Privacy

Last Updated: 02/06/2026

This Privacy Policy explains how Vision Technologies Pte. Ltd. collects, uses, discloses, stores, protects and processes personal data in connection with the FinStyle platform and related services.

Please read this Privacy Policy carefully before accessing or using FinStyle. By accessing or using FinStyle, registering an account, submitting information, using our calculators or tools, interacting with our services, using our portals, submitting an enquiry, redeeming an offer, registering for an event, or otherwise providing personal data to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use and disclosure of your personal data as described in this Privacy Policy, unless otherwise notified to you.

This Privacy Policy applies together with our Terms of Use, any consent clauses, application forms, account registration forms, enquiry forms, campaign forms, merchant terms, adviser portal terms, partner terms, and other documents or notices that apply to your use of FinStyle.

 

1. Who We Are

Vision Technologies Pte. Ltd. (“Vision Technologies”, “we”, “us” or “our”) is a Singapore-based company that owns and operates FinStyle.

FinStyle is a financial and lifestyle portal that may include, without limitation, mobile applications, websites, web portals, consumer portals, adviser portals, backend portals, merchant portals, calculators, educational content, fintech tools, portfolio features, dashboards, forms, campaigns, events, promotions, merchant pages, partner pages, push notifications, in-app notifications, referral functions, marketing services, and other related services and features.

In this Privacy Policy, we refer to these collectively as the “FinStyle Services”.

 

2. Important Clarification on Professional Services

Vision Technologies and FinStyle do not provide financial advisory services, insurance advice, investment advice, medical advice, legal advice, tax advice, estate planning advice, or any other regulated or professional advice, unless expressly stated and permitted by applicable law.

From time to time, insurance products, financial services, medical services, legal services, trust services, mortgage services, educational services, lifestyle services, merchant services, and other professional or partner services may be featured, promoted, introduced, referred or made available through the FinStyle Services.

Such services are provided by the relevant licensed, exempt, authorised, qualified or otherwise responsible third-party partner, and not by Vision Technologies or FinStyle, unless expressly stated otherwise.

For example:

(a) financial advisory services, financial review sessions, insurance advice, investment advice, product recommendations, and related regulated financial services may be provided by licensed or exempt financial advisory firms, their authorised representatives, insurers, investment platforms, banks, fund platforms, or other financial services partners;

(b) Manulife Financial Advisers Pte Ltd (“Manulife Financial Advisers”) is one of our financial services partners. We may work with Manulife Financial Advisers and its representatives to arrange financial review sessions, conduct marketing campaigns, support client engagement, and refer user enquiries or consented leads for follow-up;

(c) iFAST Financial Pte Ltd (“iFAST”) is one of our financial platform partners. Where authorised, we may receive, retrieve, access, display, store or process client information from iFAST for FinStyle consumer users who have an iFAST account. Such iFAST account may or may not be linked to a financial adviser or representative who is an ambassador, adviser or user on FinStyle; and

(d) medical, legal, trust, tax, mortgage, education, merchant, lifestyle and other professional services are provided by the relevant third-party partners or service providers, under their own terms, privacy policies, professional duties and legal obligations.

Where a third-party partner follows up with you directly, provides services to you, processes your application, enters into an agreement with you, or collects personal data from you directly, that third-party partner may process your personal data under its own privacy policy, contractual terms, professional duties, regulatory obligations and relationship with you.

 

3. FinStyle Ambassadors, Advisers and Portal Users

FinStyle may work with selected financial advisers, financial representatives, professionals, partner representatives, merchants, business partners and other authorised users who are given access to relevant FinStyle portals, tools, dashboards or campaign functions.

These persons may be referred to as “FinStyle Ambassadors”, “ambassadors”, “advisers”, “representatives”, “portal users” or similar terms.

A FinStyle Ambassador is not necessarily an employee, agent or representative of Vision Technologies. A FinStyle Ambassador may be an independent professional, a representative of a financial advisory firm, a representative of Manulife Financial Advisers, a merchant representative, a business partner representative, or another authorised user participating in the FinStyle ecosystem.

Where a FinStyle Ambassador or authorised portal user is involved in your account, enquiry, campaign, event, referral, servicing relationship, merchant interaction or partner interaction, we may allow that person to access, use or process only the personal data reasonably relevant to the applicable purpose, subject to role-based access controls, platform permissions, contractual obligations, professional duties and applicable law.

For example, an authorised financial adviser or representative may be able to access information relevant to adviser servicing, portfolio review, financial review arrangements, client engagement or consented follow-up. An authorised merchant user may be able to access information relevant to deal listings, redemptions, fulfilment, enquiries or merchant portal administration.

FinStyle Ambassadors, advisers, representatives, merchants, partners and portal users must only access, use, disclose and process personal data for authorised purposes and in accordance with applicable law, contractual obligations, professional duties and our platform rules.

 

4. Our Commitment to Data Protection

Vision Technologies complies with the Singapore Personal Data Protection Act 2012 (“PDPA”) in respect of the collection, use, disclosure, storage and processing of your personal data.

In particular, we will take reasonable steps to ensure that:

(a) personal data is collected only by fair, proper and lawful means;

(b) personal data is collected, used and disclosed only for purposes that have been notified to you, for which consent has been obtained where required, or where otherwise permitted or required under the PDPA or applicable law;

(c) personal data collected and used by us is accurate and complete, where such personal data is likely to be used by us to make a decision that affects you, or disclosed by us to another organisation;

(d) personal data in our possession or under our control is protected by reasonable security arrangements against unauthorised access, collection, use, disclosure, copying, modification, disposal, loss or similar risks;

(e) personal data is made available only to authorised personnel, representatives, service providers, data intermediaries, financial partners, advisers, ambassadors, merchants or other partners who require such access for authorised purposes;

(f) personal data is retained only for as long as necessary for legal, regulatory, contractual, business, operational or other legitimate purposes, and is thereafter deleted, destroyed, anonymised or de-identified where appropriate; and

(g) you have the right to request access to and correction of your personal data in accordance with the PDPA and the procedures set out in this Privacy Policy.

 

5. What Personal Data Means

In this Privacy Policy, “personal data” has the meaning given to it under the PDPA. It refers to data, whether true or not, about an individual who can be identified:

(a) from that data; or

(b) from that data and other information to which an organisation has or is likely to have access.

Examples of personal data may include your name, identification number, date of birth, contact details, financial information, account information, images, recordings, device information, transaction records, enquiry records, and other information that can identify you.

 

6. Who This Privacy Policy Covers

This Privacy Policy applies to personal data that we collect, use, disclose, store or process in connection with the FinStyle Services.

This includes personal data relating to:

(a) consumer users of the FinStyle mobile application, website, calculators, educational content, fintech tools, portfolio features, partner pages, campaigns, events and related services;

(b) financial advisers, financial representatives, ambassadors, managers, representatives, administrative users and other users of our adviser portal, backend portal or related business tools;

(c) merchants, merchant representatives, outlet managers, business partners, service providers and users of our merchant portal or partner tools;

(d) visitors to our websites, landing pages, event pages, partner pages, campaign pages and online forms;

(e) prospects, leads, event attendees, referral form users, calculator users, enquiry submitters and persons who interact with our marketing campaigns;

(f) job applicants, contractors, vendors and other individuals who interact with Vision Technologies; and

(g) individuals whose personal data is provided to us by another person, such as family members, dependants, nominees, beneficiaries, employees, clients, referrals, representatives or contact persons.

 

7. How We Collect Personal Data

We may collect personal data in several ways, including:

(a) when you download, access, register for, log into or use the FinStyle mobile application, website or portals;

(b) when you create, update or manage a FinStyle account;

(c) when you use our calculators, simulations, educational tools, financial planning tools, fintech tools, forms, dashboards, portfolio features or other digital features;

(d) when you provide information to us through forms, onboarding flows, enquiry forms, account settings, profile pages, campaign pages, event registration pages, calculator flows, surveys, feedback forms, support channels or other submission channels;

(e) when you submit an enquiry, request a consultation, request a call-back, register for an event, redeem an offer, apply for a product or service, use a partner code, use a referral code, click “I’m interested”, complete a calculator and request follow-up, or otherwise indicate interest in a product, service, event, campaign, offer or partner;

(f) when you communicate with us by email, telephone call, SMS, WhatsApp, Telegram, social media, direct messaging platform, push notification, in-app message, chatbot, customer support channel or other communication channel;

(g) when you interact with our marketing campaigns, advertisements, social media pages, landing pages, webinars, physical events, workshops, partner events or promotional activities;

(h) when you redeem, purchase, book, register for or enquire about merchant offers, products, services, events or promotions through FinStyle;

(i) when you use our adviser portal, backend portal, merchant portal or other business tools;

(j) when financial advisers, financial representatives, merchants, partners, service providers, platforms or other authorised parties provide information to us in connection with the FinStyle Services;

(k) when we receive, retrieve, access, display, store or process information from iFAST, Manulife Financial Advisers, insurers, investment platforms, financial institutions, fund platforms, advisers, representatives, merchants, partners, service providers or other authorised sources;

(l) when we collect information automatically through cookies, analytics tags, pixels, web beacons, software development kits, device identifiers, logs, crash reports, diagnostic tools and similar technologies; and

(m) when you apply for a job, contractor role, partnership, merchant listing, adviser onboarding, business relationship or other arrangement with us.

 

8. Personal Data We May Collect

Depending on your relationship with us and your use of the FinStyle Services, we may collect, use, disclose, store or process the following categories of personal data.

 

8.1 Identification and Contact Information

This may include your name, alias, address, email address, telephone number, mobile number, date of birth, age, gender, nationality, marital status, occupation, employer, company name, job title, and other contact or profile information.

 

8.2 Government-Issued Identification Information

Where required or provided, this may include NRIC number, passport number, foreign identification number, birth certificate number, tax identification number, work pass details, identification document copies, and other identity verification information.

 

8.3 Account and Authentication Information

This may include username, password, login credentials, authentication records, verification codes, security settings, account preferences, device identifiers, IP address, login history, access logs, consent records and communication preferences.

 

8.4 Financial Portfolio and Product Information

This may include information relating to your insurance policies, investment holdings, fund holdings, financial products, portfolio summaries, transaction records, account information, premium information, policy details, product details, investment platform information, bank account information, credit card information, payment information, assets, liabilities, income, salary, expenditure, savings goals, financial objectives, risk profile, investment knowledge, risk tolerance, financial needs, protection needs, retirement needs, estate planning needs and other financial planning or portfolio information.

 

8.5 Information From Financial Partners and Platforms

Where authorised, we may receive, retrieve, access, display, store or process information from financial partners, financial advisory partners, insurers, investment platforms, fund platforms, banks, advisers, representatives or other authorised sources.

This may include information from iFAST for FinStyle consumer users who have an iFAST account, whether or not such iFAST account is linked to a financial adviser who is an ambassador, adviser or user on FinStyle.

This may also include information relating to enquiries, referrals, marketing campaigns, financial review sessions, client engagement and follow-up involving Manulife Financial Advisers or its representatives.

 

8.6 Adviser, Representative, Ambassador and Servicing Information

This may include the identity of your servicing adviser, financial representative, relationship manager, financial advisory firm, ambassador, manager, support personnel, servicing history, appointment details, enquiry records, notes, follow-up records, event records, campaign participation, client engagement records and records relating to requested services.

For adviser, representative, ambassador and portal users, this may also include professional details, firm details, representative codes, business contact details, access rights, portal usage records, campaign participation, client engagement activity, referral activity, appointment records, training records, compliance records and related information.

 

8.7 Calculator, Tool and Educational Content Information

When you use calculators, simulations, educational tools, financial planning tools, retirement tools, mortgage tools, insurance tools, investment tools, fintech tools or similar features, we may collect and save the inputs you provide, outputs generated, assumptions used, results shown, usage history, tool interactions and related analytics.

Such calculator and tool data may be saved by default and associated with your account, device, profile, enquiry or session, where applicable.

 

8.8 Merchant, Promotion and Transaction Information

This may include merchant offer redemptions, product enquiries, service bookings, event registrations, purchases, payment records, refund records, transaction records, partner codes, referral codes, campaign codes, fulfilment details, outlet details, appointment details, reward redemption details and related interactions.

 

8.9 Marketing and Consent Information

This may include your marketing preferences, consent records, opt-in and opt-out records, DNC-related records, communication preferences, campaign engagement, advertisement interactions, email engagement, push notification interactions, social media interactions, remarketing preferences and responses to promotions.

 

8.10 Communication and Support Information

This may include enquiries, complaints, feedback, survey responses, customer support records, chatbot interactions, emails, telephone call records, WhatsApp messages, Telegram messages, SMS messages, direct messages, in-app messages and other correspondence with us or our partners.

 

8.11 Images, Recordings and Event Information

This may include photographs, videos, CCTV footage, voice recordings, call recordings, event photographs, webinar recordings, workshop recordings, screen recordings, electronic communications and other media records, where collected in connection with our services, events, training, quality assurance, customer support, compliance, security or business operations.

 

8.12 Family, Dependant, Nominee and Third-Party Information

This may include information relating to your spouse, children, dependants, nominees, beneficiaries, family members, employees, clients, referrals, representatives or other third parties, where you provide such information for financial planning, portfolio management, family sharing, nomination, referral, application, event, merchant, professional service or related purposes.

 

8.13 Technical, Device, Analytics and Usage Information

This may include device type, mobile device identifier, operating system, browser type, IP address, location information where enabled, app activity, website activity, pages or screens viewed, links clicked, time spent, referring website, crash logs, diagnostic data, cookies, analytics tags, software development kits, pixels, web beacons and similar technology information.

 

8.14 Merchant, Adviser and Business Portal Information

For advisers, representatives, ambassadors, merchants and business users, this may include business contact details, company information, outlet information, licence or registration information, professional details, access rights, portal activity, listing details, product and deal submissions, campaign performance, user roles, approval records, support records and transaction-related information.

 

8.15 Recruitment, Vendor and Business Relationship Information

Where relevant, this may include resumes, employment history, education history, qualifications, background check information, references, interview records, contractor information, vendor contact information, business proposals and related information.

 

9. Third-Party Personal Data Provided By You

If you provide us with personal data relating to another individual, including a spouse, child, dependant, nominee, beneficiary, family member, employee, client, referral, representative, customer, outlet manager or contact person, you confirm, represent and warrant that:

(a) you have obtained the necessary consent or authority to disclose such personal data to us;

(b) the individual has consented to our collection, use, disclosure, storage and processing of such personal data for the relevant purposes set out in this Privacy Policy;

(c) the personal data provided is accurate and complete to the best of your knowledge; and

(d) you will inform the individual of this Privacy Policy where appropriate.

If you do not have the necessary consent or authority, you should not provide that individual’s personal data to us.

 

10. How We Use Personal Data

The purposes for which we collect, use, disclose, store and process personal data will vary depending on your relationship with us, your use of the FinStyle Services, your relationship with our partners, and the services, tools, enquiries, referrals, promotions or transactions you request.

We may use personal data for the following purposes.

 

10.1 Account, Platform and Service Operation

We may use personal data:

(a) to verify your identity and uniquely identify you;

(b) to create, administer, manage, secure and maintain your FinStyle account;

(c) to provide access to the FinStyle mobile application, website, portals, dashboards, calculators, tools, content, forms, campaigns, merchant pages and partner pages;

(d) to operate, maintain, improve, troubleshoot and update the FinStyle Services;

(e) to authenticate users, prevent unauthorised access and protect account security;

(f) to provide customer support, technical support and service assistance;

(g) to communicate with you regarding your account, security, service updates, support requests, transactions, enquiries, events, redemptions and other service-related matters; and

(h) to enforce our terms, policies and user obligations.

 

10.2 Financial Portfolio, Platform Data and Adviser Servicing

We may use personal data:

(a) to receive, retrieve, access, display, store, update and process information relating to your financial portfolio, insurance policies, investment holdings, fund holdings, transactions and financial products;

(b) to display financial portfolio information, policy information, investment information and other relevant information through the FinStyle Services;

(c) to support adviser servicing, relationship management, client engagement, portfolio reviews, policy reviews, investment reviews, financial planning discussions, follow-up actions and related administrative support;

(d) to support authorised financial advisers, representatives, ambassadors, managers or support personnel in providing services or follow-up requested by you;

(e) to process information received from iFAST, Manulife Financial Advisers, insurers, investment platforms, financial institutions, fund platforms, advisers, representatives or other authorised sources;

(f) to reconcile, verify, update or maintain portfolio, account or servicing information; and

(g) to comply with applicable legal, regulatory, contractual, operational and compliance requirements.

 

10.3 Calculators, Educational Content and Fintech Tools

We may use personal data:

(a) to provide calculators, simulations, educational content, financial planning tools, retirement tools, mortgage tools, insurance tools, investment tools, fintech tools and other digital features;

(b) to save your calculator inputs, assumptions, generated outputs, results, usage history and tool interactions by default, where applicable;

(c) to allow you to retrieve, review or continue previous calculations, results or tool sessions;

(d) to personalise educational content, tool suggestions, app experience and relevant communications;

(e) to improve our calculators, tools, content, user experience, product design and service offerings;

(f) to conduct analytics, research, product development, campaign measurement and business planning; and

(g) where you request or consent to follow-up, to assist the relevant partner, adviser or representative in following up with you regarding the topic, product or service related to the calculator or tool.

Calculator results, educational content, articles, guides, simulations and tools provided through FinStyle are for general information, education and convenience only. They do not constitute financial advice, insurance advice, investment advice, legal advice, medical advice, tax advice or other professional advice, unless expressly provided by the relevant licensed, exempt, authorised or qualified professional or partner.

 

10.4 Enquiries, Referrals, Partner Follow-Up and Marketing Services

FinStyle may operate as a platform for users to discover, compare, enquire about, register for, redeem or access offers, events, services, promotions, financial review sessions, financial advisory services, merchant services, lifestyle benefits, professional services and partner services.

Where you submit an enquiry, request a consultation, request a financial review, request a call-back, register for an event, redeem an offer, use a partner code, use a referral code, click “I’m interested”, complete a calculator and request follow-up, apply for a product or service, participate in a campaign, or otherwise indicate interest or provide consent through the FinStyle Services, we may use your personal data:

(a) to administer, facilitate, track, transmit and follow up on that enquiry, referral, registration, redemption, campaign, application or request;

(b) to disclose the relevant personal data to the relevant partner so that the partner may contact you directly, process your request, provide information, fulfil the offer, administer the event, arrange an appointment, process the application, perform advisory follow-up or provide the relevant service;

(c) to support Manulife Financial Advisers and its representatives in arranging financial review sessions, marketing campaigns, client engagement, lead follow-up and related services where you have indicated interest or provided consent;

(d) to support merchants and partners in fulfilling offers, redemptions, bookings, purchases, services, appointments, rewards and promotions requested by you;

(e) to track campaign source, referral source, partner code, referral code, conversion status and fulfilment status;

(f) to process payments, refunds, service fees, platform fees, commissions, transaction fees, rewards and related amounts; and

(g) to respond to your enquiries, instructions, feedback, complaints or requests.

For most partner referrals and follow-up, we will require a user action, request or specific consent. We do not sell bulk user data to third parties.

 

10.5 Marketing, Communications and Personalisation

With your consent, or where permitted by applicable law, we may use personal data:

(a) to send you information, updates, invitations, promotions, rewards, privileges, educational content, financial planning content, merchant offers, partner offers, event invitations, campaign materials and other marketing communications that may be relevant to you;

(b) to personalise your app experience, content, tools, offers, recommendations, campaigns, advertisements and communications;

(c) to analyse customer behaviour, user preferences, usage patterns, market trends and campaign performance;

(d) to conduct customer profiling, segmentation, market research, surveys, statistical analysis and business planning;

(e) to display relevant in-app offers, partner content, merchant deals, educational materials and product-related content;

(f) to conduct remarketing, retargeting, audience matching, lookalike audience creation, social media custom audience campaigns and similar advertising activities, where permitted by law and your consent settings; and

(g) to measure the effectiveness of our marketing, advertisements, campaigns, events, partner pages and referral activities.

Marketing communications may be sent by email, SMS, WhatsApp, phone call, push notification, in-app notification, Telegram, social media, direct messaging platforms, remarketing advertisements, custom audience advertisements or other communication channels, subject to applicable law, your consent and your communication preferences.

 

10.6 Security, Fraud Prevention and Compliance

We may use personal data:

(a) to diagnose, monitor and prevent service, security or technical issues;

(b) to detect, investigate, prevent and respond to fraud, unauthorised activity, misuse, security incidents, data breaches, prohibited activity, unlawful activity or improper conduct;

(c) to protect the safety, integrity, rights and interests of Vision Technologies, FinStyle, users, partners, merchants, advisers, employees and third parties;

(d) to conduct audit reviews, compliance monitoring, risk management, internal controls, governance and record keeping;

(e) to conduct checks against internal suppression lists, DNC records, consent records and marketing preference records;

(f) to comply with legal, regulatory, contractual, audit, tax, accounting, reporting, court, law enforcement, statutory, governmental, industry or professional requirements, whether in Singapore or elsewhere;

(g) to comply with anti-money laundering, counter-terrorism financing, sanctions, fraud prevention, anti-bribery, anti-corruption, tax, regulatory reporting and similar requirements where applicable; and

(h) to cooperate with regulators, government authorities, law enforcement agencies, courts, dispute resolution bodies, professional bodies and industry bodies where required or permitted by law.

 

10.7 Business Operations and Transactions

We may use personal data:

(a) for internal administrative purposes;

(b) to manage our business operations, service providers, partners, merchants, advisers, representatives, ambassadors, campaigns, events and portals;

(c) to conduct training, quality assurance, service monitoring, business reporting and performance reviews;

(d) to maintain internal records, transaction records, consent records, audit trails and system logs;

(e) to develop, test, improve and launch new features, tools, products, content, campaigns and services;

(f) to exercise or defend legal rights, enforce our terms, recover debts, resolve disputes and protect our business;

(g) to enable an actual or proposed assignee, transferee, investor, acquirer, purchaser, participant or sub-participant of our rights, business, assets or obligations to evaluate or carry out any proposed transaction; and

(h) for any other purpose which we notify you of at the time of collection, or which is permitted or required under the PDPA or applicable law.

 

11. Financial Data, Personalisation and Merchant Data Boundaries

FinStyle may use your financial portfolio information, insurance policy information, investment information, calculator data, tool data, profile information, app usage, communication preferences, enquiry history, redemption history, event participation and interactions within the FinStyle ecosystem to personalise your FinStyle experience, display relevant educational content, provide useful tools, support adviser servicing, recommend relevant in-app content, improve our services and support your requested interactions.

However, unless you specifically request, authorise or consent to such disclosure for a specific service, enquiry, referral, transaction or follow-up:

(a) merchants, lifestyle partners, medical partners, legal partners, education partners and advertising partners will not receive your detailed financial portfolio information, insurance policy details, investment holdings or financial product information for their direct marketing purposes; and

(b) we will not disclose your detailed financial portfolio information to non-financial merchants or lifestyle partners merely because they participate in the FinStyle ecosystem.

Where aggregated, anonymised or de-identified data is used for analytics, reporting, product development, business planning, campaign measurement or service improvement, we will take reasonable steps to ensure that such data does not identify you.

 

12. To Whom We May Disclose Personal Data

Personal data held by us will be kept confidential. However, we may disclose or transfer personal data to the following persons or entities, whether located in Singapore or outside Singapore, for one or more of the purposes set out in this Privacy Policy.

We will only disclose personal data that is reasonably necessary or relevant for the stated purpose.

 

12.1 Vision Technologies and Related Parties

We may disclose personal data to our directors, officers, employees, authorised personnel, contractors, agents, representatives, professional advisers, consultants, auditors, service providers, related corporations, affiliates, business units and authorised support teams.

 

12.2 Financial Partners, Professional Partners and Adviser Servicing

Where required or authorised for the relevant FinStyle Service, we may disclose relevant personal data to:

(a) iFAST, where required or authorised in connection with displaying, retrieving, storing, updating, reconciling or supporting portfolio, fund, transaction, account or platform information for FinStyle consumer users who have an iFAST account;

(b) Manulife Financial Advisers, its authorised representatives and support personnel, where required or authorised in connection with user enquiries, consented referrals, financial review sessions, adviser servicing, client engagement, marketing campaigns, portfolio reviews, follow-up, compliance, reporting or related purposes;

(c) financial institutions, insurers, investment platforms, fund platforms, banks, mortgage providers, financial advisory firms, authorised representatives and other financial services partners, where you have requested, applied for, enquired about, consented to, or are receiving a product, service, review, referral, campaign, event or follow-up involving such party; and

(d) legal, tax, trust, estate planning, medical, education, merchant, lifestyle and other professional or service partners, where you have requested, applied for, enquired about, registered for, redeemed, consented to, or are receiving a product, service, event, offer, referral or follow-up involving such party.

We will disclose only the personal data that is reasonably relevant for the applicable purpose, such as account display, service fulfilment, enquiry follow-up, appointment arrangement, application processing, referral tracking, compliance, reporting, support or transaction administration.

Unless you specifically request, authorise or consent to such disclosure for a specific service, enquiry, referral, transaction or follow-up, we will not disclose your detailed financial portfolio information, insurance policy details, investment holdings or financial product information to merchants, lifestyle partners, medical partners, legal partners, education partners or advertising partners for their direct marketing purposes.

 

12.3 Ambassadors, Advisers, Representatives and Portal Users

Where required or authorised for the relevant FinStyle Service, we may disclose relevant personal data to authorised FinStyle Ambassadors, advisers, representatives, managers, administrative users, merchant users, partner users and other portal users.

Such disclosure or access will generally be limited to personal data reasonably relevant to the person’s authorised role, such as adviser servicing, financial review arrangements, consented follow-up, campaign administration, client engagement, merchant fulfilment, support, reporting, portal administration, compliance or transaction administration.

A FinStyle Ambassador or authorised portal user may also be subject to his or her own professional, regulatory, contractual or employment obligations, depending on whether the person acts independently, as a representative of a partner, as a representative of a financial advisory firm, as a representative of Manulife Financial Advisers, as a merchant representative, or in another authorised capacity.

 

12.4 Merchants, Lifestyle Partners and Professional Service Partners

We may disclose personal data to merchants, lifestyle partners, healthcare partners, medical service providers, education partners, event partners, legal service providers, trust service providers, mortgage partners, service providers and other business partners participating in the FinStyle ecosystem, but only to the extent relevant to the offer, enquiry, registration, redemption, transaction, service, event, fulfilment, referral or follow-up that you have requested, consented to or interacted with.

 

12.5 Technology, Hosting, Analytics and Operational Service Providers

We may disclose personal data to technology providers, cloud service providers, hosting providers, data storage providers, software providers, analytics providers, customer data platform providers, cybersecurity providers, payment processors, customer support providers, communications providers, marketing service providers, advertising platforms, IT support providers, data processing providers and other outsourced service providers or data intermediaries.

When we engage service providers or data intermediaries to process personal data on our behalf, we will require them to process such personal data only for authorised purposes and to protect the personal data in accordance with applicable data protection obligations.

 

12.6 Marketing and Advertising Partners

Where permitted by law and your consent settings, we may disclose personal data to marketing partners, advertising platforms, advertising networks, social media platforms, analytics providers and remarketing service providers for purposes such as personalised advertisements, campaign measurement, audience matching, custom audience creation, lookalike audience creation, retargeting, remarketing and marketing analytics.

We do not sell bulk user data to third parties.

 

12.7 Payment, Fulfilment and Transaction Parties

We may disclose personal data to parties involved in payment processing, settlement, refunds, transaction fulfilment, reward fulfilment, accounting, reconciliation, audit, reporting, fraud prevention, dispute handling and related activities.

 

12.8 Regulators, Authorities and Legal Parties

We may disclose personal data to regulators, statutory boards, government authorities, law enforcement agencies, courts, dispute resolution bodies, tax authorities, professional bodies, industry bodies, public agencies and other persons or organisations to whom disclosure is required or permitted under applicable laws, regulations, rules, codes of practice, guidelines, directions, court orders, regulatory requirements, governmental requirements, statutory requirements or industry requirements, whether within or outside Singapore.

 

12.9 Corporate Transactions

We may disclose personal data to any actual or proposed assignee, transferee, investor, acquirer, purchaser, participant, sub-participant, successor, purchaser of assets, merger partner or other party involved in an actual or proposed business transfer, restructuring, financing, investment, acquisition, sale, merger or similar transaction, and their advisers or representatives.

 

12.10 Persons Authorised By You

We may disclose personal data to any person or entity to whom you have authorised or consented to disclosure, or to whom disclosure is permitted or required under the PDPA or applicable law.

 

13. Partner Products, Partner Services and Referrals

The FinStyle Services may allow you to enquire about, register for, redeem, apply for, access or be introduced to products or services provided by third-party partners.

These may include financial review sessions, insurance products, investment-related services, mortgage services, banking services, legal services, trust services, medical services, education services, merchant offers, lifestyle services, events, promotions and other partner services.

If you submit an enquiry, request a consultation, request a call-back, register for an event, redeem an offer, apply for a product or service, use a partner code, click through to a partner service, complete a calculator and request follow-up, or otherwise indicate interest through the FinStyle Services, we may transmit the relevant personal data to the relevant partner.

The relevant partner may contact you directly regarding your enquiry, request, application, appointment, event, redemption, product, service, promotion or follow-up.

Where the partner processes your personal data independently, that partner’s own privacy policy, terms of business, professional duties, regulatory obligations and legal responsibilities will apply. You should review the relevant partner’s privacy policy and terms where applicable.

Vision Technologies is not responsible for the independent privacy practices of third-party partners once they collect, use, disclose or process your personal data as independent organisations, except to the extent required under applicable law.

 

14. Direct Marketing, DNC and Opt-Out

With your consent, or where permitted under applicable law, we may use your personal data to send you marketing communications regarding FinStyle, educational content, calculators, tools, campaigns, events, promotions, partner offers, merchant deals, financial planning content, lifestyle privileges and other products or services that may be relevant to you.

We may contact you through email, SMS, telephone call, WhatsApp, Telegram, push notification, in-app notification, direct messaging platform, social media, remarketing advertisement, custom audience advertisement or other communication channels.

We may also use personal data such as your name, contact details, age, location, income range, employment information, browsing history, app usage, calculator usage, requested quotes, enquiries, redemptions, preferences and interactions to provide materials that are more relevant to you.

Where required, we will comply with the Do Not Call provisions under the PDPA when sending marketing messages to Singapore telephone numbers.

If your Singapore telephone number is registered with any applicable Singapore Do Not Call register, we will not send promotional or marketing messages to that number by voice call, text message, fax message or applicable communication application, unless:

(a) you have given clear and unambiguous consent for us to do so;

(b) you have an ongoing relationship with us and the message is permitted under applicable law; or

(c) another exception under applicable law applies.

You may withdraw your marketing consent or opt out of marketing communications at any time by:

(a) using the unsubscribe or opt-out instructions provided in the communication;

(b) adjusting your app or account settings where available;

(c) submitting a request through the relevant form or support channel; or

(d) contacting our Data Protection Officer at [email protected].

After opting out, you may still receive non-marketing messages, such as account messages, security alerts, service notices, transactional messages, portfolio-related updates, adviser servicing messages, legal notices, regulatory messages and administrative communications.

 

15. Cookies, Analytics, Pixels and Similar Technologies

We may use cookies, analytics tags, pixels, web beacons, software development kits, device identifiers, mobile technologies and similar technologies to operate, secure, analyse, personalise and improve the FinStyle Services.

These technologies may collect information such as:

(a) device type, browser type, operating system and device settings;

(b) IP address, mobile device identifier and other technical identifiers;

(c) pages, screens, tools, content, offers and campaigns viewed;

(d) links, buttons, notifications, advertisements and forms interacted with;

(e) time spent on the FinStyle Services;

(f) referring websites or campaign sources;

(g) approximate or precise location information, where enabled or permitted;

(h) calculator usage, tool usage and content engagement;

(i) account, login and session activity; and

(j) diagnostic, crash and performance data.

We may use such information to:

(a) remember your preferences;

(b) keep you logged in or improve login security;

(c) provide and improve calculators, tools, content and services;

(d) study usage patterns and improve user experience;

(e) personalise content, offers and communications;

(f) measure campaign performance;

(g) conduct analytics, research and product development;

(h) detect fraud, abuse, technical issues or security risks; and

(i) conduct remarketing, retargeting, custom audience campaigns and similar advertising activities, where permitted by law and your consent settings.

You may be able to disable or manage cookies through your browser or device settings. However, if you disable cookies or similar technologies, some features of the FinStyle Services may not function properly.

 

16. Location Information

Where location-based features are available, we may collect approximate or precise location information from your device, but only where you have enabled such access or otherwise provided permission.

Location information may be used to provide location-based offers, nearby merchant promotions, event suggestions, service availability, fraud prevention, analytics, personalisation or other relevant features.

You may enable or disable location access through your device settings.

 

17. Accuracy of Personal Data

We will make reasonable efforts to ensure that personal data collected by us or on our behalf is accurate and complete where the personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation.

You are responsible for ensuring that the personal data you provide to us is accurate, complete and up to date.

You should notify us as soon as reasonably practicable if there are changes to your personal data.

We may not be responsible for any loss, damage, delay, error or issue caused by inaccurate, incomplete or outdated personal data provided by you or by a third party acting on your behalf.

 

18. Access and Correction of Personal Data

You may request access to or correction of personal data that is in our possession or under our control.

If you wish to make an access or correction request, please contact our Data Protection Officer at [email protected].

To help us process your request, please provide sufficient details to identify you and the personal data requested.

We may need to verify your identity before processing your request.

For access requests, we will respond within a reasonable time in accordance with the PDPA. Where permitted by law, we may charge a reasonable administrative fee for processing an access request. If a fee is payable, we will inform you of the estimated fee before processing the request.

For correction requests, we will correct the personal data as soon as practicable unless we have reasonable grounds not to do so. Where required and practicable, we may also send corrected personal data to organisations to which the personal data was disclosed within the relevant period, unless such correction is not necessary or an exception applies.

There may be circumstances where we are not required or permitted to provide access to or correction of personal data under the PDPA or applicable law.

 

19. Withdrawal of Consent

You may withdraw your consent for the collection, use or disclosure of your personal data by contacting our Data Protection Officer at [email protected] or through the relevant account setting, form or support channel where available.

Please state clearly the consent you wish to withdraw.

We will process your withdrawal request within a reasonable time. After processing your request, we will stop collecting, using or disclosing your personal data in the manner stated in your withdrawal request, unless such collection, use or disclosure is required or permitted under the PDPA or applicable law.

Please note that withdrawal of consent may affect our ability to provide some or all of the FinStyle Services to you. For example:

(a) if you withdraw consent for account-related processing, we may not be able to maintain your FinStyle account;

(b) if you withdraw consent for financial portfolio data processing, we may not be able to display your portfolio information or support related features;

(c) if you withdraw consent for partner referral disclosure, the relevant partner may not be able to follow up on your enquiry or request;

(d) if you withdraw consent for calculator data storage, some saved calculator history or personalised tool features may not be available, subject to technical capability; and

(e) if you withdraw marketing consent, you may still receive non-marketing service, security, account, transactional, legal, regulatory or administrative communications.

Withdrawal of consent does not affect our right to continue collecting, using or disclosing personal data where such collection, use or disclosure is required or permitted by law.

 

20. Account Deletion

You may request deletion of your FinStyle account through our account deletion form or other account deletion function made available through the FinStyle Services.

When you submit an account deletion request, we may need to verify your identity and process the request in accordance with our internal procedures, technical requirements, legal obligations, regulatory obligations, contractual obligations and legitimate business purposes.

Upon deletion of your account, we may delete, anonymise, de-identify or restrict access to personal data associated with your account, unless retention is required or permitted for legal, regulatory, contractual, accounting, audit, security, dispute resolution, fraud prevention, business continuity, record keeping or other legitimate purposes.

We may retain aggregated, anonymised or de-identified information that no longer identifies you for analytics, research, statistical, service improvement, business planning or reporting purposes.

If your personal data has been disclosed to third-party partners acting independently, you may need to contact those partners directly regarding access, correction, withdrawal or deletion requests relating to personal data held by them.

 

21. Protection of Personal Data

We will make reasonable security arrangements to protect personal data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal, loss or similar risks.

Such arrangements may include, where appropriate:

(a) access controls and role-based permissions;

(b) authentication and account security measures;

(c) encryption in transit and at rest where appropriate;

(d) audit logs and monitoring;

(e) vulnerability management and security testing;

(f) incident response procedures;

(g) staff training and internal policies;

(h) vendor and service provider management;

(i) backup, business continuity and disaster recovery measures;

(j) data minimisation and retention controls; and

(k) other administrative, technical and organisational safeguards.

However, no method of transmission over the internet or electronic storage is completely secure. While we take reasonable steps to protect personal data, we cannot guarantee absolute security.

You are responsible for keeping your login credentials, password, verification codes and devices secure. You should notify us promptly if you suspect unauthorised access to your account.

 

22. Retention of Personal Data

We will retain personal data for as long as necessary to fulfil the purposes for which it was collected, used or disclosed, or as required or permitted for legal, regulatory, contractual, accounting, audit, tax, dispute resolution, security, business continuity, fraud prevention, operational or other legitimate business purposes.

The retention period may vary depending on the type of personal data, the purpose for which it was collected, the nature of your relationship with us, legal or regulatory requirements, and business needs.

When personal data is no longer required, we will take reasonable steps to delete, destroy, anonymise or de-identify it.

 

23. Overseas Transfers

Your personal data may be transferred to, stored in, processed in or accessed from countries outside Singapore.

This may occur where our service providers, cloud providers, technology providers, data intermediaries, partners, group companies, support teams, professional advisers or other authorised parties are located outside Singapore or use systems located outside Singapore.

Where we transfer personal data outside Singapore, we will take appropriate steps to ensure that the transferred personal data receives a standard of protection comparable to that required under the PDPA, including through contractual safeguards, due diligence, security requirements and other appropriate measures.

 

24. Data Breach Management

In the event of a data breach or suspected data breach involving personal data in our possession or under our control, we will take reasonable steps to assess, contain, investigate and remediate the breach.

Where the breach is notifiable under the PDPA, we will notify the Personal Data Protection Commission and affected individuals as required by law.

We may also notify relevant partners, service providers, regulators, authorities or other parties where required or appropriate for containment, investigation, remediation, legal compliance or user protection.

 

25. Use of the FinStyle Services by Minors

The FinStyle Services are not intended for individuals under the age of 18, unless use is expressly permitted by us and appropriate consent or authority has been obtained from a parent, legal guardian or authorised person.

If you provide personal data relating to a child or minor, you confirm that you are the parent, legal guardian or authorised person, or that you have obtained the necessary consent or authority to provide such personal data to us for the relevant purposes.

We may take additional steps where appropriate to protect children’s personal data.

 

26. Third-Party Websites, Applications and Services

The FinStyle Services may contain links to third-party websites, applications, platforms, forms, payment pages, partner pages, merchant pages, social media pages or other services.

We are not responsible for the privacy practices, content, security or terms of such third-party websites, applications or services, unless otherwise required by law.

You should review the privacy policies and terms of the relevant third-party providers before submitting personal data to them or entering into any transaction with them.

 

27. Adviser Portal and Merchant Portal Users

If you use the FinStyle adviser portal, backend portal, ambassador tools, merchant portal or related business tools, we may collect, use, disclose, store and process your personal data and business contact information for purposes including:

(a) account registration, verification and administration;

(b) user access management and role-based permissions;

(c) portal usage, activity logging and security monitoring;

(d) merchant listing, deal creation, product upload, service management and offer fulfilment;

(e) adviser, representative, ambassador or partner onboarding;

(f) campaign management, event management and client engagement;

(g) reporting, analytics, performance tracking and business operations;

(h) compliance, audit, quality assurance and governance;

(i) communication, support and troubleshooting; and

(j) enforcement of our terms, policies and contractual rights.

Advisers, representatives, ambassadors, merchants, partners and portal users must only access, use, disclose and process personal data for authorised purposes and in accordance with applicable law, contractual obligations, professional duties and our platform rules.

 

28. No Sale of Bulk User Data

We do not sell bulk user personal data to third parties.

Where we disclose personal data to partners, merchants, advisers, ambassadors, service providers or other third parties, such disclosure will be for the purposes described in this Privacy Policy, for purposes notified to you, with your consent where required, or where otherwise permitted or required under applicable law.

For partner referrals, enquiries, campaigns, event registrations, merchant redemptions and professional service follow-up, we generally disclose relevant personal data only where you have taken an action, submitted a request, indicated interest, provided consent or otherwise interacted with the relevant offer, service, campaign, partner or feature.

 

29. Changes to This Privacy Policy

We may revise or update this Privacy Policy from time to time to reflect changes in our services, technology, business model, partners, legal requirements, regulatory requirements or operational practices.

Any updated Privacy Policy will be posted on our website, app or other appropriate channel. The “Last Updated” date will indicate when the Privacy Policy was last revised.

Where changes are material, we may notify you through email, in-app notice, website notice, push notification or other appropriate means. Where required by law, we will seek fresh consent.

Your continued access or use of the FinStyle Services after the updated Privacy Policy takes effect will constitute your acknowledgement of the updated Privacy Policy, unless otherwise required by law.

 

30. Contacting Our Data Protection Officer

If you have any questions, feedback, complaints, requests for access or correction, withdrawal requests, account deletion queries or other concerns regarding this Privacy Policy or the way we handle personal data, you may contact our Data Protection Officer at:

Data Protection Officer Vision Technologies Pte. Ltd. 22 Sin Ming Lane #06-76 Midview City Singapore 573969

Email: [email protected]

Telephone: +65 6807 2088

When contacting us, please provide sufficient details to allow us to understand and respond to your request.

We will review and respond to your request, enquiry or complaint as soon as reasonably practicable.

 

31. Governing Law

This Privacy Policy is governed by the laws of Singapore.

Your rights under this Privacy Policy are subject to the PDPA and other applicable laws.