RIVEX FOUNDATION LTD.
Privacy Policy
For the use by RIVEX only
April 2020
Last changed: 21.4.2019

IMPORTANT NOTICE:


This Privacy Policy explains what information Rivex gathers about you, the source of that information, what we use that information for, the lawful basis on which that information is used, and who we share that information with when you use products, services, content, features, technologies or functions offered by Rivex and all related, sites, applications, and services (collectively, the “Rivex Services”). It also sets out your rights in relation to your information and who can you contact for more information or queries.


By accepting this Privacy Policy or continuing to use Rivex services after the effective date of this Privacy Policy (as set out above), you are deemed to have agreed and consented to allow Rivex and its affiliates and related corporations to:


- 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 Privacy Policy; and
- Disclose information about you to third party service providers that are engaged by the Rivex Group to perform certain functions in connection with the purposes set out below in this Privacy Policy
- This Privacy Policy may be revised over time as new features are added to the Rivex Services or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our website or softwares. 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 the revised privacy policy. We will post the notice on our website followed by a notification to you by e-mail or physical mail.
- 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 governed by their own privacy statements and terms of use, and Rivex 

 

The third party service providers as referred to in para(b) may be located within or outside Singapore. In this regard, by accepting this Privacy Policy or continuing to use the Rivex Services  after the effective date of this Privacy Policy (as set out above), you are deemed to have agreed and consented that such third party service providers may, to the extent necessary to perform the said functions, collect, use, disclose and/or process information about you.
 

Should you wish to withdraw your consent in part or whole, please contact us at info@rivex.io.

 

1. Overview
    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.
    1.2 Information: For the purposes of this Privacy Policy, the term “information” means any information about you that we or our third party service providers collect from you or a third party, including such information set out in Section 2 below. Rivex takes the processing of your information very seriously and will use your information only in accordance with the terms of this Privacy Policy. It is important for you to review this Privacy Policy as it applies to all of the Rivex Services.
    1.3 Notification of Changes: This Privacy Policy may be revised over time as new features are added to the Rivex Services or as we incorporate suggestions from our customers. We may change this Privacy Policy at any time by posting a revised version of it on our 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 the revised privacy policy. We will post the notice on our website followed by a notification to you by e-mail.
    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 to third-party websites. These sites are governed by their own privacy statements and terms of use, and Rivex is not responsible for their operations, including but not limited to their information handling practices. Users submitting information to or through these third-party websites should review the privacy statements and terms of use of these sites before providing them with personally identifiable 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:
• name;
• address;
• 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 applicable):
• 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 purposes;
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.

 

4. Marketing
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, intergovernmental 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 https://support.Rivex.tech/. 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.

 

9. Accountability
Our privacy office and our data protection officer are responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you have any questions about this Privacy Policy, Rivex's information practices, or your dealings with Rivex in relation to your information, you can contact us at john@rivex.io.