Privacy Notice

As updated on 4 July 2022

1.NOTICE

1.2 APPLICATION

MARS FINTECH PTE LTD and its affiliated and its associated businesses (collectively referred to as “MARS FINTECH PTE LTD”) owned and operated websites and mobile applications (collectively refer to as “Services”) may have different channels of collecting personal data, but each are committed to complying with this Notice in its collection, use, disclosure of personal data to ensure that there is a accountability and uniformity in the way we protect your personal data. Although this Notice is in common use by MARS FINTECH PTE LTD, and its ‘affiliated and its associated businesses, each is responsible to you to the extent of its own collection, use and disclosure of your personal data, and its own actions.

1.3 COMPLIANCE WITH THIS NOTICE

This Notice applies to all personal data you provide to us, or that we may collect about you. Please do not provide any personal data to us if you do not accept this Notice.

We may also require you to accept this Notice when you contact, interact, transact, or deal with us, or when you access and use our websites, applications or services. If you notify us that you do not accept this Notice, we may not be able to establish a relationship with you or be able to service your requests.

For purposes of this notice, we will use the following definitions:

Personally identifiable information (PII) is information that can identify a user of the Services, including his or her e-mail, name, mobile number, address, pictures and videos. It also includes PII combined with non-PII.

De-identified information is information from which personally identifiable components have been removed and a reasonable determination made that an individual is not identifiable.

1.4 Amendment to this Notice

We may amend this Notice from time to time without notice to you, to comply with applicable laws or as we update our data usage and handling processes. The updated Notice will supersede earlier versions and will apply to personal data provided to us previously. The amended Notice will take effect when made available.

2. Personal Data

Depending on your relationship with us, we may also collect your personal data from third parties, including: from your family members, employees, and mutual contacts who provide your personal data to us on your behalf; and from public agencies or other public.

Our website and applications may also contain or involve certain technologies that automate the collection of data (including personal data). These technologies include cookies, web beacons and web analytics. If you do not wish to have your data collected through such technologies you may disable the operation of these technologies on your devices (where possible), or you may refrain from using our websites and applications.

3. Purposes

We will not contact you for marketing purposes unless with your consent, or we are exempted by applicable law from having to obtain consent. When contacting you for marketing purposes, we will not contact you through your telephone number, unless you have specifically consented to such a mode of communication. If you do not wish to receive any communication or information from us or wish to restrict the manner by which we may contact or send you information, you may contact us to do so.

4. Disclosure of Personal Data

When disclosing personal data to third parties, we will (where appropriate and required by applicable law) enter contracts with these third parties to protect your personal data in a manner that is consistent with applicable laws and/or ensure that they only process your personal data in accordance with our instructions.

5. Cross Jurisdiction Transfers of Personal Data

6. Protection of Personal Data

7. Your Rights

Information Collected Automatically

We automatically receive and record information on our server logs from a user’s browser. This may include the IP address, pages of MARS FINTECH PTE LTD visited, the time spent on those pages, and access times and dates. We use this information to better display our Services, maintain a user’s session, identify the country the user is located in, monitor, analyse use of and administer MARS FINTECH PTE LTD, and to better tailor it to your needs. We may also use this information to serve advertising to adult users.

To collect this information, we use technological tools including:

Cookies. A cookie is a small data file sent from a website or application and stored on your computer or device. Cookies allow us to recognize your browser when you return to MARS FINTECH PTE LTD, remember your login information, enable access to paid content and monitor potential account misuse. Cookies also allow us to better understand how you interact with MARS FINTECH PTE LTD and to monitor aggregated usage. You can set your browser to detect some cookies, to stop accepting cookies or to prompt you before accepting a cookie. Disabling our cookies will prevent access to paid content and limit some of the functionalities within our Services. To learn more about browser cookies, including how to manage or delete them, look in the Tools, Help or similar section of your web browser.

Pixel Tags. A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that we place in our marketing emails, newsletters, promotional offerings and surveys. We use pixel tags and line tracking to analyze the effectiveness of our marketing campaigns.

We use Google Analytics to assist us in collecting and assessing automatically collected information. For more information about Google Analytics, see Google Analytics Terms of Service and the Google Privacy Policy. You can prevent Google Analytics from collecting information about you and recognizing you on return visits to our Services by disabling cookies on your browser or by installing the Google Analytics opt-out plug in. Note that we are not responsible for Google’s opt-out tools.

By using our Services, you agree to our use of these tracking technologies.

We do not track users across unaffiliated sites and services, however, when you use the Internet, unaffiliated parties such as ad networks, web analytics companies and social networking platforms may collect information about your online activities over time and across our and other websites. This information may be used to provide advertisements for products and services that may interest you, and those companies may use cookies, clear GIFs, and other tracking technologies.

In addition, we and our third-party partners may use tracking technologies to deliver targeted advertisements and marketing messages to adult users on our or unaffiliated websites and online services. We also occasionally source information about groups of adults to generate a "lookalike audience" or similar audience of prospective customers through PII platforms. This allows us to target prospective customers with advertisements on their networks who appear to have shared interests or similar demographics to our existing customers, based on the platforms' own data. We do not have access to the identity of anybody in the lookalike audience, unless they choose to click on the ads, and this information is only used for customer prospecting.

Note that if you wish to opt out, you will need to do so separately for each of your devices and for each web browser you use.

We also subscribe to various third parties’ education market information and databases, for example databases of school contacts. We use this data to learn about the industry we serve, to improve our services and for direct marketing. Some third parties may provide us pseudonymized information about you (such as demographic information or sites where you have been shown ads) from offline and online sources that we may use to provide you more relevant and useful advertising.

Push notifications on mobile apps: Our adult users have the option to accept push notifications. If push notifications are accepted, we will store your previously provided name, mobile number and email address in the push notification token. If you choose to receive push notifications, we will need to collect certain information about your device - such as operating system and user identification information - to ensure they are delivered properly. We also collect the user time zone, which is set on the device, to ensure that we send notifications at an appropriate time of the day. We do not combine this information with other PII. You may turn push notifications off at any time using your device controls.

How Long We Retain Personal Information:

We will retain, use, and share anonymous or aggregate and de-identified information for lawfully permissible purposes, including developing and improving educational products and services, educational research purposes, evaluating, informing, and demonstrating the effectiveness and efficacy of our products and services. If you wish to make any changes to your personal identifiable information, you may email us for assistance at  [email protected] with the subject header [Re: Privacy Policy].

How We Share Your Information

We may provide Personally Identifiable Information to our partners, business affiliates, and third party service providers who work for MARS FINTECH PTE LTD and operate some of its functionalities. These may include but not limited to hosting, streaming, credit card processing services and companies that provide marketing emails on our behalf. A current list of these third parties service providers is available to our subscribers upon request through at   [email protected] with the subject header [Re: Privacy Policy]. These third parties service providers are bound contractually to practice commercially reasonable security measures and to use your Personally Identifiable Information solely as it pertains to the provision of their services. They do not have the independent right to share your Personally Identifiable Information or use it for any unrelated purposes.

We reserve the right to disclose personally identifiable information if we are required to do so by law, or if we believe that disclosure is necessary to protect our rights, protect your safety or others' safety, investigate fraud, and/or comply with a judicial proceeding, court order, subpoena, or legal process.

We also reserve the right to transfer your Personally Identifiable Information in case of a corporate restructuring (such as a merger, acquisition, or other disposition of our business), as long as the receiving entity adopts this Privacy Policy regarding your information.

We may share your email addresses collected when registering to free trials with third parties business partners for marketing purposes when the individual has opted in to receive such communication. You may opt out of promotional messaging at any time as described in the Opt Out section below.

How to request for access to your personal data

Individuals will be charged (SGD$20/hour) subjected to the complexity of the request per subject access request. MARS FINTECH PTE LTD will aim to provide the relevant data within 14 days. The fees charge for an access request shall only be calculated on a manpower hours basis to fulfill the request. Should the response not be able to be within thirty (30) days after receiving the request, MARS FINTECH PTE LTD will inform individual in writing within thirty (30) days of the time by which MARS FINTECH PTE LTD will be able to respond to your request.

MARS FINTECH will always verify the identity of anyone making a subject access request before handing over any information.

Data Protection Officer

We have appointed a Data Protection Officer to oversee the protection & security management of all personal data. Should you have any query, request or feedback relating to your Personal Data, please contact us at the following: -

Data Protection Officer: Ms Jin Yan

MARS FINTECH PTE LTD
7 Straits View, Marina One East Tower, #05-01 Singapore (018936)

Tel: +65 8299 3601

Email: [email protected]

For more information about the Singapore Personal Data Protection Act, please visit http://www.pdpc.gov.sg

Terms of Service Agreement

Last Updated: 11th November 2022

Welcome to MarsConnect, owned, and operated by MARS FINTECH PTE. LTD (“MarsConnect,” “we,” “us”, or “our”). These Terms of Service (“Terms”) govern your access to and use of the MarsConnect website(s), our APIs, mobile app (the “App”), and any other software, tools, features, or functionalities provided on or in connection with our services

You agree to be bound by (i) these Terms of Use, (ii) Privacy Policy, Cookie Policy, Arbitration Procedures (if applicable), Safety Tips, and Community Guidelines, each of which is incorporated by reference into this Agreement, and (iii) any terms disclosed and agreed to by you if you purchase additional features, products, or services we offer on our Services (collectively, this “Agreement”).

If you do not accept and agree to be bound by all the terms of this Agreement, please do not use, or attempt to access any of our Services.

We will not be liable for any product or services made within our website or mobile application, this includes any misleading representation of “Service Providers”, in or out of the platform. We will do our best to ensure the integrity of the “Service Providers”, as they communicate their product or services but shall not be liable for any misrepresentation made by any “Service Providers”.

These Terms of Service (“Terms”) govern your use of the websites, landing pages, mobile applications, and services (collectively, the “Services”) provided by Mars Fintech Pte Ltd as defined below).

1.General

These Terms applies to all users of the Services, including without any limitation to users who are business user “Seller”, and consumer user “Buyer”, or any contributors of content, information, and other materials. If you are entering into this agreement for and on behalf of a business entity, the term “you” in this agreement shall represents the business entity unless otherwise stated.

These Terms are between you and Mars Fintech Pte Ltd or between you and any different service provider identified for a particular Service known as the “Business User”.

By using the Services in any manner, including but not limited to visiting or browsing the Services, you agree to observe and be bound by our terms of service and privacy policies referenced herein www.marsconnect.io/terms-of-service and www.marsconnect.io/privacy-policy collectively.

We may make changes to this Agreement and to our Services from time to time. We may do this for a variety of reasons including to reflect changes in or requirements of the law, new features, or changes in business practices.

The most recent version of this Agreement will be posted on our Services under Settings and on https://www.marsconnect.io , and you should regularly check for the most recent version while accessing our Services. The most recent version is the version that applies. If the changes include material changes to your rights or obligations, we will notify you at least 30 days in advance of the changes (unless we are unable to do so under applicable law) by reasonable means, which could include notification through our Services or via email. If you continue to use our Services after the changes become effective, it is implied that you agree to the revised Agreement.

2.Eligibility

You are not authorized to create an account, access, or use our Services and applications unless all the following are true:

3.Your Account

To access MarsConnect, you may sign in using several ways, including through Mobile Number, Email, Google and Facebook login. If you choose to use the methods of Google or Facebook login, you authorize us to access to obtain account information of your Google and Facebook, including but not limited to your public Facebook profile.

For more information regarding the information, we collect from you, and how we use it, please refer to our Privacy Policy.

You are responsible for maintaining the confidentiality of your login credentials you use to sign up for MarsConnect, and you are solely responsible for all activities that occur under those credentials. If you think someone has gained access to your account, please immediately contact us.

Your login credential includes:

4.Prohibited uses

You may not use our Services to do or share anything that violates our Terms of Service, Community Guidelines, and other terms and policies that apply to your use of our Services.

5.Applicable Privacy Policy and other Policies

In addition to this Agreement, your access to and use of the Content and Service (including without limitation your submission of information through the App) is subject to MarsConnect then-current policies relating to the Content and Service, including, without limitation, MarsConnect Privacy Policy, located at “Privacy Policy”, www.marsconnect.io/privacy-policy. If you open an account with MarsConnect and use our Services, you are consenting to have your personal data transferred to and processed by digital advisers/consultants and its affiliates. Such consent will include your agreement that MarsConnect may provide your digital advisers/consultants with any updates in your personal data as furnished by you to MarsConnect. You may also use the Service to display on the Application the status of your account at your broker-dealer.

Your personal account information displayed on the Application will be subject to MarsConnect privacy policy.

As part of the Services, your digital adviser/consultants may communicate with you through the Application. You may not be able to opt-out from receiving those communications.

6.Modifying and Termination of our Services

MarsConnect will always be looking to improve your experience on our platform and bring you features and changes that our users will find engaging and useful. We can remove or restrict access to content that is in violation of any provisions as stated above. This means we may add new features or functionalities from time to time as well as remove any said features or functionalities to protect our Users (Business and Consumer).

If these actions do not materially affect your rights or obligations, we may not provide you with a notice before making such changes. We may extend to suspend our Services entirely, in any event that we deemed as high risk by our advisory board, government regulatory bodies. In this course of action, we will notify you in advance unless extenuating circumstances, such as safety or security concerns, prevents us from doing so.

If we determine that a user has breached our Terms of Use Agreement, which includes our Community Guidelines, we may suspend or permanently disable access to the account without informing. We may also suspend or disable the account if the user has repeatedly infringed other people’s intellectual property rights, or where we are required to do so for legal purposes.

If your account has been deleted, disabled, suspended, or terminated, these Terms of Use Agreement shall terminate as well between you and MarsConnect, except for any provision that is required to retain for legal purposes.

7.Business and Consumer Users Generated Content

MarsConnect allows business and consumer user refers to as “Users”, (on the business application) to post content, including photos, comments, links, and other materials. Anything that the users (on the business application) post or make available on MarsConnect is referred to Users Content. The users retain all rights in and are solely responsible for the Users Content posted on MarsConnect Website and Application.

We would like to remind users that they are responsible for their own action and are advice to do their due diligence before engaging in any product or services through any Users content Generation that has been provided, including performing checks on compliance with applicable laws, rules, and regulations. You should only provide content that you are comfortable sharing with others.

MarsConnect maintains the right to remove any content that may compromise the physical or emotional safety of all the users on the platform. MarsConnect compliance team may assess the degree of severity in safety and may submit necessary documentations if requested by the law.

8.Interaction with other Users

The interaction with the Business User, “Financial Advisers/Consultants/Representatives” on this platform allows communication only after the user (using the client’s application) accepts their proposal and initiates an appointment.

Intellectual Property/License to use – includes free use, no creating derivative works Subject to your compliance with these Terms of Use Agreement, MarsConnect grants you a limited, non-exclusive, non-transferable, non-sub-licensable license to download and install a copy of the application on a mobile device and to run such copy of the application solely for your own personal purposes.

Except as expressly permitted in these Terms of Use or under applicable law, you may not: (a) copy, modify, or create derivative works based on the application; (b) distribute, transfer, sublicense, lease, lend, or rent the application to any third party; (c) reverse engineer, decompile, or disassemble the application; or (d) make the functionality of the application available to multiple users through any means. MarsConnect reserves all rights in and to the application not expressly granted to you under these Terms of Use.

9.Disclaimers/ Limitation of Liability

Our Services is provided “as is,” and we cannot guarantee it will be safe and secure or will work perfectly all the time. TO THE EXTENT PERMITTED BY LAW, WE ALSO DISCLAIM ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT.

We also do not control what people and others do or say, and MarsConnect are not responsible for their (or your) actions or conduct (whether online or offline) or content (including unlawful or objectionable content). We also are not responsible for services and features offered by other people or companies, even if you access them through our Service.

Our responsibility for anything that happens on the Service (also known as “liability”) is limited as much as the law will allow. If there is an issue with our Services, we cannot know what all the possible impacts might be. By using our website, landing pages, mobile applications, you agree that you will not hold MarsConnect responsible (“liable”) for any potential damages, lost profits, revenues, information, data, or consequential, special, indirect, exemplary, punitive, or incidental damages arising out of or related to these Terms of Use, even if we know they are possible. This includes when we delete your content, information, or account.

Any use or reliance on any Content or materials posted via our Services or obtained by you through the Services is at your own risk. We do not endorse, support, represent or guarantee the completeness, truthfulness, accuracy, or reliability of any content or communications posted via our Services or endorse any opinions expressed via our Services. You understand that by using our Services, you may be exposed to content that might be offensive, harmful, inaccurate, or otherwise inappropriate, or in some cases, postings that have been mislabeled or are otherwise deceptive. All content is the sole responsibility of the person who originated such content. We may not monitor or control the content posted via our Services and, we cannot take responsibility for such content.

10.Third party services

The service may contain advertisements and promotions offered by third parties and links to other web sites or resources. MarsConnect is not responsible for the availability (or lack of availability) of such external websites or resources. If you choose to interact with the third parties made available through our Services, such party’s terms will govern their relationship with you. MarsConnect is not responsible or liable for such third parties’ terms or actions.

11.Trademark information

We use proprietary algorithms in the portfolio building process including but not limited to portfolio optimization and portfolio rebalancing. The underlying inputs and assumptions are based on external information. Mars FinTech Pte Ltd will try to ensure its reliability but do not guarantee the accuracy or reliability of such information.

By using our website, landing page and mobile application, you deemed to understand the limitations of advice provided by a digital advisor, including the fact that the recommendation may not take into consideration your financial circumstances, existing investment portfolios or the affordability of the investment. We have the right to override the automated algorithm or temporarily halt the digital advisory service in extreme market conditions.

We also retain the right to make material adjustments to the algorithms in the future as it deems necessary. However, any asset allocation changes to your portfolio will require your prior consent.

12.Indemnity by You

By agreeing to the Terms of Service upon using the Service or accessing the Platform, you agree that you shall indemnify and hold Mars Fintech Pte Ltd the registered company registered under the Republic of Singapore, operating under the name “MarsConnect” with its digital platform including and not excluding its websites, landing pages, application, its licensors and each such party’s affiliates, officers, directors, members, employees, attorneys and agents harmless from and against any and all claims, costs, damages, losses, liabilities and expenses (including attorneys’ fees and costs and/or regulatory action) arising out of or in connection with: (a) your use of the Service, the Platform and/or any part thereof in your dealings with the Partners or Consumers (as the case may be), third party merchants, providers, partners, advertisers and/or sponsors, or (b) your violation or breach of any of the Terms of Service, any third party terms and conditions or any applicable law or regulation, whether or not referenced herein, or (c) your violation of any rights of any third party, including Partners or Consumers arranged via the Service, or (d) your use or misuse of the Service, the Platform and/or any part thereof, or (e) where applicable, your ownership, use or operation of any property, including your provision of Solutions to Consumers via the Service.

13.Purchases & Payment

MarsConnect does not take or collect any payment within its platform. All payment transaction shall commence out of the platform.

14.Severability

If any term, clause, or provision of these Terms is held invalid or unenforceable, then that term, clause, or provision will be severable from these Terms and will not affect the validity or enforceability of any remaining part of that term, clause, or provision, or any other term, clause, or provision of these Terms.

15.Governing law

These terms of services shall be governed by, and construed and enforced in accordance with, under the laws of the Republic of Singapore.

16.Arbitration and Meditation

Mars Fintech Pte Ltd highly encouraged between the parties (Business and Consumer) to meditate between “FIRDEC” https://www.fidrec.com.sg/. Any dispute between the parties that is not subjected to arbitration depending on the plaintiff claims may proceed to state or high court under the Republic of Singapore.

17.Representative Proceedings

By agreeing to the Terms of Service upon using the Service or accessing the Platform, you agree that you shall indemnify and hold Mars Fintech Pte Ltd the registered company registered under the Republic of Singapore, operating under the name “MarsConnect” with its digital platform including and not excluding its websites, landing pages, application, its licensors and each such party’s affiliates, officers, directors, members, employees, attorneys and agents harmless from and against any and all claims, costs, damages, losses, liabilities and expenses (including attorneys’ fees and costs and/or regulatory action) arising out of or in connection with any “Service Providers” wrongdoing through any direct or indirect misrepresentation. The Individual and Service Providers agree that any claims will be adjudicated on an individual basis, and each waives the right to participate in a class, collective, Paga or other joint action with respect to the claims.

18.Entire Agreement

This Agreement contains the entire agreement and understanding among the parties hereto with respect to the subject matter hereof, and supersedes al prior and contemporaneous agreement, writing, understandings, inducements, and conditions, express or implied indirectly or indirectly in writing or oral of any nature whatsoever with respect to the subject matter hereof. The express terms hereof control and supersede any course of performance and or usage of the trade inconsistent with any of the terms hereof.