Personal Data Privacy Notice

Collection, use, and disclosure of personal data

1. From time to time, [Toast] may collect:

  1. personal data (including but not limited to names, identification particulars, date of birth, contact details, photographic identification documents, and other relevant personal information) about the User and certain persons related to the User, including persons to whom Users remit money or receive money from (the “Related Persons”); and

  2. information and data (including but not limited to physical and electronic signatures, answers to questions intended for security verification, emergency contact numbers, or other contact details) generated in the ordinary course of the User’s relationship with [Toast].

Personal data of Users and Related Persons may be processed, kept, transferred, or disclosed in accordance with the Personal Data Protection Act 2012.

Deemed Consent

2. The User is deemed to have consented and to have obtained the consent of all Related Persons to the collection, use, and disclosure of the abovementioned personal data and information in connection with the User’s interactions with [Toast].

Purposes for which Information is Used and Disclosed

3. Information and data may be used and disclosed to places in or outside Singapore to (collectively, “Permitted Purposes”):

  1. facilitate the remittance of monies between countries;

  2. facilitate the conversion of fiat currencies into digital currencies and vice versa;

  3. verify Users’ identities at any point in time before and after Users create a [Toast] account;

  4. make decisions relating to the [Toast] account of any User; and

  5. carry out or respond to requests, questions, or instructions from government agencies, regulatory authorities, or courts of competent jurisdiction.

Parties to whom Personal Data may be Disclosed

4. Personal data may be disclosed, where permitted by applicable law, to the entities (inside or outside Singapore) below (please note this is not an exhaustive list) for the Permitted Purposes or for processing in accordance with any of the Permitted Purposes on a need-to-know basis:

  1. any agent, contractor, or third party services provider who provides banking, remittance, administrative, mailing, telecommunications, call centres, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, payment, debt collection, credit reference checks, or other services to [Toast] in connection with the operation of the business of [Toast];

  2. any person or entity which is part of [Toast] and is under a duty of confidentiality to the disclosing [Toast] entity, although only to the extent necessary to fulfil the relevant Permitted Purposes;

  3. any person or entity to whom [Toast] is under an obligation or otherwise required to make disclosure pursuant to any legal process, or any other foreign or domestic legal and/or regulatory obligation, including disclosure to courts, tribunals, and/or legal, regulatory, tax, and government authorities;

  4. any actual or proposed assignee of [Toast] or transferee of [Toast]’s rights in respect of any User, or all or any part of the assets or business of [Toast]; or

  5. any party giving or proposing to give a guarantee or third party security to guarantee or secure the obligations of the User.

[1] “User” means any natural person or legal entity which creates an account with [Toast].