This Privacy Policy sets out the terms, conditions, situations and basis on which we may collect, use, disclose, store, transfer and/or otherwise process any information or data to which the Personal Data Protection Act 2012 (the “Act”) applies (“Personal Data”).

Please note that this Privacy Policy shall apply to your use of or access to the Site and/or Services. You acknowledge that you have read, understood and agree with the terms of this Privacy Policy and consent to the collection, use, disclosure, storage, transfer and/or processing of your Personal Data in accordance with and for the Purposes set out below. If you do not agree, do not use or access the Site and/or Services.

We reserve the right to change, modify and/or update this Privacy Policy at any time as we may determine in our sole and absolute discretion. Any such changes, modifications or updates shall be effective from the date posted here. It shall be your responsibility to periodically check and review the Privacy Policy and your continued use of the Site and/or Services shall constitute your agreement and acceptance of the Privacy Policy published here.

  1. Definitions

    Unless otherwise defined herein, the terms defined in the Terms of Use are adopted by reference. In addition, the following words and express shall have the following meanings:

    1. “Accounts” mean any one or more the accounts you establish with us on the Site, through which you access and/or operate the Services or Platform and/or such other services as we may offer and for which you may have subscribed and shall include any of your Admin Accounts or User Accounts.
    2. “Clauses” mean clauses of this Privacy Policy.
    3. “Corppass Account” means the account created by you or on your behalf with the authorisation system for corporate entities provided by the Government of Singapore through which you or your employer perform corporate transactions.
    4. “Data Processing” means, in relation to Personal Data, the carrying out of any operation or set of operations in relation to the Personal Data and includes any of the following: (a) recording; (b) holding; (c) organization, adaptation or alteration; (d) retrieval; (e) combination; (f) transmission; and/or (g) erasure or destruction.
    5. “Data Protection Officer” shall have the meaning described at Clause 5.1 below.
    6. “Data Intermediary” means an organization which processes personal data on behalf of another organization but does not include an employee of that other organization;
    7. “Designated Party” and “Designated Parties” mean one or more of the banks, financial institutions, lenders and/or service providers with which you may potentially enter into Third Party Arrangements with in connection with your use of the Services or Platform.
    8. “Guud”“we”“us” or “our” mean Guud Asset Pte Ltd and the “Group” shall mean Guud Asset Pte Ltd, its respective subsidiaries, affiliates and associated companies (which shall include its related and jointly controlled entities), which for the avoidance of doubt shall include but not be limited to CamelOne Pte Ltd, Guud (Finance) Pte Ltd, Guud (Singapore) Pte Ltd, Guud (Africa) Pte Ltd, Guud (International) Pte Ltd, Guud (Source) Pte Ltd, PT GUUD Logistics Indonesia , Guud Asset Argon Pte Ltd, Guud Asset Boron Pte Ltd and Guud Pte Ltd.
    9. “Personal Data” means data and information, whether true or not, about a person (whether the User or otherwise) who can be identified from: (a) that data or information; (b) from that data and other information to which we have or are likely to have access to; and/or (c) the data or information provide, furnished or uploaded by you in connection with your use of the Services or the Site, but shall not include any data or information to which the Act does not apply.
    10. “Platform” shall mean the restricted areas or parts of the Site accessed by you through the Account (whether on the web, via any mobile or other computing device or through any mobile applications made available by us).
    11. “Privacy Policy” means the terms, conditions and contents of this privacy policy as published on as may be changed, modified, supplemented, revised or updated from time to time.
    12. “Purposes” mean any one or more of purposes or reasons set out at Clauses 3.1 to 3.13 below.
    13. “Services” shall mean your use of or access to the Site or the Platform as requested by you.
    14. “Site” means and shall include all other associated websites or webpages within the clickargo domain.
    15. “Terms of Use” means the terms and conditions applicable to the Site published at
    16. “User”“you” and “yours” means any corporate or natural person that uses, accesses and/or utilises the Site, Services, Account or Platform including any individual through which the User accesses, uses and/or utilises the Site, Services, Account or Platform.
    17. The headings herein for convenience only and shall not affect the interpretation of this Privacy Policy.
    18. Unless the context otherwise requires, references to the singular number shall include references to the plural number and vice versa, references to natural persons shall include bodies corporate, and the use of any gender shall include all genders.
  2. Personal Data
    1. Consent: It shall be a condition of your use of the Site and/or Services that any Personal Data provided, furnished, uploaded or otherwise disclosed by you to us (whether through the Site or otherwise) is:
      1. For the Purposes stated in this Privacy Policy; and
      2. Made with your consent or the consent of the individual(s) identified by or in the Personal Data unless such consent is revoked in accordance with Clause 5 below.
    2. Provision: We collect Personal Data when you voluntarily provide it to us. For example, you may provide Personal Data (such as identification, contact, employment and/or financial information) to us when you:
      1. Provide us with information or documents when creating a user profile or completing the applicable registration forms in connection with an application for the Services;
      2. Verify your identity and/or credentials through various means (including, where applicable, through your Corppass Account) when you access, log into and/or operate the Account;
      3. Access, utilise or operate Services or Platform available on or facilitated through the Site.
    3. Collection: Depending on the nature of your interaction with us, some examples of Personal Data we may collect from you include but are not limited to:
      1. Your name, identification information or government issued identification numbers;
      2. Place and date of birth or incorporation;
      3. Contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information;
      4. Corporate or shareholder information including annual returns, financial statements, audited accounts, list and details of members and information, details, notices or resolutions lodged by you or on your behalf with the Accounting and Corporate Regulatory Authority of Singapore or such other government or regulatory authority as may be applicable;
      5. Employment and/or financial information such as credit card numbers, debit card numbers or bank account information such as bank account details, bank statements and credit history;
      6. Where applicable, all such Personal Data of any of your directors, officers, agents, employees or representatives (howsoever described); or
      7. Information provided, furnished and/or uploaded by you to us in connection with your access or use of the Site and/or the Services constituting Personal Data.
  3. Collection, Use and Storage

    You agree and consent to the Group’s collection, use and storage of any Personal Data you voluntarily provide to us for any or all of the following purposes or reasons (collectively referred to as the “Purposes”):

    1. Verifying your identity, entitlement or authorisation:
      1. To use or access the Site and/or Account;
      2. Providing the Services requested or applied for by you; and/or
      3. Facilitating and/or processing payments (whether to us or otherwise) and managing your relationship with the Group;
    2. Executing the operation, fulfilment and administration of the Services and/or functions or features of the Site such as the Platform;
    3. Conducting or facilitating audits for the purposes of meeting legal requirements, compliance or industry standards or as may be desirable to enhance the standing, quality, scope and capacity of the Site and/or Services;
    4. Conducting applicable due diligence or observing our internal know-your-client and anti-money laundering protocols as may be required, necessary or applicable;
    5. Communicating with you to inform you of changes to the Site, Services and/or our policies, terms and conditions and other administrative information;
    6. Responding to, handling, and processing queries, requests, applications, or feedback from you as well as monitoring the Site and/or Services;
    7. To comply with our obligations or to enforce our rights in connection with the Site and/or Services, including but not limited to complying with any applicable law, judgment, order, code, standard or regulation and participate in (or co-operate with) legal, regulatory or administrative proceedings or directions;
    8. Transmitting, sharing, disclosing and/or providing such Personal Data to unaffiliated third parties, including relevant governmental or regulatory authorities, whether in Singapore or abroad, for the Purposes;
    9. Protecting and safeguarding the operation of the Site and/or Services including preventing, detecting, reporting and supporting or assisting in investigations into any crime (including fraud, theft, money laundering, terrorism misuse or abuse of the Site and/or the Services), cybersecurity incidences or risks, or any of the same where suspected
    10. Conducting data analytics, including (but not limited to) matching and profiling you to provide you with features and functions of the Site and/or the Services which may be relevant or of interest to you and to improve your user experience and for the purposes of enhancing the Site or the Services or developing new product or service offerings provided by the Group; and
    11. Any other purposes or reasons for which you have provided the information, including any other incidental business, marketing or commercial purposes related to or in connection with the Purposes; and
    12. In relation to this Clause 3 (and its sub-clauses), Personal Data protected by the Act will be aggregated and/or anonymized, such that no one individual can be identified or recognized from the user statistics in question. You acknowledge and agree that any anonymised data is not personal data and that we have the right to share and disclose such anonymized data with third parties for any purposes.
    13. The Purposes may continue to apply (for such period as may be reasonably necessary) even in situations where you cease to use the Services or where your access to your Account and/or your relationship with us has been terminated or altered in any way, e.g., where we enforce our rights or powers under this Privacy Policy, the Terms of Use, the Services Agreement and/or such other agreements, guidelines or policies as may be applicable.
  4. Disclosure

    You agree and consent to our disclosure of your Personal Data:

    1. To any one or more of the Designated Parties or members of the Group where such disclosure is required or reasonably necessary for the provision of the Services (in particular your access to and/or operation of the Account and Platform) or in connection with managing your relationship with any member of the Group; and
    2. To third party service providers, agents, and other organisations we may engage to perform any one or more of the Purposes for us.
  5. Withdrawal of Consent
    1. The consent provided at Clause 2 above in relation to the collection, storage, use and/or disclosure of Personal Data for the Purposes shall remain valid until such time it is withdrawn by written request submitted to our Data Protection Officer at the contact details below:

      Guud Asset Pte Ltd
      2 Tanjong Katong Road
      Singapore 437161
      Attention: The Data Protection Officer

    2. Upon receipt of such written request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
    3. Please note that depending on the nature and scope of your request, we may not be in a position to continue providing the Services to you and shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described at Clause 5.1 above.
    4. Please note that the withdrawal of consent does not affect our right to continue to collect, store, use and/or disclose Personal Data where we are permitted or required to do so under applicable laws.
  6. Access and Correction
    1. If you wish to make (a) an access request for access to a copy of the Personal Data provided by you or information about the ways in which we use or disclose such Personal Data; or (b) a correction request to correct or update any of Personal Data provided by you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided at Clause 5.1 above.
    2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
    3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Act).
  7. Protection of Personal Data
    1. To safeguard Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as making reasonable security arrangements to prevent (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal, or similar risks; and (b) the loss of any storage medium or device on which personal data is stored.
    2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
  8. Accuracy and Retention of Personal Data
    1. In providing the Services, we (and the applicable Designated Parties) may rely on the information and/or documents provided, furnished and/or uploaded by you, whether or not such information or documents contain Personal Data.
    2. In the event the information and/or documents provided, furnished and/or uploaded by you is incorrect or misleading, we reserve the right to take such steps as may be necessary to protect our rights, including but not limited to commencing legal proceedings against you.
    3. In order to ensure that the documents and information you have provided us (including but not limited to your Personal Data) is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided above at Clause 5.1.
  9. Transfer or Export of Personal Data
    1. In submitting personal data to us, you agree that the Personal Data may be transferred or exported to locations in other territories outside of your location for the purposes of Data Processing by Data Intermediaries.
    2. Where such Personal Data is so transferred or exported, we endeavour to do so in each instance in accordance with applicable laws and, as far as practicable, require such Data Intermediaries to comply with all applicable laws and to provide an equivalent standard of protection for such personal data as such personal data would have received had the personal data remained in your territory. Such personal data may be stored in servers operated by third party service providers.
  10. Retention of Personal Data
    1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, including one or more of the Purposes, or as required or permitted by applicable laws.
    2. We will cease to retain your Personal Data or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected and is no longer necessary for legal or business purposes.
  11. Cookie Policy
    1. You agree that we or our authorised service providers may use cookies, web beacons, and other similar technologies in connection with your use of the Site and/or Services.
    2. As with most other websites, we collect and use the data contained in log files. The information in the log files include your IP (internet protocol) address, your ISP (internet service provider), the browser you used to visit the Site, the time you visited the Site, and which pages you visited throughout the Site. When you visit or interact with the Sites or Services, we or our authorized service providers may use cookies, web beacons, and other similar technologies for collecting and storing information to help provide you with a better, faster, and safer web experience.
    3. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow us to recognise a particular device or browser. Web beacons are small graphic images that may be included on our Services and the Platform. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.
    4. You may be able to manage and delete cookies through your browser or device settings. However, certain cookies are required to enable core functionality (such as the submission of any application by you through the Platform), so please note that changing and deleting cookies may affect the Services and/or functionality available on the Site.
  12. Miscellaneous
    1. Application: This Privacy Policy only applies to Personal Data protected by the Act and shall not include any other information, data or documents provided, furnished and/or uploaded by you.
    2. Transfer: We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the Act.
    3. Nature of Privacy Policy: This Privacy Policy applies in conjunction with such other notices, contractual clauses and/or consent clauses that apply in relation to the collection, use, disclose, store, transfer and/or otherwise process collection, storage, use, disclosure and/or processing of your Personal Data by us and is not intended to override them unless we state expressly otherwise.
    4. Acknowledgement and Acceptance: As stated above, we reserve the right to change, modify, revise and/or supplement this Privacy Policy at any time and in any manner as we may, in our sole absolute discretion, think fit. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of the Site and/or the Services constitutes your acknowledgement and acceptance of such changes.
    5. Indemnity: Without prejudice to any other rights we may have under this Privacy Policy or elsewhere, you agree to fully indemnify and hold us (and any of our affiliates, members, directors, officers, employees and agents, collectively, the “Indemnified Parties”) from and against any claim, demand, loss, damage, cost, or liability (including legal costs and expenses on an indemnity basis) which any of the Indemnified Parties may suffer or suffers in connection with or arising from your breach of this Privacy Policy.
    6. User’s Duties and Responsibilities
      1. You shall be solely responsible for maintaining the security and confidentiality of any personal data provided, furnished and/or uploaded by or through you (including, without limitation, any user credentials). Further, where any of the Site and/or Services is installed or accessed via any device, you agree that you will safeguard the access to the use of the same on that device by applying security measures as may be reasonably appropriate.
      2. We will not be responsible for any unauthorised use of the Site and/or Services by you, users who act on your behalf or any unauthorised users. It is your responsibility to make your own informed decisions about the use of the Services and take necessary steps to prevent any misuse of the Services.
    7. Minors: We do not provide the Services to minors and, accordingly, do not knowingly collect any minor’s personal data. You hereby confirm and warrant that you are above the age of majority, and you are capable of understanding and accepting the terms of this Privacy Policy.
    8. Other Sites: The Site may contain links to other websites operated by other parties, such as our business affiliates, merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable privacy policies of those websites to determine how they will handle any information they collect from you.
    9. Third Parties: Save for the rights of the Indemnified Parties who are entitled to enforce Clause 12.5 above, a person who is not a party to these this Privacy Policy shall have no right under the Contracts (Rights of Third Parties) Act (Cap. 53B) to enforce any of its terms and conditions.
    10. Governing Law: The Privacy Policy shall be governed by and construed in accordance with Singapore law.
    11. Dispute Resolution: Any dispute arising out of or in connection with this Services Agreement, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this clause. The Tribunal shall consist of a single arbitrator and the language of the arbitration shall be English.

    Effective date : 01 Apr 22
    Last updated : 01 Apr 22

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