5. Disclosure of your information 5.1 We may share your information with selected third parties including:
- (a) affiliates, business partners, suppliers and sub-contractors for the performance and execution of any contract we enter into with them or you;
- (b) advertisers and advertising networks solely to select and serve relevant adverts to you and others; and
- (c) analytics and search engine providers that assist us in the improvement and optimization of our site; and
- (d) our group entities or subsidiaries
5.2 We may disclose your personal information to third parties:
- (d) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- (e) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; or to protect the rights, property, or safety of Sirocco Pay, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;
- (f) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
- (g) to prevent and detect fraud or crime;
- (h) in response to a subpoena, warrant, court order, or as otherwise required by law;
- (i) to assess financial and insurance risks;
- (j) to recover debt or in relation to your insolvency; and
- (k) to develop customer relationships, services and systems.
5.3 We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to You, you can request this by writing to
support@siroccopost.com. 6. Where we store your personal data 6.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
7. Sharing your data outside of the EEA 7.1 In order to provide our Services to you, it is sometimes necessary for us to transfer your data to the third parties outlined in section 5.1 that are based outside of the European Economic Area. In these cases, we ensure that both ourselves and our partners take adequate and appropriate technical, physical and organizational security measures to protect your data. We also ensure we have appropriate contractual protections in place with these third parties.
8. Profiling and Automated Decision Making 8.1 We may use some instances of your data in order customize our Services and the information we provide to you, and to address your needs - such as your country of address and transaction history. For example, if you frequently send funds from one particular currency to another, we may use this information to inform you of new product updates or features that may be useful for you. When we do this, we take all necessary measures to ensure that your privacy and security are protected - and we only use pseudonymised data where ever possible. This activity has no legal effect on you.
8.2 As part of being a highly technical and innovative company, we may use Automated Decision Making (ADM) in order to improve your experience, or to help fight financial crime. For example, so that we can provide you with a fast and efficient service, we may use ADM to verify your identity documents, or to confirm the accuracy of the information you have provided to us. None of our ADM processes have a legal effect on you.
9. Data Retention 9.1 Sirocco Pay. may be required by law to store some of your personal and transaction data beyond the closure of your account with us. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.
9.2 We will always delete data that is not longer required by a relevant law or jurisdiction in which we operate.
9.3 Retention periods defined for the storage of your data can be found by
support@siroccopost.com.
10. Your rights 10.1 You have the right to ask us not to contact you for marketing purposes by contacting us at
support@siroccopost.com, or by adjusting your notification preferences in the "Settings" section of your account page.
10.2 You have the right to correct any personal information. We hold on you that is inaccurate, incorrect, or out of date.
10.3 You have the right to ask us to delete your data when it is no longer necessary, or no longer subject to a legal obligation to which Sirocco Pay Pte. Ltd. is subject to.
10.4 You have the right to transfer your personal data between data controllers, for example, to move your account details from one online platform to another.
10.5 Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
11. Access to information 11.1 Subject to applicable laws, you may have the right to access information we held about you. Your right of access can be exercised in accordance with the relevant data protection legislation.
12. Changes to our privacy policy 12.1 Any changes we may make to our privacy policy will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
13. Contact 13.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to
support@siroccopost.com or at the address: 15 Beach Road, #35-28 Gateway West, Singapore (189720), Unit Number 28,.