use, disclose, store, transfer and/or otherwise process any information or data to which the
Personal Data Protection Act 2012 (the “Act”) applies (“Personal Data”).
Services. You acknowledge that you have read, understood and agree with the terms of this Privacy
Policy and consent to the collection, use, disclosure, storage, transfer and/or processing of your
Personal Data in accordance with and for the Purposes set out below. If you do not agree, do not use
or access the Site and/or Services.
determine in our sole and absolute discretion. Any such changes, modifications or updates shall be
effective from the date posted here. It shall be your responsibility to periodically check and
reference. In addition, the following words and express shall have the following
“Accounts” mean any one or more the accounts you
establish with us on the Site, through which you access and/or operate the Services
or Platform and/or such other services as we may offer and for which you may have
subscribed and shall include any of your Admin Accounts or User Accounts.
“Corppass Account” means the account created by
you or on your behalf with the authorisation system for corporate entities provided
by the Government of Singapore through which you or your employer perform corporate
“Data Processing” means, in relation to Personal
Data, the carrying out of any operation or set of operations in relation to the
Personal Data and includes any of the following: (a) recording; (b) holding; (c)
organization, adaptation or alteration; (d) retrieval; (e) combination; (f)
transmission; and/or (g) erasure or destruction.
“Data Protection Officer” shall have the meaning
described at Clause 5.1 below.
“Data Intermediary” means an organization which
processes personal data on behalf of another organization but does not include an
employee of that other organization;
“Designated Party” and “Designated Parties” mean one or more of the
banks, financial institutions, lenders and/or service providers with which you may
potentially enter into Third Party Arrangements with in connection with your use of
the Services or Platform.
“Guud”, “we”, “us” or
“our” mean Guud Asset Pte Ltd and the “Group”
shall mean Guud Asset Pte Ltd, its respective subsidiaries, affiliates and
associated companies (which shall include its related and jointly controlled
entities), which for the avoidance of doubt shall include but not be limited to
CamelOne Pte Ltd, Guud (Finance) Pte Ltd, Guud (Singapore) Pte Ltd, Guud (Africa)
Pte Ltd, Guud (International) Pte Ltd, Guud (Source) Pte Ltd, Guud Asset Argon Pte
Ltd, Guud Asset Boron Pte Ltd and Guud Pte Ltd.
“Personal Data” means data and information,
whether true or not, about a person (whether the User or otherwise) who can be
identified from: (a) that data or information; (b) from that data and other
information to which we have or are likely to have access to; and/or (c) the data or
information provide, furnished or uploaded by you in connection with your use of the
Services or the Site, but shall not include any data or information to which the Act
does not apply.
“Platform” shall mean the restricted areas or
parts of the Site accessed by you through the Account (whether on the web, via any
mobile or other computing device or through any mobile applications made available
modified, supplemented, revised or updated from time to time.
“Purposes” mean any one or more of purposes or
reasons set out at Clauses 3.1 to 3.13 below.
“Services” shall mean your use of or access to
the Site or the Platform as requested by you.
“Services Agreement” shall mean the terms and
conditions published at https://www.rytefinance.com/servicesagreement and which
apply to your access to and/or use or operation of the Account and/or Platform.
“Site” means https://www.rytefinance.com
and shall include all other associated websites or webpages within the rytefinance
applicable to the Site published at https://www.rytefinance.com/termsofuse.
“User”, “you” and “yours” means any corporate or natural person that
uses, accesses and/or utilises the Site, Services, Account or Platform including any
individual through which the User accesses, uses and/or utilises the Site, Services,
Account or Platform.
The headings herein for convenience only and shall not affect the interpretation of
Unless the context otherwise requires, references to the singular number shall
include references to the plural number and vice versa, references to natural
persons shall include bodies corporate, and the use of any gender shall include all
Consent: It shall be a condition of your use
of the Site and/or Services that any Personal Data provided, furnished, uploaded or
otherwise disclosed by you to us (whether through the Site or otherwise) is:
Made with your consent or the consent of the individual(s) identified by or
in the Personal Data unless such consent is revoked in accordance with
Clause 5 below.
Provision: We collect Personal Data when you
voluntarily provide it to us. For example, you may provide Personal Data (such as
identification, contact, employment and/or financial information) to us when you:
Provide us with information or documents when creating a user profile or
completing the applicable registration forms in connection with an
application for the Services;
Verify your identity and/or credentials through various means (including,
where applicable, through your Corppass Account) when you access, log into
and/or operate the Account;
Access, utilise or operate Services or Platform available on or facilitated
through the Site.
Collection: Depending on the nature of your
interaction with us, some examples of Personal Data we may collect from you include
but are not limited to:
Your name, identification information or government issued identification
Place and date of birth or incorporation;
Contact information such as your address, email address or telephone number,
nationality, gender, date of birth, marital status, photographs and other
Corporate or shareholder information including annual returns, financial
statements, audited accounts, list and details of members and information,
details, notices or resolutions lodged by you or on your behalf with the
Accounting and Corporate Regulatory Authority of Singapore or such other
government or regulatory authority as may be applicable;
Employment and/or financial information such as credit card numbers, debit
card numbers or bank account information such as bank account details, bank
statements and credit history;
Where applicable, all such Personal Data of any of your directors, officers,
agents, employees or representatives (howsoever described); or
Information provided, furnished and/or uploaded by you to us in connection
with your access or use of the Site and/or the Services constituting
Collection, Use and Storage
You agree and consent to the Group’s collection, use and storage of any Personal Data
you voluntarily provide to us for any or all of the following purposes or reasons
(collectively referred to as the “Purposes”):
Verifying your identity, entitlement or authorisation:
To use or access the Site and/or Account;
Providing the Services requested or applied for by you; and/or
Facilitating and/or processing payments (whether to us or otherwise) and
managing your relationship with the Group;
Executing the operation, fulfilment and administration of the Services and/or
functions or features of the Site such as the Platform;
Conducting or facilitating audits for the purposes of meeting legal requirements,
compliance or industry standards or as may be desirable to enhance the standing,
quality, scope and capacity of the Site and/or Services;
Conducting applicable due diligence or observing our internal know-your-client and
anti-money laundering protocols as may be required, necessary or applicable;
Communicating with you to inform you of changes to the Site, Services and/or our
policies, terms and conditions and other administrative information;
Responding to, handling, and processing queries, requests, applications, or feedback
from you as well as monitoring the Site and/or Services;
To comply with our obligations or to enforce our rights in connection with the Site
and/or Services, including but not limited to complying with any applicable law,
judgment, order, code, standard or regulation and participate in (or co-operate
with) legal, regulatory or administrative proceedings or directions;
Transmitting, sharing, disclosing and/or providing such Personal Data to
unaffiliated third parties, including relevant governmental or regulatory
authorities, whether in Singapore or abroad, for the Purposes;
Protecting and safeguarding the operation of the Site and/or Services including
preventing, detecting, reporting and supporting or assisting in investigations into
any crime (including fraud, theft, money laundering, terrorism misuse or abuse of
the Site and/or the Services), cybersecurity incidences or risks, or any of the same
Conducting data analytics, including (but not limited to) matching and profiling you
to provide you with features and functions of the Site and/or the Services which may
be relevant or of interest to you and to improve your user experience and for the
purposes of enhancing the Site or the Services or developing new product or service
offerings provided by the Group; and
Any other purposes or reasons for which you have provided the information, including
any other incidental business, marketing or commercial purposes related to or in
connection with the Purposes; and
In relation to this Clause 3 (and its sub-clauses), Personal Data protected by the
Act will be aggregated and/or anonymized, such that no one individual can be
identified or recognized from the user statistics in question. You acknowledge and
agree that any anonymised data is not personal data and that we have the right to
share and disclose such anonymized data with third parties for any purposes.
The Purposes may continue to apply (for such period as may be reasonably necessary)
even in situations where you cease to use the Services or where your access to your
Account and/or your relationship with us has been terminated or altered in any way,
Use, the Services Agreement and/or such other agreements, guidelines or policies as
may be applicable.
You agree and consent to our disclosure of your Personal Data:
To any one or more of the Designated Parties or members of the Group where such
disclosure is required or reasonably necessary for the provision of the Services (in
particular your access to and/or operation of the Account and Platform) or in
connection with managing your relationship with any member of the Group; and
To third party service providers, agents, and other organisations we may engage to
perform any one or more of the Purposes for us.
Withdrawal of Consent
The consent provided at Clause 2 above in relation to the collection, storage, use
and/or disclosure of Personal Data for the Purposes shall remain valid until such
time it is withdrawn by written request submitted to our Data Protection Officer at
the contact details below:
Guud Asset Pte Ltd
2 Tanjong Katong Road
Attention: The Data Protection Officer
Upon receipt of such written request, we may require reasonable time (depending on
the complexity of the request and its impact on our relationship with you) for your
request to be processed and for us to notify you of the consequences of us acceding
to the same, including any legal consequences which may affect your rights and
liabilities to us.
Please note that depending on the nature and scope of your request, we may not be in
a position to continue providing the Services to you and shall, in such
circumstances, notify you before completing the processing of your request. Should
you decide to cancel your withdrawal of consent, please inform us in writing in the
manner described at Clause 5.1 above.
Please note that the withdrawal of consent does not affect our right to continue to
collect, store, use and/or disclose Personal Data where we are permitted or required
to do so under applicable laws.
Access and Correction
If you wish to make (a) an access request for access to a copy of the Personal Data
provided by you or information about the ways in which we use or disclose such
Personal Data; or (b) a correction request to correct or update any of Personal Data
provided by you, you may submit your request in writing or via email to our Data
Protection Officer at the contact details provided at Clause 5.1 above.
Please note that a reasonable fee may be charged for an access request. If so, we
will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be
able to respond to your request within thirty (30) days after receiving your
request, we will inform you in writing within thirty (30) days of the time by which
we will be able to respond to your request. If we are unable to provide you with any
Personal Data or to make a correction requested by you, we shall generally inform
you of the reasons why we are unable to do so (except where we are not required to
do so under the Act).
Protection of Personal Data
To safeguard Personal Data from unauthorised access, collection, use, disclosure,
copying, modification, disposal or similar risks, we have introduced appropriate
administrative, physical and technical measures such as making reasonable security
arrangements to prevent (a) the unauthorised access, collection, use, disclosure,
copying, modification or disposal, or similar risks; and (b) the loss of any storage
medium or device on which personal data is stored.
You should be aware, however, that no method of transmission over the Internet or
method of electronic storage is completely secure. While security cannot be
guaranteed, we strive to protect the security of your information and are constantly
reviewing and enhancing our information security measures.
Accuracy and Retention of Personal Data
In providing the Services, we (and the applicable Designated Parties) may rely on
the information and/or documents provided, furnished and/or uploaded by you, whether
or not such information or documents contain Personal Data.
In the event the information and/or documents provided, furnished and/or uploaded by
you is incorrect or misleading, we reserve the right to take such steps as may be
necessary to protect our rights, including but not limited to commencing legal
proceedings against you.
In order to ensure that the documents and information you have provided us
(including but not limited to your Personal Data) is current, complete and accurate,
please update us if there are changes to your Personal Data by informing our Data
Protection Officer in writing or via email at the contact details provided above at
Transfer or Export of Personal Data
In submitting personal data to us, you agree that the Personal Data may be
transferred or exported to locations in other territories outside of your location
for the purposes of Data Processing by Data Intermediaries.
Where such Personal Data is so transferred or exported, we endeavour to do so in
each instance in accordance with applicable laws and, as far as practicable, require
such Data Intermediaries to comply with all applicable laws and to provide an
equivalent standard of protection for such personal data as such personal data would
have received had the personal data remained in your territory. Such personal data
may be stored in servers operated by third party service providers.
Retention of Personal Data
We may retain your Personal Data for as long as it is necessary to fulfil the
purpose for which it was collected, including one or more of the Purposes, or as
required or permitted by applicable laws.
We will cease to retain your Personal Data or remove the means by which the data can
be associated with you as soon as it is reasonable to assume that such retention no
longer serves the purpose for which the Personal Data was collected and is no longer
necessary for legal or business purposes.
and other similar technologies in connection with your use of the Site and/or
As with most other websites, we collect and use the data contained in log files. The
information in the log files include your IP (internet protocol) address, your ISP
(internet service provider), the browser you used to visit the Site, the time you
visited the Site, and which pages you visited throughout the Site. When you visit or
interact with the Sites or Services, we or our authorized service providers may use
cookies, web beacons, and other similar technologies for collecting and storing
information to help provide you with a better, faster, and safer web experience.
Cookies are small text files (typically made up of letters and numbers) placed in
the memory of your browser or device when you visit a website or view a message.
They allow us to recognise a particular device or browser. Web beacons are small
graphic images that may be included on our Services and the Platform. They allow us
to count users who have viewed these pages so that we can better understand your
preference and interests.
You may be able to manage and delete cookies through your browser or device
settings. However, certain cookies are required to enable core functionality (such
as the submission of any application by you through the Platform), so please note
that changing and deleting cookies may affect the Services and/or functionality
available on the Site.
to Personal Data protected by the Act and shall not include any other information,
data or documents provided, furnished and/or uploaded by you.
Transfer: We generally do not transfer your
Personal Data to countries outside of Singapore. However, if we do so, we will
obtain your consent for the transfer to be made and we will take steps to ensure
that your Personal Data continues to receive a standard of protection that is at
least comparable to that provided under the Act.
applies in conjunction with such other notices, contractual clauses and/or consent
clauses that apply in relation to the collection, use, disclose, store, transfer
and/or otherwise process collection, storage, use, disclosure and/or processing of
your Personal Data by us and is not intended to override them unless we state
Acknowledgment and Acceptance: As stated
above, we reserve the right to change, modify, revise and/or supplement this Privacy
Policy at any time and in any manner as we may, in our sole absolute discretion,
think fit. You may determine if any such revision has taken place by referring to
Site and/or the Services constitutes your acknowledgement and acceptance of such
Indemnity: Without prejudice to any other
indemnify and hold us (and any of our affiliates, members, directors, officers,
employees and agents, collectively, the “Indemnified
Parties”) from and against any claim, demand, loss, damage, cost, or
liability (including legal costs and expenses on an indemnity basis) which any of
the Indemnified Parties may suffer or suffers in connection with or arising from
User’s Duties and Responsibilities
You shall be solely responsible for maintaining the security and
confidentiality of any personal data provided, furnished and/or uploaded by
or through you (including, without limitation, any user credentials).
Further, where any of the Site and/or Services is installed or accessed via
any device, you agree that you will safeguard the access to the use of the
same on that device by applying security measures as may be reasonably
We will not be responsible for any unauthorised use of the Site and/or
Services by you, users who act on your behalf or any unauthorised users. It
is your responsibility to make your own informed decisions about the use of
the Services and take necessary steps to prevent any misuse of the Services.
Minors: We do not provide the Services to
minors and, accordingly, do not knowingly collect any minor’s personal data. You
hereby confirm and warrant that you are above the age of majority, and you are
Other Sites: The Site may contain links to
other websites operated by other parties, such as our business affiliates, merchants
or payment gateways. We are not responsible for the privacy practices of websites
operated by these other parties. You are advised to check on the applicable privacy
policies of those websites to determine how they will handle any information they
collect from you.
Third Parties: Save for the rights of the
Indemnified Parties who are entitled to enforce Clause 12.5 above, a person who is
(Rights of Third Parties) Act (Cap. 53B) to enforce any of its terms and conditions.
governed by and construed in accordance with Singapore law.
Dispute Resolution: Any dispute arising out
of or in connection with this Services Agreement, including any question regarding
its existence, validity or termination, shall be referred to and finally resolved by
arbitration in Singapore in accordance with the Arbitration Rules of the Singapore
International Arbitration Centre for the time being in force, which rules are deemed
to be incorporated by reference in this clause. The Tribunal shall consist of a
single arbitrator and the language of the arbitration shall be English.
Effective date : 8 Jul 21
Last updated : 8 Jul 21