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PRIVACY POLICY

The following Privacy Policy outlines how 111 Credit (the “Company”) manages and protects personal data. As this document affects your legal rights, please read it carefully.

1. Introduction

111 Credit takes its responsibilities under Singapore’s Personal Data Protection Act 2012 (PDPA) seriously. We recognise the importance of the personal data entrusted to us by customers, employees, and third parties, and it is our responsibility to properly manage and safeguard this information.

This Privacy Policy (the “Policy”) explains how we collect, use, disclose, retain, and protect personal data.

2. Purpose

This Policy governs the collection, use, and disclosure of personal data from customers, employees, and third parties, and explains how the Company complies with the PDPA and its regulations.

“Personal data” has the meaning ascribed to it under the PDPA.

3. Responsibility

The Company’s appointed Data Protection Officer (DPO) is responsible for implementing and updating this Policy. The Policy may be revised from time to time to reflect technological developments, regulatory updates, and industry practices.

4. Scope

This Policy applies to all personal data collected by the Company in connection with our operations, whether from customers, employees, or authorised third parties.

5. Consent

We collect, use, and disclose personal data only where:

  • Consent has been obtained (express or deemed).

  • Notification of the purpose has been given.

  • It is required or authorised under applicable laws.

Consent is obtained through loan application forms, contracts, declarations of agreement to our Terms and Conditions, or written employee consent forms.

6. Collection of Personal Data

6.1 From Customers

6.1.1 Purpose and Scope

We collect personal data to:

  • Assess and process loan applications.

  • Comply with regulatory obligations (e.g., Moneylenders Credit Bureau, Registry of Moneylenders).

  • Conduct credit checks through approved agencies (e.g., Credit Bureau Singapore, DP Information Network).

  • Understand customers’ financial needs to tailor loan products.

  • Enforce loan repayment, including debt recovery through authorised agents, law firms, or collection agencies.

  • Fulfil accounting, auditing, and compliance requirements

6.1.2 Types of Personal Data Collected

  • Full Name

  • NRIC / FIN / Passport No.

  • Nationality

  • Date of Birth

  • Gender / Marital Status / Ethnicity

  • Residential Address

  • Contact Numbers

  • Email Address

  • Employment and income details

  • Photograph

  • Next-of-kin details

6.2 From Employees

6.2.1 Purpose and Scope

We collect personal data from employees to:

  • Evaluate job suitability and performance.

  • Administer employment benefits (e.g., CPF, insurance, staff schemes).

  • Apply for relevant work passes.

  • Manage HR records and payroll.

  • Fulfil statutory and regulatory requirements.

6.2.2 Types of Personal Data Collected

  • Full Name

  • NRIC / FIN / Passport No.

  • Date of Birth / Nationality / Marital Status / Gender

  • Address / Contact Numbers / Email Address

  • CV, qualifications, and work experience

  • Employment details (designation, appraisal records, entitlements)

  • Bank account details / CPF contributions / Income information

  • Photograph

6.3 From Third Parties

We may collect or disclose personal data from/to third parties with consent, deemed consent, or as required by law. These include auditors, debt collection agencies, affiliated companies, or other licensed moneylenders.

Such purposes include:

  • Debt collection

  • Legal and audit compliance

  • Accounting functions

  • Employment verification

All third parties engaged are contractually bound to maintain confidentiality.

7. Disclosure of Personal Data

We disclose personal data only when:

  • Required by law.

  • Authorised by the individual.

  • Necessary for business operations such as credit checks, debt collection, HR, or auditing.

Secure Methods of Disclosure: Personal data is transmitted via encrypted electronic submission, secure email, or verified postal channels.

8. Access and Correction 

Individuals may request access to or correction of their personal data by contacting us at [email protected].

  • Requests will be processed within 5 working days.

  • If more time is needed, we will notify the individual via interim email before the deadline.

9. Withdrawal of Consent

Individuals may withdraw consent by contacting [email protected].

  • Requests will be processed within 5 working days.

  • Consequences of withdrawal (e.g., inability to proceed with loan applications or employment) will be explained.

  • If additional time is required, an interim email will be sent before the 5-day deadline.

10. Accuracy of Data

We take reasonable steps to ensure that personal data is accurate and up to date, including verification against original documents, Singpass records, or MyInfo records.

11. Security and Protection 

We adopt industry-standard security practices to protect personal data against unauthorised access, disclosure, or loss. Access to personal data is restricted to authorised personnel on a need-to-know basis.

12. Retention of Personal Data

  • Customer data is retained for a minimum of 5 years after loan termination, in accordance with regulatory requirements.

  • Employee records are retained as necessary for HR, compliance, and record-keeping purposes.

13. Transfer of Personal Data outside of Singapore

The Company does not transfer data overseas.

If transfer becomes necessary, it will be done in compliance with PDPA requirements, ensuring comparable protection standards through contractual obligations, corporate binding rules, or recipient country laws.

14. Website Privacy

Cookies may be used on our website to improve the user experience. Individuals may disable cookies in their browser settings, although some site functionality may be affected.

15. Notification of Policy Changes

We will notify customers and employees of any changes to this Policy 14 days in advance through:

  • Email

  • SMS / written notice

  • Website updates

  • Internal communication channels (for employees)

16. Data Protection Officer

For any questions, concerns, or requests relating to personal data, please contact our Data Protection Officer at [email protected]. 

Employees may also contact HR through the same email address, following procedures outlined in the Internal Communication Management system.