FUNNELFLOCK PRIVACY POLICY
 
Reventas Pte. Ltd. (company registration 201315684G) (“FunnelFlock”, “us”, “we”, “our”) is a proprietary limited company incorporated in Singapore. We are a platform dedicated to bringing deals and promotions relating to cars to end users. Through our website and/or mobile application (“Platform”), we enable end users to browse, search, and indicate their interest to acquire a car from various merchants.

This Privacy Policy explains how FunnelFlock treats your personal data. By using and accessing FunnelFlock’s platform and/or services, or by dealing with us, you signify that you have read, understood, and agree to be bound by this Privacy Policy, as may be amended from time to time.

 
1. Collection of personal data
 
FunnelFlock only collects personal information that is necessary to carry out its contractual obligations in accordance with legal requirements. The failure to provide FunnelFlock with mandatory personal information may result in FunnelFlock being unable to provide you with the services. Where any information is not necessary, the field will be marked “optional” in the relevant forms.
Personal data may be collected directly from you through the Platform, by email, over the phone, or in person, but only when you voluntarily give it to us.
When you access our Platform, register for an account, subscribe to our updates, use our services, send us correspondence, or submit any comments or feedback, you may be asked to provide information that personally identifies you, including your name, address, identity number, date of birth, age, contact number, email address and personal financial information (including information regarding annual salary and outstanding debts).
In addition, we may collect personal data which is provided or made available by any third parties whom you have authorised, credit reference or reporting bodies, regulatory and law enforcement authorities, for the purposes of providing the services and/or to comply with our legal and regulatory obligations.
The use of the Platform may also include the gathering of data which may at times contain or be associated with personal data. Examples of data which may be collected include: the number of times to visit the Platform, the length of time spent on the Platform, the pages you visit on the Platform, as well as server log data such as your computer or device’s IP address, your preferred browser and the website you visited prior to using the FunnelFlock website. This information can be obtained through the use of cookies. Cookies are a small data file transferred to your device that recognises and identifies your device to allow your device to “remember” information from the Platform for future use. Unless you have elected to remain anonymous through your device and/or the web browser, the abovementioned information may be collected and used by us automatically through your use of the Platform.
 
2. Use of personal data
 
The purposes for which FunnelFlock collects and uses your personal data include: verifying your identity when using the Platform and/or services; preparing and lodging loan application documentation; preparing sales contracts; assisting you with the sale of the car by the car merchant; providing you with customer support and resolving any problems or disputes you may encounter in relation to the Platform or services; complying with legal and regulatory obligations and requirements; accounting, risk management, compliance and record keeping purposes; research and evaluation purposes; staff training; investigating any fraudulent, illegal or prohibited activities or misuse of the Platform and/or services; and to transfer or assign our rights, interests and obligations under any agreements entered into with us.
If you have contacted FunnelFlock’s customer service with any complaints or comments, we will use and/or disclose your personal data (including contact history) to respond to you and handle the complaint. If you do not wish for FunnelFlock to disclose your identity to the party you are complaining about, you must inform FunnelFlock immediately. However, doing so may limit our capacity to deal with your complaint effectively or satisfactorily.
Please note that by submitting any comments and feedback regarding the Platform and/or services, you consent to FunnelFlock using such comments and feedback in any marketing or advertising materials. We will only identify you for this purpose by your first name and the city in which you reside. If you do not wish for us to do so, please let us know through the following email address: info@funnelflock.com
If you consent, FunnelFlock will use your personal data for advertising and direct marketing purposes in order to inform you about any updates about the Platform or the services, and information regarding any car deals. You may opt out of receiving such emails at any time by clicking the “Unsubscribe” link at the bottom of any such email correspondence.
If FunnelFlock needs to use your personal data for any other purposes, FunnelFlock will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data in relation to these other purposes.
 
3. Disclosure and transfer of personal data
 
FunnelFlock will disclose your personal data to third parties only with your consent or when it is necessary for FunnelFlock to carry out its obligations to you. In particular, you expressly consent that FunnelFlock may disclose your personal data to: the relevant car merchant for the purposes of communicating your interest in a particular deal and concluding the relevant sales contract; credit reference or reporting agencies for the purpose of checking on your credit history; and financial institutions for the purpose of applying and obtaining credit facilities, if necessary. In some circumstances, FunnelFlock may contract with a service provider to perform technical, administrative, marketing or other services on FunnelFlock’s behalf, and FunnelFlock may share your personal data with such service providers. FunnelFlock may also disclose your personal data to third parties who provide necessary services to FunnelFlock, such as FunnelFlock’s consultants and professional advisors (such as lawyers, accountants and auditors). FunnelFlock may also disclose your personal data to third parties in order to comply with legal and regulatory obligations and requirements. FunnelFlock reserves the right to disclose your personal data if it is required or authorised to do so by law. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, your personal data may be part of the assets that is transferred. You consent to such transfer and you acknowledge and agree that any successor or acquirer of FunnelFlock or its assets will continue to have the right to use your personal data and other information in accordance with the terms of this Privacy Policy.

The personal data you provide to FunnelFlock will be transferred to and stored with a cloud service provider with servers that are located outside of Singapore. Some of these countries may not have the same or substantially similar privacy laws than those of your home jurisdiction. In those circumstances, Nexlec will ensure that recipients in those countries will provide you with a standard of protection that is at least comparable to the protection of your home jurisdiction.

 
4. Retention of personal data
 
FunnelFlock will retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected, except where FunnelFlock is legally obliged to retain such information. FunnelFlock will destroy or anonymise any personal data is holds about you which it no longer requires under the terms of this Privacy Policy.
 
5. Consent
 
By using and accessing the Platform and/or services, or by dealing with us, you signify that you consent to the collection, use, disclosure and transfer of your personal data by FunnelFlock in accordance with this Privacy Policy.
 
6. Security
 
FunnelFlock will take all reasonable precautions to ensure that the information you have provided is protected against unauthorised or unintended use, access or disclosure. Where you have chosen a password to access the Platform, you are responsible for keeping your password confidential. Do not share your password with anyone. Due to the nature of the Internet, FunnelFlock does not provide any guarantee or warranty regarding the security of your personal data during transmission to FunnelFlock or storage by FunnelFlock and you acknowledge that you disclose your personal data to FunnelFlock at your own risk.
 
7. Withdrawal of consent, access to and correction of personal data
 
If you would like to unsubscribe from receiving direct marketing communications from FunnelFlock, withdraw any authorisations for processing of your personal data by third parties, or request to access or correct personal data, please contact us at the email address provided below or follow the steps to unsubscribe which are presented in communications you receive from us. We will use reasonable endeavours to comply with your request within a reasonable period of receipt of your request. Please note that the withdrawal of any authorisations may result in us not being able to provide you with any services.
info@funnelflock.com
We take it that you have the right to provide any and all information you submit to FunnelFlock, and that all such information is accurate, true, current, and complete. You shall promptly update and correct all information you have submitted to FunnelFlock and ensure that it is accurate, true, current, and complete at all times. All requests to access or correct personal data shall be in writing.
 
8. Privacy practices of third parties
 
This Privacy Policy applies to the Platform and information that FunnelFlock collects from you. FunnelFlock may offer through its Platform or send to you links to or offers from third parties (where you have consented) or provide your personal information to car merchants for the purposes of negotiating the potential sale of a car. This Privacy Policy does not apply to information that you may provide to or that may be collected by such third parties. These third parties have separate privacy policies that govern how these third parties handle your personal data. FunnelFlock is not responsible for the collection, use or disclosure of your personal data by such third parties.
 
9. Disclaimer
 
FunnelFlock shall not be liable for any special, punitive, exemplary, incidental, indirect or consequential damages of any kind, or for any loss of reputation and goodwill, whether based on contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your personal data.
 
10. Changes to this policy
 
FunnelFlock may amend this Privacy Policy from time to time. The amended Privacy Policy will be published on the Platform.
 
11. Contact
 
All comments, queries and requests relating to our use of your information are welcomed and should be address to our data protection officer at info@funnelflock.com
 
Last updated: October 2017