SmartLoans Privacy Policy

The Real Group respects the privacy of our consumer users and has developed this Privacy Policy to demonstrate its commitment to protecting your privacy. As an individual who is a user of our website or otherwise as a user of the services provided by SmartLoans, this Privacy Policy is intended to describe for you: 
• the information we collect about you; 
• how that information may be used; 
• with whom it may be shared; 
• how you may access the information you provide us; and 
• your choices about such uses and disclosures. 

We encourage you to read this Privacy Policy carefully when using our websites, services or transacting business with us. By using our websites, you are accepting the practices described in this Privacy Policy. 

If you have any questions about our privacy practices, please refer to the end of this Privacy Policy for information on how to contact us. 

INFORMATION WE COLLECT ABOUT YOU 

In General. We may collect personal information that can identify you such as your name and e-mail address, as well as other information that does not identify you. When you provide personal information through our websites or otherwise provide to us, the information may be sent to servers located in the Singapore and other countries around the world. 
• Information you provide. We may collect and store any personal information you enter on our websites or otherwise provide to us. This includes identifying information (such as your name, home or mailing address, e-mail address and telephone number), information about your home or prospective home, your financial information (such as your income, assets or debts), personal information (such as your gender and age). 
• Information from Other Sources. We may also periodically obtain both personal and non-personal information about you from business partners, contractors and other third parties. Examples of information that we may receive include credit reports, information about your home and additional demographic information. However, SmartLoans does not pull a credit bureau report on loan customers without permission. 
• Information about others. We may also collect and store personal information that you provide to us about other people (such as co-borrowers), including their name, address, phone number, financial information or other personal information. 
• Use of Cookies and Other Technologies to Automatically Collect Information. We use various technologies to collect information from your computer and about your activities on our websites. We automatically collect information from your browser when you visit our websites. This information includes your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us (see "Cookies" below) and the referring website address. 
• Cookies. When you visit our websites, we may assign your computer one or more cookies, to facilitate access to our websites, to personalize your online experience and to record information about your visit to our websites. Through the use of a cookie, we also may automatically collect information about your online activity on our websites, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while on our websites. The cookies do not store any personally identifiable information about you. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered on our websites. 
• Other Technologies. We may use standard Internet technology, such as web beacons and other similar technologies, to track your use on our websites. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our websites' visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities. 
• Information Collected by Third Parties. We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our websites. We and these companies may use tracking technologies, such as cookies, to collect information about users who view or interact with these advertisements and connect to our websites. Our websites do not provide any personal information to these third parties. This information allows us and these companies to deliver and gauge the effectiveness of targeted advertisements. Some of these third-party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. 

HOW WE USE THE INFORMATION WE COLLECT 

In general. We may use information that we collect about you to: 
• deliver the products and services that you have requested; 
• manage your customer relationship and provide you with customer support; 
• perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
• communicate with you by e-mail, postal mail, telephone and/or mobile devices about products or services that may be of interest to you either from us, other The Real Group companies or other third parties; 
• develop and display content and advertising tailored to your interests on our websites and other websites; 
• verify your eligibility and deliver prizes in connection with promotions, contests and sweepstakes; 
• enforce our terms and conditions; 
• manage our business; and 
• perform functions as otherwise described to you at the time of collection. 

Financial information. We may use financial information to match you with lenders or to provide lenders' conditional loan offers to you, to verify your identity, to protect against or identify possible fraudulent transactions, or otherwise as needed to manage our business. 

WITH WHOM WE SHARE YOUR INFORMATION 

We want you to understand when and with whom we may share personal or other information we collect about you or your activities on our websites or your use of our services. 

Personal information. We do not share your personal information with others except as indicated below or when we inform you and give you an opportunity to opt out of having your personal information shared. We may share all types of personal information with: 
• Authorized service providers: We may share your personal information with our authorized service providers that perform certain services on our behalf in connection with your request for a loan. These service providers may include credit bureaus, title companies, flood or other insurance providers, appraisal companies, escrow companies, closing agents, other financial institutions, marketing and customer services firms, credit card payment processors, as well as companies that support contests, sweepstakes, surveys, or other features offered through our websites, or that provide business analysis or website support. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such information for any other purpose. 
• Business partners: When you express interest in products, services or promotions offered through our websites or our services, we may share your expression of interest with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes, and, as applicable, their affiliates and third-party finder or marketing companies. When you elect to engage in a particular offer or program, you authorize us to provide your e-mail address and other information to those businesses. 
• Other lenders or investors. If you submit a completed SmartLoans form, we may share your personal information with lenders on the SmartLoans network with whom you are or may be matched. 
• Other The Real Group Businesses. We may share information we collect, including personal information, with other The Real Group companies (some of which are nonfinancial companies). Sharing information with the The Real Group companies enables us to provide you with information about a variety of products and services that might interest you. All The Real Group companies comply with this Privacy Policy. The Real Group companies also will comply with applicable privacy and security laws and, at a minimum, in any commercial e-mail they send to you, will give you the opportunity to choose not to receive such e-mail messages from that company in the future. However, in no circumstance will SmartLoans share with other The Real Group companies any personally identifiable information that you provide to us if that information bears on your creditworthiness. 
• Other Situations. We also may disclose your information: 
o In response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. 
o When we believe disclosure is appropriate in connection with efforts to investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; or to enforce our websites' terms and conditions or other agreements or policies. 
o In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, asset sale or in the unlikely event of bankruptcy. 

Any third parties to whom we may disclose personal information may have their own privacy policies that describe how they use and disclose personal information. Those policies will govern use, handling and disclosure of your personal information once we have shared it with those third parties as described in this Privacy Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties. These entities or their servers may be located either inside or outside the Singapore. 

Aggregated and Non-Personal Information. We may share aggregated information (i.e., information about you and other customers collectively, but not specifically identifiable to you) and other non-personal information we collect under any of the above circumstances. We may also share it with third parties and The Real Group companies to develop and deliver targeted advertising on our websites and on websites of third parties. We may combine non-personal information we collect with additional non-personal information collected from other sources. We also may share aggregated information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to our websites and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find of interest and to target content and advertising. 

Third-party websites. There are a number of places on our websites where you may click on a link to access other websites that do not operate under this Privacy Policy. For example, if you click on an advertisement or a search result on our websites, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with information about your activities on those websites. We recommend that you consult the privacy statements of all third-party websites you visit by clicking on the "privacy" link typically located at the bottom of the webpage you are visiting. 

HOW WE PROTECT YOUR PERSONAL INFORMATION 

We take appropriate security measures (including physical, electronic and procedural measures) to help safeguard your personal information from unauthorized access and disclosure. For example, only authorized employees and authorized third-party service providers are permitted to access personal information, and they may do so only for permitted business functions. We use encryption in the transmission of your sensitive personal information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal information. 

We want you to feel confident using our websites to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information, searches, or other communications will always remain secure. Users should also take care with how they handle and disclose their personal information. 

Visiting our websites from outside Singapore 

This Privacy Policy is intended to cover collection of information on our websites from residents of Singapore. If you are visiting our websites from outside Singapore, please be aware that your information may be transferred to, stored and processed in Singapore where our servers are located and our central database is operated. The data protection and other laws of Singapore and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy. 

No Rights of Third Parties 

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our websites. 
Changes to this Privacy Policy. We will occasionally update this Privacy Policy to reflect changes in our practices and services. When we post changes to this Privacy Policy, we will revise the "last updated" date at the top of this Privacy Policy. If we make any material changes in the way we collect, use, and/or share personal information that may impact you, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or registration (unless we do not have such an e-mail address), and/or by prominently posting notice of the changes on our websites. We recommend that you check our websites from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies. 

How to contact us 

If you have any questions about this Privacy Policy or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us via e-mail at admin@smartloans.sg. 

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