Customer Personal

Data Agreement

Doo Payment Holding Pte. Ltd. Doo Exchange AU Pty Ltd

Doo Technology Singapore Pte. Ltd.

Updated as of 26 August 2024

1.                   Introduction

1.1.            This Customer Personal Data Agreement (“Agreement”) is entered into by and between you, the  customer  and us, Doo Payment  Holding Pte. Ltd.  (Company Registration No.: 202227865N) (“DPHL”), Doo Exchange AU Pty Ltd (Australian Company No: 661717237)  (“DEAU”),  and  Doo  Technology  Singapore  Pte.  Ltd.  (Company  Registration  No.: 202104581D) (“Doo Tech”) (collectively referred to as ‘Doo Group’, ‘we’, ‘our’, ‘us’ and ‘ourselves’ as appropriate). The customer is referred to as ‘you’, ‘your’, ‘yours’, ‘yourself’ and ‘Customer’ as appropriate. The Customer and Doo Group are each a “Party,” and together, the “Parties”.

1.2.            This  Agreement  shall  govern  the  collection,  use,  disclosure  and  processing  of  your Personal Data and Personal Information. 

1.3.            By electronically accepting or acknowledging this Agreement on our Platform (as defined in 2.1.13 of the Terms and Conditions and reiterated below) or by signing up for a Card (as defined in 2.1.4 of the Terms and Conditions and reiterated below), you are deemed to have read and accepted this Agreement.

2.                   Definitions

2.1.  The definitions in this clause 2.1 apply in this Agreement.

App  :  Application provided and maintained by Doo Technology

Singapore Pte. Ltd. for the purposes of Card registrations, applications and usage; 

Australia Privacy Act  :  Means (i) the Australia Privacy Act (No. 119, 1988) and (ii)

any successor laws and regulations that have the same general intent and effect.

Card :       means  the  Platinum  Dragon  Card,  virtual  or  physical, powered  and  issued  by  DCS  and  any  substitution, replacement or renewal thereof;

Data Protection Laws :       means all laws and regulations that are applicable to the Processing  of  Personal  Data  under  this  Agreement, including, but not limited to the Singapore PDPA and  the Australia Privacy Act.

Personal Data :       has the meaning referred to in section 2 of the Singapore PDPA, which refers to data, whether true or not, about a Customer who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access; and for the avoidance of doubt, does not include business contact information but includes Sensitive Personal Data;

Personal Information  :  has the meaning referred to in section 2 of the Australia

Privacy  Act,  which  refers  to  information  or  an  opinion about  an  identified  individual,  or  an  individual  who  is reasonably identifiable:

1.   whether the information or opinion is true or not; and
2.   whether the information or opinion is recorded in a material form or not.

Platform  :  means a mobile application that can be downloaded from

the Apple App Store or Google Play Store by the Customer who has a valid Card.

Sensitive Personal  :  special categories of Personal Data, including:

Data  (a)  NRIC and/or passport numbers;

2.     Nationality;
3.     Place of residence;
4.     Personal  Data  of  a  financial  nature  such  as  bank account details; and
5.     Personal Data of minors.

Singapore PDPA  Means (i) the Singapore Personal Data Protection Act of

2012 and (ii) any successor laws and regulations that have the same general intent and effect.

3.                   Collection, Use, Disclosure and Processing of Personal Data

3.1.            By electronically accepting or acknowledging this Agreement on our Platform, you hereby confirm  that  you  have  provided  your  irrevocable  consent  to  the  collection  of  your Personal Data and Personal Information by us for the purpose which includes but is not limited to the fulfilment of the Know Your Customer (KYC) requirements.

3.2.            The Customer acknowledges, agrees and consents that the Personal Data and Personal Information collected by us will be transmitted to DCS Card Centre Pte. Ltd. (UEN No.: 197300502W) (“DCS”), which is the card service provider, to facilitate the completion of the KYC process.

3.3.            The  Customer  shall  be  responsible  to  ensure  that  the  Personal  Data  and  Personal Information submitted to us is accurate and up to date. In the event there is an error or update to the Personal Data associated with the Platform/Card, the Customer shall submit a request to us to correct the Personal Data and Personal Information as soon as practicable and we shall correct or update the Personal Data and Personal Information in our database accordingly.

3.4.            We shall take reasonable steps to ensure the security and confidentiality of your Personal Data  and  Personal  Information  during  transmission  to  DCS  and  comply  with  the prevailing  requirements  of  the  Singapore  PDPA,  the  Australia  Privacy  Act  or  other applicable Data Protection Laws.  

3.5.            Personal Data and Personal Information provided to us will be kept confidential but the Customer  hereby consents and authorises us to provide or disclose Personal Data and Personal Information to the following categories of parties:-

1.                 Any person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency;
2.                 Government agencies, statutory authorities and industry regulator as necessary to comply with legal obligations or investigations; or 
3.                 with your explicit consent.

3.6.            Where  we  consider  it  necessary  or  appropriate  for  the  purposes  of  data  storage  or processing or providing any service or deliverable on our behalf to you, we may transfer Personal Data and Personal Information to a third-party service or product providers within  or  outside  the  country  in  which  we  are  established,  under  conditions  of confidentiality and similar levels of security safeguards.

4.                   Customers below 21 years of age

4.1.            If the Customer is below 21 years of age when the Customer applies for a Card, the following provisions will apply.

4.2.            The  Customer’s  parent  or  guardian,  by  proceeding  with  the  application,  on  the Customer’s behalf consents  to the collection, use, disclosure and processing of  the Customer’s Personal Data and Personal Information for the purpose which includes but is not limited to the fulfilment of the Know Your Customer (KYC) requirements. 

4.3.            The Customer’s parent or guardian, on the Customer’s behalf, acknowledges, agrees and consents  that  the  Personal  Data  and  Personal  Information  collected  by  us  will  be transmitted to DCS Card Centre Pte. Ltd. (UEN No.: 197300502W) (“DCS”), which is the card service provider, to facilitate the completion of the KYC process.

4.4.            Clauses 3.3, 3.4, 3.5 and 3.6 above shall apply, mutatis mutandis, to the Customer who is below 21 years of age.

5.                   Amendment

5.1.  We may modify all or any part of this Agreement at any time by posting a modified version

of this Agreement (including any terms incorporated by reference into this Agreement) on our Platform or by notifying the Customer. The modified Agreement is effective upon posting or, if we notified the Customer, as stated in the notice. If the Customer objects to any of the modified terms in the Agreement, the Customer may terminate this Agreement by calling  the DCS Card Hotline at +65 6571 0128 or email to [email protected].  By continuing to use the Card after the effective date of any modification to this Agreement, the Customer agrees to be bound by the modified Agreement.

6.                   General provisions

6.1.            Notice. Each Party agrees that it will notify the other Party if it determines that it cannot or will no longer meet the obligations set forth in this Agreement or applicable Data Protection Laws. Each Party may give such notice in accordance with clause 5.1 of this Agreement. 

6.2.            Severance. If any court of competent authority finds that any provision of this Agreement (or part of any provision) is void, invalid, illegal or unenforceable, that provision or part- provision shall, to the extent required, be deemed to be deleted and the validity and enforceability of the other provisions and, as the case may be, the remainder of the relevant provision of this Agreement shall not be affected.

6.3.            Third Parties. A person who is not a party to this Agreement shall not have any rights under or in connection with it by virtue of the Contracts (Rights of Third Parties) Act 2001.

6.4.            Governing Law and Jurisdiction. This Agreement and any disputes or claims arising out of or in connection with this Agreement are governed by and construed in accordance with the laws of Singapore. The Parties irrevocably agree that the courts of Singapore shall have exclusive jurisdiction to settle any such dispute or claim.

[The remainder of this page has been intentionally left blank]