Labamu Privacy Policy

This Privacy Policy (“Privacy Policy”) is issued by CashEnable Pte. Ltd. (“Labamu” / “We” / “Us” / “Our”), a limited liability company duly established under the laws of Singapore.

This Privacy Policy explains the Processing of your Personal Data as a user, including but not limited to when you register, access, use, and/or utilize the services, features, or facilities provided by Labamu through: (i) its website (the “Website”); (ii) the Labamu application (the “Application”); and (iii) other services provided by Us and/or connected to Third Parties.

The Website and the Application, together with the information, features, and services available therein, are collectively referred to as the “Services”.

In providing the Services, Labamu may cooperate with or use services provided by Third Parties. Any Personal Data that you provide directly to such Third Parties shall be subject to the respective privacy policies and terms of those Third Parties.

Labamu does not control and shall not be responsible for the content, privacy policies, or security practices implemented by such Third Parties, to the extent that they are beyond Labamu’s control. Therefore, you are advised to carefully read and understand the applicable privacy policies and terms of such Third Parties before using their services.

Depending on the purposes for which personal information is used, and the context in which the information is obtained, we rely on one or more of the following legal bases, subject to applicable law:

• Performance of a contract or to take steps at your request prior to entering into a contract
• Reasonably necessary for our legitimate business interests
• Compliance with a legal obligation, or 
• Your consent to the processing of your personal information

By using the Services, you acknowledge this Privacy Policy. Where required by applicable law, we will obtain your consent for specific processing activities as further described in this Privacy Policy.

A. Definition

In this Privacy Policy, including in the Introduction, unless the context or subject matter requires otherwise, the following terms shall have the meanings set out below:

You / Your mean users and/or visitors who access and/or use Our Services, whether or not you have registered and have an account;

Account means your profile obtained after you register and/or sign up through the Services, including both verified and unverified profiles;

Application means the application that We manage, operate, and provide under the “Labamu” trademark;

Business Data means identity data including business name, contact details, email address, telephone number, business category, business address, merchant ID, merchant name, merchant type, and operating profit;

Personal Data means any data relating to you as an identified or identifiable individual, whether identified separately or combined with other information, either directly or indirectly, through electronic or non-electronic systems;

Features means existing or future service products available on the Labamu Services;

Know Your Customer (“KYC”) means the identity verification process carried out to identify your identity data, which is connected with Third Parties in conducting verification and validation processes related to the Account data that you have registered on the Services;

Services means the Website and/or the Application, together with the information, Features, and services contained therein, as applicable to you as a user of the Services that We provide;

Your Customers means your customers who shop and interact with businesses supported by Labamu;

Personal Data Processor means any person, public body, or international organization that processes Personal Data on behalf of and based on the instructions of the Personal Data Controller, without having the authority to determine the purposes and means of such Personal Data Processing, unless otherwise stipulated by applicable laws and regulations;

Personal Data Processing means the processing of Personal Data carried out by Us, which includes: (i) collection and acquisition; (ii) processing and analysis; (iii) storage; (iv) enhancement and updating; (v) display, announcement, transfer, dissemination, or disclosure; and/or (vi) deletion or destruction;

Personal Data Controller means any person, public body, or international organization that, either individually or jointly with others, determines the purposes and means of Personal Data Processing and has decision-making authority over such Personal Data Processing, in accordance with applicable laws and regulations;

Third Party means Labamu’s partners or other parties that cooperate with such partners in supporting the provision of the Services that We provide to You. Examples of third parties are cloud hosting and analytics platforms. Information, products, or services from Third Parties are provided solely for Users’ convenience and shall not be construed as a recommendation or endorsement by Labamu. Furthermore, in general, the elucidation of relationship between the Services and Third Parties may be subject to Labamu’s Terms and Conditions;

Terms and Conditions means the terms and conditions governing all use of the Application and the Services.

B. Collection and Use of Personal Data

Collection of Users’ Personal Data. When you access and/or use the Services, We may collect and process Personal Data that you provide directly or indirectly, insofar as it is relevant and necessary for the provision and use of the Services and/or certain Features, including but not limited to:

• Your information, such as name, address, email address, telephone number, place and date of birth, position/title, salary slip, and other administrative information;
• Identity card information, solely for verification and KYC purposes;
• Account information, including username, password (in encrypted form), and Account settings;
• Financial, transaction, and/or bank account information, to the extent required for facilitating payment data transmission;
• Business Data that you input into the Services;
• Photographs, videos, other visual data, and/or biometric data, to the extent voluntarily provided by you or required for certain Features such as identity verification with your explicit consent; and
• Other data that you lawfully provide to Labamu in connection with your use of the Services.

Such collection of Personal Data may occur, among others, when you:

• access and/or use Features on the Services;
• register and create an account for the Services and/or other supporting services (for the purpose of building connections, relationships, and collaborations) to support the development of your business through use of the Services;
• respond to surveys, submit reviews, questions, messages, feedback, and/or suggestions, and contact Us through communication channels provided by Us;
• interact with Our official social media accounts;
• make payments, billing, or transactions related to the Services;
• grant access permissions to certain Features on your device; or
• consent to the use of cookies and related technologies, such as public information containing Personal Data and/or online news published on social media.

Your Customers’ Personal Data. If You use the Services to interact with Your Customers, clients, or other related parties, Labamu may also conduct Personal Data Processing of Your Customers to the extent necessary for the provision of the Services. Such Personal Data may include, among others:

• Your customers’ transaction information, including the names of transacting parties, transaction descriptions, types and amounts of transactions, payment methods, transaction dates and histories, and billing information; and
• Information provided by You or Your Customers, such as customer identity, full name, email address, telephone number, or other data that You input into the Services to facilitate services to Your Customers.

Consent for Your Customers’ Data. You are responsible for obtaining all necessary consents, permissions, and legal bases from Your Customers to enable Us to process such Personal Data in accordance with this Privacy Policy and applicable laws and regulations.

Data Accuracy and Responsibility. We take reasonable steps to ensure that Personal Data collected by us is accurate, complete, and up to date where such data is likely to be used to make decisions affecting individuals or disclosed to other organizations. Notwithstanding the foregoing, You bear the ultimate responsibility for the data you provide. You represent and warrant that all Personal Data that You and/or Your Customers input, upload, or submit through the Services is true, accurate, and lawfully obtained. In this regard, You agree to indemnify and hold Us harmless from any demands, claims, or actions, whether civil or criminal, arising from Your breach of the obligations referred to in this provision.

Personal Data Security by You. To the extent that such Personal Data remains under your control, You are obliged to safeguard and protect the Personal Data to prevent damage, loss, unauthorized access, or misuse by unauthorized parties, including maintaining the confidentiality of Account credentials used to access the Services.

Verification and Updating of Personal Data. From time to time, We may request that You verify and/or update Your Personal Data to ensure accuracy and compliance with applicable requirements. If You fail to carry out such verification and/or updates as requested, We reserve the right to restrict, suspend, or terminate, temporarily or permanently, Your access to part or all the Features on the Services, in accordance with Our internal policies and applicable provisions.

Involvement of Third Parties. In providing the Services, including but not limited to identity verification or KYC processes, payment processing, technology infrastructure management, and/or the provision of certain Features, You authorize Us to transfer and/or disclose Your Personal Data to Third Parties appointed by Us for the purpose of Processing Your Personal Data. Any Third Party receiving Your Personal Data shall be bound by confidentiality obligations and may only process such Personal Data in accordance with the specified purposes and applicable laws and regulations.

Labamu’s Role in Personal Data Processing. In processing Personal Data, Labamu may act as a Personal Data Controller and/or a Personal Data Processor, either independently or jointly with Third Parties, depending on the context of the use of the Services and the type of Personal Data being processed, in accordance with applicable laws and regulations.

C. Purpose of Personal Data Use

We use Personal Data obtained through the Services for lawful purposes that are relevant to the provision of the Services, including  the following purposes:

• providing, managing, and operating the Services and Features;
• conducting identity verification and KYC activities;
• transmitting transactions data and facilitating billing;
• providing support, communications, and customer services;
• improving, developing, and evaluating the quality of the Services and Features, including through analysis, research, and system testing;
• maintaining the security of the Services, and preventing and addressing fraud, misuse, or violations of the Terms and Conditions;
• complying with legal obligations and lawful requests from competent authorities; and
• we will notify you and obtain consent where required before using Personal Data for materially different purposes where relevant to the use of the Services and permitted under applicable laws and regulations.

You have the right not to provide your Personal Data and Your Customers’ Personal Data to Us. However, you acknowledge and understand that this may result in limited access to some or all Features within the Services. Where the use of the Services requires verification and/or updating of Personal Data, we will request such consent separately or at the point of collection.

D. Our Cookie Policy

Cookies are small text files consisting of information or data that are stored by Your browser or device when You access or use the Services via the internet.

We may use cookies and similar technologies to automatically collect certain information for the following purposes:

• enabling core functions of the Services, including security, authentication, network management, and accessibility;
• personalizing Your experience in using Our Services, including remembering certain preferences;
• monitoring, analysing, and evaluating the performance and effectiveness of the Services and relevant marketing activities;
• measuring aggregate usage of the Services, such as the number of visitors and pages accessed; and
• supporting the implementation of promotions or other activities available within the Services.

In providing the Services, we use the following types of cookies:

• Essential cookies, which are necessary for the Services to function properly;
• Analytics cookies, which help Us understand the use of the Services in aggregate without directly identifying You; and
• Third-party cookies, which are provided by analytics partners, social media platforms, search engines, or other related service providers.

You may manage or disable cookies through Your browser settings. However, restricting or refusing certain cookies may cause some Features of the Services to not function optimally.

We may also use other technologies such as web beacons or clear GIFs to automatically record certain information, including IP addresses, device and browser types, pages accessed, and the time and duration of use of the Services. Such information may be linked to Your Personal Data to the extent permitted under applicable laws.

E. Data Sharing Policy

We share Personal Data with Third Parties to the extent necessary for the provision of the Services, including but not limited to technology infrastructure providers, payment service providers, verification partners, delivery service providers, and other supporting service providers. The sharing of Personal Data is carried out on a limited basis and in accordance with the purposes of Personal Data Processing as set out in this Privacy Policy.

These Third Parties may have access to or process information about You as part of providing such services to Us. In general, We limit the information We provide to only that which is reasonably necessary for the service providers to perform their functions, and We require them to agree to maintain the confidentiality of such information. Third Parties agree to use such Personal Data only for the purposes determined by Us, including to:

• comply with Personal Data protection principles or other mechanisms permitted under applicable laws regarding the transfer and Processing of Personal Data; and
• provide reasonable protection for Personal Data in accordance with the safeguards set out in this Privacy Policy.

We may disclose Your information to Your company, in accordance with the information You provide during registration, to enable Us to verify Your identity for the purpose of providing the Services to You.

We may disclose Your Personal Data if required by applicable laws and regulations, court orders / requests from competent authorities, and/or where such disclosure is deemed necessary to:

• prevent, investigate, or take action against suspected violations of law;
• protect our rights, interests, or security, those of other users, or the public; or
• enforce the Terms and Conditions or this Privacy Policy.

In the event of a merger, acquisition, restructuring, or similar transaction, your Personal Data may be transferred to a successor entity, provided that it remains subject to this Privacy Policy and applicable laws.

We may process Personal Data into aggregated data or data that can no longer directly identify You. Such data may be used and shared with Third Parties for purposes of analysis, research, service development, reporting, business, or marketing, provided that such data cannot be used to personally identify You.

Your Personal Data may be stored and processed in Singapore and/or outside the territory of Singapore, including in Indonesia, provided that such storage and processing are carried out in accordance with this Privacy Policy and applicable laws and regulations. Where we transfer Personal Data outside Singapore, we will take appropriate steps to ensure the recipient is bound by legally enforceable obligations providing comparable protection.

F. Your rights

You have certain rights in relation to the Personal Data Processing in accordance with the applicable laws and regulations. However, please note that the exercise of these rights may affect Our ability to provide the Services to You optimally.

Such rights include, to the extent permitted by law:

• the right to obtain information regarding the Personal Data Processing;
• the right to access and/or update your Personal Data stored in our systems;
• the right to withdraw Your consent to certain Personal Data Processing, insofar as such withdrawal does not conflict with applicable legal obligations; and
• other rights as provided under applicable laws and regulations.  

Requests relating to the exercise of these rights may be submitted by contacting us via email at dpo@labamu.sg, with the subject line “Personal Data Subject Rights” and a clear explanation in the body of the email.

Please note that notwithstanding any modification or deletion of certain Personal Data, We may retain such information for purposes of backup, archiving, fraud prevention, misuse prevention, analytics, and compliance with legal obligations, where We reasonably believe that We have a lawful basis to do so.

G. Marketing

We will only send You marketing communications where You have provided Your clear and unambiguous consent to do so (e.g., by ticking a box at sign-up).

You may opt out of receiving marketing communications at any time by following the unsubscribe instructions included in the marketing messages; or by withdrawing Your consent by contacting Us via email at dpo@labamu.sg with the subject line “Withdraw Marketing Consent”

Please note that it may take up to 10 (ten) business days for Us to process such requests. During this period, You may continue to receive marketing communications from Us. The withdrawal of marketing consent will not affect the delivery of administrative or operational messages related to the Services.

Where required, we will comply with applicable direct marketing, unsubscribe, anti-spam, and Do Not Call requirements.

H. Personal Data Security

We implement reasonable physical, technical, and administrative security measures to protect Personal Data from unauthorized access, use, disclosure, alteration, or destruction.

Personal Data may be stored, processed, and transmitted through servers located in Singapore and/or Indonesia, and may also be stored locally on the device You use to access the Services.

Although We have implemented reasonable security standards in accordance with industry practices, the processing of Personal Data through the internet or other open networks is never completely secure, and there is a risk that Your Personal Data may be accessed by unauthorized third parties. Therefore, we cannot guarantee the absolute security of Your Personal Data.

I. Personal Data Security Failure

In the event of a failure in the protection of Personal Data that may pose a risk to Your rights and freedoms as a data subject, We will promptly notify You in accordance with applicable laws and regulations and Our internal procedures.

Such notification may be made electronically or through other means that We deem appropriate and lawful. We will deliver the notification through Your registered email address or other electronic means, by which We will use reasonable efforts to ensure that You receive such notification.

J. Data Retention and Deletion

We retain Personal Data collected only for a limited period to the extent necessary to fulfil the purposes for which it was collected, unless a retention period is required or permitted by applicable laws, regulations, or legitimate business purposes.

You may submit a request for the deletion of Your Personal Data by contacting Us at dpo@labamu.sg with the subject line “Personal Data Subject Rights”. For deletion requests, please include the following information:

• full name;
• registered email address;
• the Personal Data requested to be deleted (if specific); and
• the reason for the request (optional).

Upon receiving a valid deletion request, We will delete or irreversibly anonymize Your Personal Data without undue delay.

K. Limitation of Liability

We shall not be liable for:

• Personal Data that You voluntarily disclose or share independently through the Services;
• Your failure to safeguard the security of your Account, password, or authentication codes; and
• Any losses arising from unauthorized access caused by Your own errors or negligence.

Our responsibility for the protection of Personal Data is limited to Personal Data that is stored and managed within systems developed and operated by Us, to the extent required by applicable laws and regulations.

By continuing to use Our Services and/or Features, You agree to indemnify and hold Us harmless from any claims, demands, or losses arising from Your own breach of obligations under this Privacy Policy.

L. Notices

We may provide notices to You, whether for legal, operational, marketing, or other business purposes, through one or more of the following means:

• electronic mail;
• written notice or hard copy; and/or
• announcements or publications through the Services.

We reserve the right to determine the form and method of delivering notices to You, to the extent permitted by applicable laws and regulations.

M. Amendments and Updates to the Privacy Policy

We may amend and update this Privacy Policy from time to time for the purposes of the Services, business practices, or compliance with applicable laws and regulations.

Any amendments to this Privacy Policy shall take effect after:

• being published through the Services; and/or
• being communicated to You through communication channels deemed appropriate by Us.

You are encouraged to review this Privacy Policy periodically. We may update this Privacy Policy from time to time. If we make material changes, we will notify you through appropriate channels, such as email, in-app notice, or notice through the Services. Where required by applicable law, we will obtain your consent before applying material changes to the processing of your Personal Data.

N. General Provisions

Relationship with the Terms and Conditions. This Privacy Policy constitutes an integral and inseparable part of Labamu’s Terms and Conditions. In the event of any discrepancy, inconsistency, or differing interpretation between this Privacy Policy and the Terms and Conditions, the provisions of this Privacy Policy shall prevail to the extent they govern the Personal Data Processing.

Governing Law. This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore, including applicable personal data protection regulations.

No Waiver. Any failure by Labamu to enforce any right or provision under this Privacy Policy shall not be deemed a waiver of such right, and Labamu shall remain entitled to enforce such right at any time thereafter.

Severability. If any provision of this Privacy Policy is held to be invalid or unenforceable, the remaining provisions shall remain valid and enforceable in full force and effect.

Assignment. We may assign or transfer part or all our rights and obligations under this Privacy Policy to any other party, including but not limited to in the event of a merger, acquisition, restructuring, or transfer of assets, provided that such assignment does not contravene applicable laws and regulations.

Correspondence. For any questions, comments, or reports relating to this Privacy Policy, or if you wish to exercise your rights with respect to your Personal Data, you may contact us through:

To	:	Data Protection Officer
Address	:	9 Raffles Place, #18-21, Republic Plaza, Singapore 048619
Customer Support	:	dpo@labamu.sg