Privacy Policy

1. CONTROLLER AND CONTACT

1.1. This Privacy Policy is issued by AQUAPAY PTE. LTD., a company registered in Singapore (“AQUAPAY”), operating under the COREDO brand. AQUAPAY, as the COREDO group entity providing services to you, is the controller of your personal data in connection with those services. For website visitors without an engagement, the website operator identified in the website footer is the controller.

1.2. For any questions about this Privacy Policy or about the processing of your personal data, please contact us at the email address indicated in the website footer.

2. PERSONAL DATA WE COLLECT

2.1. We may collect and process the following categories of personal data, depending on the nature of your interaction with us:

• Contact and identification data: name, email address, telephone number, postal address, company name and position, and any other information you provide through forms on the website or in direct communication with us.
• Engagement data: information provided or generated in connection with our services, including correspondence, instructions, documents and deliverables.
• KYC and compliance data: where required by applicable regulatory requirements, we may collect identification documents, proof of address, information on beneficial ownership, source of funds, politically exposed person status and other information necessary for customer due diligence.
• Payment data: invoicing details, payment instrument details and payment history.
• Website usage data: IP address, browser type, operating system, pages visited, time and date of access, and similar technical data collected automatically, including through cookies (see our Cookie Policy).

2.2. Most personal data is provided directly by you. We may also obtain data from publicly available sources, screening databases, identity verification providers and other third parties where necessary for the provision of services or compliance with applicable law.

3. PURPOSES AND LEGAL BASES

3.1. We process your personal data for the following purposes:

• Performance of a contract: to provide services to you, communicate with you in connection with an engagement, issue invoices and process payments.
• Compliance with legal obligations: to comply with anti-money-laundering, sanctions, tax, accounting, regulatory reporting and other legal requirements applicable to the relevant COREDO group entity.
• Legitimate interests: to respond to enquiries, protect our rights and prevent fraud, improve our services and website, and maintain internal administration.
• Consent: where you have given consent for a specific purpose, such as receiving marketing communications. You may withdraw consent at any time by contacting us.

4. RECIPIENTS AND SECURITY

4.1. We may share your personal data with the following categories of recipients, to the extent necessary for the purposes described in this Privacy Policy:

• other COREDO group entities, where necessary for the administration or performance of services;
• subcontractors and third-party service providers, including identity verification and compliance screening providers;
• auditors, insurers, banks, payment institutions and professional advisers;
• competent authorities, courts or regulators, where required or permitted by applicable law.

4.2. We require all recipients to process personal data in accordance with applicable data protection law and to maintain appropriate confidentiality and security measures. We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration or disclosure.

5. INTERNATIONAL TRANSFERS

5.1. Your personal data may be transferred to and processed in jurisdictions other than the one in which you are located. Where such transfers take place, we implement appropriate safeguards, such as standard contractual clauses, intra-group agreements or other mechanisms recognised under applicable data protection law.

6. RETENTION

6.1. We retain personal data for as long as necessary to fulfil the purposes for which it was collected, including to comply with applicable legal, regulatory, accounting and reporting requirements. After the applicable retention period, personal data is securely deleted or anonymised.

7. YOUR RIGHTS

7.1. Subject to applicable law, you have the right to request access to, rectification or erasure of your personal data, to request restriction of processing, to object to processing, to data portability, and to withdraw consent where processing is based on consent. To exercise any of these rights, please contact us at the email address indicated in the website footer.

7.2. In certain cases we may not be able to fully comply with your request due to overriding legal obligations or other lawful grounds. We will inform you of the reasons in such cases.

7.3. You also have the right to lodge a complaint with the competent supervisory authority.

8. COOKIES

8.1. We use cookies and similar technologies on the website. For details, please refer to our Cookie Policy published on the website.

9. THIRD PARTY LINKS

9.1. The website may contain links to third-party websites. We are not responsible for the privacy practices or content of such websites.

10. CHANGES

10.1. We may update this Privacy Policy from time to time. The current version is published on the website with the version date indicated above.