For the use by RiveX only
a) Collect, use, disclose and/or process information about you that you had previously provided to the RiveX Services, that you now
provide to the RiveX Services and/or that you may in the future provide to the RiveX Services for the purposes set out below in this
b) Disclose information about you to third party service providers that are engaged by the RiveX Group to perform certain functions in
have legal grounds to do so otherwise, we will provide you with at least 30 days’ priori notice of the effective date of the revised privacy
policy. We will post the notice on our website follewed by a notification to you by e-mail or physical mail.
d) Some pages on the websites of the RiveX Group of parts of the RiveX services may include links to third-party websites. These sites are
Should you wish to withdraw your consent in part or whole, please contact us at email@example.com.
1.1. Overview: In order to provide the RiveX Services and to reduce the risk of fraud, RiveX, the data controller, must ask you to provide the
information (as defined below) about yourself, including your bank account details, information about any other financial instruments
that may be connected to your RiveX wallet and the information particularly set out in Section 2 below.
service providers collect from you or a third party, including such information set out in Section 2 below. RiveX takes the processing of
website. Unless we have legal grounds to do so otherwise, we will provide you with at least 30 days' prior notice of the effective date of
1.4. Third Party Websites or Applications: Some pages on the websites of the RiveX Group or parts of the RiveX Services may include links
their operations, including but not limited to their information handling practices. Users submitting information to or through these third-
information. RiveX is not responsible for the content or information practices of such third parties.
2. Information We Collect
2.1. Account Information: We will collect the following information for the purposes of opening and operating the RiveX account.
a) Account opening and usage:
To open a RiveX account or use the RiveX Services, we need your:
• phone number;
• the details of your identification document(s); and
• email address.
b) Topping up and making payments (where applicable):
To top-up your available balance of your RiveX account, or make certain payments through the RiveX Services, we need (where
• your bank (or another payment instrument) account information;
• to ask you to choose different security questions and answers (such as your city of birth or your pet's name); and
• other additional commercial and/or identification information, if you send or receive certain high-value transactions or high overall
payment volumes through the RiveX Services, or we are otherwise required by anti-money laundering laws and regulations.
3. How We Use the Information We Collect
We will use your Account Information to provide the RiveX Services. In particular, we will use your information for the following purposes:
3.1. Internal Uses: Our primary purpose in collecting your information is to provide you with a safe, smooth, efficient, and customized
experience in your use of the RiveX Services. We do this by processing your information to:
a) process transactions and provide the RiveX Services;
b) complete our customer screening and identity verification process including checks in relation to fraud detection and prevention,
anti-money laundering, know-your-client and the countering of the financing of terrorism;
c) resolve disputes, collect fees, and troubleshoot problems;
d) manage risks and carry out investigations, in relation to any illegal activity or potential illegal activity or transactions for breach or
potential breach of our terms and conditions;
e) provide you with customer support services;
f) improve the RiveX Services by customising your user experience;
g) measure the performance of the RiveX Services and improve their content and layout;
h) manage and protect our information technology infrastructure;
i) provide targeted marketing and advertising, service updates, and deliver promotional offers based on the communication
preferences you have defined for your RiveX account (please refer to the section "Our Contact with RiveX Customers" below) and
your activities when using the RiveX Services; and
j) perform creditworthiness and solvency checks, compare information for accuracy, and verify it with third parties.
3.2. Questionnaires, Sweepstakes, Surveys and Profile Data: If you choose to answer our optional questionnaires or surveys, we may use
such information to improve the RiveX Services, send you marketing or advertising information, manage the sweepstakes, or as
otherwise explained in detail in the survey itself.
3.3. Our Contact with RiveX Customers: We communicate with our users on a regular basis via email and chats to provide requested
services. We may also communicate with our users by phone to:
a) resolve customer complaints or claims made by users;
b) respond to requests for customer service;
c) inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
d) confirm information concerning a user's identity, business or account activity;
e) carry out collection activities;
f) conduct customer surveys; and
g) investigate suspicious transactions.
We use your email or physical address to confirm your opening of a RiveX account, to send you notice of payments that you send or receive through RiveX, to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.
We also use your email address to send you other types of communications that you can control, including "news” and “notice of special third-party promotions”. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account and then selecting settings and updating your preferences.
3.4. Other purposes: In some cases, we will also use your information for the purposes of, or in connection with:
a) independent audits of our financial statements and operations – the auditors may seek to contact a sample of our customers to
confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary
b) an official request from a public or judicial authority where either compelled by law or where appropriate in all the circumstances;
c) applicable legal or regulatory requirements;
d) financial accounting and invoicing purposes;
e) maintaining and managing insurance and insurance claims relating to our business;
f) services we receive from our professional advisors, such as lawyers, accountants, insurance brokers and consultants;
g) the transfer to a potential buyer, transferee, merger partner or seller and their advisers in connection with an actual or potential
transfer or merger of part or all of RiveX’s business or assets, or any associated rights or interests, or to acquire a business or
enter into a merger with it; and
h) protecting our rights and those of the RiveX Group.
We may combine your information with other information we collect from other companies and use it to improve and personalize the RiveX Services and send marketing communications to you. You will only receive such marketing communications from us or may participate in our ad-customization programs if you have expressly consented to doing so. If you have consented, but no longer wish to receive marketing communications from us or participate in our ad-customization programs, simply update your preferences.
5. How We Share your Information with Other Third Parties
We will share your information with the following types of third parties in the circumstances described below.
5.1. Disclose necessary information to the police and other law enforcement and/or fraud prevention agencies:
Such entities include security forces, competent governmental, inter-governmental or supranational bodies, regulatory authorities and
recognised self-regulatory authorities. Disclosure to such entities will be made where (i) the law (including but without limitation the the
General Data Protection Regulation, the applicable regulations on the US Foreign Account Tax Compliance Act (the “FATCA Law”),
and regulations on the OECD common reporting standard (the “CRS Law”)) compels or permits us; or (ii) we have reason to believe it
is appropriate for us to cooperate with such entities for checks in relation to fraud detection and prevention, anti-money laundering,
know-your-client and countering of the financing of terrorism, or investigations in relation to any other illegal activity or potential illegal
activity. If you are covered by the FATCA Law or CRS Law, we are required to give you notice of the information about you that we may
transfer to various authorities.
5.2. Disclose necessary information to other third parties such as payment processors, auditors, financial products providers, business
partners, marketing and public relations agencies, shipping and courier companies, RiveX Group companies, marketplaces, service
providers and your agents or legal representatives:
Such disclosure is required for purposes of our provision of the RiveX Services, investigations into transactions on breach or potential
breach of our terms and conditions, support of our business operations, checks in relation to fraud detection and prevention, anti-
money laundering, know-your-client and countering of the financing of terrorism, investigations in relation to any other illegal activity or
potential illegal activity, bill collection, marketing, provision of customer support services and public relations purposes.
5.3. Disclose necessary information to intellectual property rights owners:
Such disclosure is required under the applicable national law in the event that an owner of intellectual property rights commences any
action or pursues a claim against RiveX for an out-of-court information disclosure due to an infringement of their intellectual property
rights for which the RiveX Services have been used.
5.4. Grant access to information in event of mergers or acquisitions involving RiveX:
As with any other business, it is possible that in the future RiveX could merge with, or be acquired by, another company. If such merger
or acquisition occurs, the successor company will have access to your Account Information maintained by RiveX, and this Privacy
Policy continues to apply to such successor company unless and until it is amended.
5.5. Disclosing transactional details of RiveX users in event of transfer of funds between them:
If you are a registered RiveX user and you are sending funds or transacting with another registered RiveX user, as a part of the
transaction, the name, email address, date of sign-up and pertinent transactional details of both parties will be shared as a part of
transaction notification. However, your card number, bank account and other financial information will not be revealed to anyone whom
you have paid or who has paid you through the RiveX Services or third parties that use the RiveX Services, except with your express
permission or if we are required to do so pursuant to credit card rules, a court order or other legal process.
5.6. Disclosing information to sellers when RiveX users use purchase goods/services using the RiveX Services:
If you are buying goods or services and pay through RiveX, we may provide the seller with the delivery address for the goods and your
billing address to complete your transaction. If an attempt to pay your seller fails, or is later invalidated, we may also provide your seller
with details of the unsuccessful payment. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that
goods can be returned to the seller.
5.7. Disclosing information to loyalty schemes of which RiveX users are members:
If you link your membership of an eligible loyalty scheme to your account in our mobile app, we will share your loyalty scheme
membership ID with the relevant loyalty scheme when you pay using RiveX. If you remove your loyalty scheme membership ID from
your Account, we will stop sharing this information.
5.8. Disclosing information to third party service providers who facilitate payments from or to you:
We work with third parties to enable them to accept or facilitate payments from or to you using the RiveX Services. In doing so, a third
party may share information about you with us such as your email address or phone number, when a payment is sent to you or when
you are attempting to pay that third party. We use this information to confirm that you are a RiveX customer and that RiveX can be
enabled to make a payment, or where a payment is sent to you to send you a notification that you have received a payment. Also, if
you request that we validate your status as a RiveX customer with a third party, we will do so. Please note that third parties you receive
funds or buy from may have their own privacy policies, and RiveX is not responsible for their operations, including but not limited to
their information handling practices.
6. Cross Border Transfers of your Information
6.1. Please note that some of the recipients of your information referred to above will be based in countries outside of Singapore. RiveX is
committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for
your information where such data is transferred outside of Singapore.
6.2. RiveX will use best efforts to ensure that the third party service providers engaged by the RiveX Group in connection with the RiveX
Services will not transfer information about you to a place outside Singapore without the prior written consent of the RiveX Group. In
the event that the RiveX Group provides such consent, RiveX will use best efforts to procure that the relevant third party service
provider provides a written undertaking to the RiveX Group that the information about you which is transferred outside Singapore will
be protected at a standard that is at least comparable to that under the Personal Data Protection (No. 26 of 2012) of Singapore. If the
relevant third party service provider transfers information about you to any person overseas, RiveX will use best efforts to procure that
such third party service provider procures the same written undertaking from such person.
7. Retention of your Account Information
7.1. We will retain your information for as long as necessary to fulfil the purposes outlined in Section 3. However, we will retain your
information for a longer period where required by law and for the duration of any statutory limitation period for claims.
7.2. In general, although there are limited exceptions, we will retain your information during the period when you are using the RiveX
Services and for at least six (6) years after your use of the RiveX Services ceases.
8. Information Security
8.1. RiveX is committed to handling your information with high standards of information security. We use computer safeguards such as
firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to information
only for those employees who require it to fulfil their job responsibilities.
8.2. The security of your RiveX account also relies on your protection of your RiveX password. You may not share your RiveX password
with anyone. RiveX representatives will never ask you for your password, so any email or other communication requesting your
password should be treated as unauthorized and suspicious and forwarded to If you do share your RiveX
password with a third party for any reason, including because the third party has promised to provide you additional services such as
account aggregation, the third party will have access to your account and your information, and you may be responsible for actions
taken using your password. If you believe someone else has obtained access to your password, please change it immediately by
logging in to your account and changing your Profile settings, and also contact us right away.