install an effective personal firewall as well as anti-virus, anti-spyware and anti- Trojan-horse software. These should be updated regularly.
  • Do not download any software from a website that is of doubtful origin.
  • Do not open any email or attachment that is from a source unknown to you. When in doubt, delete such email without opening it.

Inform us immediately of suspected invasion of your privacy or of unauthorised transactions.

  • If you suspect that your privacy has been invaded or that your account(s) has/have been accessed by unauthorised persons, please change your Password immediately and contact us by calling Customer Care number.
  • Check your transaction records to see if any transaction has been performed without your authorization. Should there be any unauthorised or unusual transactions, please notify us immediately.
  • You should check your transaction records regularly and notify us promptly of any errors. At the minimum, you should check your transaction records at least once at the beginning of each month.

Data Protection

The management of data, in particular personal data is of utmost importance to us. Under the (PDPA) Personal Data Protection Act 2012 (No. 26 of 2012) in Singapore, organisations are required to develop and implement policies and practices to meet their personal data protection obligations.

Subtra is at the forefront of providing transparency & control, you may at any point access or amend your data collected by emailing us at dpo@subtra.com. Subtra reserves the right to charge fees for the same, at its sole & absolute discretion as deemed appropriate.