Privacy Policy

PRIVACY POLICY

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Welcome to ultraflowai.com, an online website (including its mobile version) (the “Website”), which is operated by Pinnacle Oak Investments Pte. Ltd. (UEN 202519603M) (hereinafter referred to as “Company”, “we”, “our” or “us”).

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We take our responsibilities under applicable privacy laws and regulations seriously, and we are committed to respecting the privacy rights and concerns of all users of our Website (the Website and the services we provide are collectively termed the "Services"). “User” refers to a user who visits the Website and/or uses our Services. 

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This Privacy Policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the Personal Data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your Personal Data.  

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"Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of Personal Data could include name, identification number and contact information. This Privacy Policy applies to all Personal Data collected by the Company, operating in the capacity of a data principal or a data intermediary, from all visitors to the Website; or (b) users of the Services (collectively, “Users”, “you” or “your”).

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By using the Services or visiting our Website, you acknowledge and agree that you have read, understood and agree to be bound by this Privacy Policy and you hereby consent to us collecting, using, disclosing and/or processing your Personal Data as described herein. 

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If you do not consent to the processing of your Personal Data as described in this Privacy Policy, please do not use our Services or continue accessing our Website. Your continued use of the Website and/or Services shall be deemed to be your unconditional acceptance and acknowledgment of, and consent to be bound by, this Privacy Policy.

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We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Services or the Website shall constitute your acknowledgment and acceptance of any such changes made to this Privacy Policy.

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  1. DEFINITIONS AND INTERPRETATION

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In this Privacy Policy, unless otherwise defined or where the context otherwise requires, the following definitions shall apply:

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“process”, “processes” or “processing”

: means any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, holding, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; and

“Terms & Conditions”

: means the terms and conditions for the use of the Website which can be accessed via a link on the Website, as from time to time amended, varied and/or supplemented. 

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  1. PURPOSE

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  1. In the course of operating the Website and providing the Services to you, the Company will obtain Personal Data about you. This Privacy Policy informs you of how the Company processes, manages and safeguards such Personal Data. For avoidance of doubt, this Privacy Policy does not apply to anonymised data, or information which cannot be used to identify any individual person.

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  1. This Privacy Policy supplements but does not supersede nor replace any consent that you may have otherwise provided to the Company in respect of your Personal Data. Your consents herein are additional to any rights which the Company may have at law to collect, use or disclose your Personal Data.

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  1. In case of conflict between any terms in this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail. 

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  1. PERSONAL DATA COLLECTED

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  1. We collect Personal Data that you voluntarily submit to us or which is obtained directly from you, including through telephone calls, face-to-face meetings, or other forms of correspondence whether in physical, written, electronic or other form, permanent or otherwise. You may be asked at any time during the engagement of the Services and/or use of the Website to provide Personal Data for the purposes in this Privacy Policy. By providing the same, you consent to for us to process such Personal Data. If you do not consent for us to collect or process your Personal Data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the paragraph below entitled “Rights in relation to Personal Data”. Note, however, that opting out or withdrawing your consent for us to collect, use or process your Personal Data may affect your use of the Services and the Website. 

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  1. We may collect Personal Data about you from you, our affiliates, third-parties, and from other sources, including without limitation our business partners (such as logistics or payment service providers), credit bureaus or scoring agencies, marketing service providers or partners, referral or loyalty programs, third-party websites, social media services, other users of our Services or publicly available or governmental sources of data.

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  1. In some situations, you may provide Personal Data of other individuals to us. If you provide us with such Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be processed in accordance with this Privacy Policy.

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  1. You warrant that all Personal Data submitted to the Company, whether via the Website or otherwise, is true, accurate, reliable, valid, complete and is not misleading does not violate any applicable law, by omission or otherwise. In the event of any change to such Personal Data provided to the Company, you should notify the Company immediately via the email in paragraph 13 below. 

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  1. Our collection of Personal Data is made pursuant to legitimate interests of the Company and for the purposes of complying with applicable law, in particular relating to money laundering and fraud prevention. As such, if need be, the Company may request other documents to verify any information provided by you. 

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  1. OTHER DATA COLLECTED

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  1. As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Website. This typically includes your device’s Internet Protocol (IP) address (“IP Address”), computer/mobile device operating system and browser type, type of computer/mobile device, the characteristics of the computer/mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your computer/mobile device, the address of a referring web site (if any), the pages you visit on our Website and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. The information is also included in anonymous statistics to allow us to understand how visitors use our Website. 

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  1. Our Website may collect precise information about your location using technologies such as GPS, Wi-Fi, cookies etc. We collect, use, disclose and/or process this information for purposes including location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our Website. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer. 

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  1. We or our authorized service providers and advertising partners may from time-to-time use "cookies" or other features to allow us or third-parties to collect or share information in connection with your use of our Services or Website. These features help us monitor and improve our Website and our Services, offer new services and features, and/or enable us and our advertising partners to serve more relevant content to you, including through remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that record data about computer or device, how and when the Services or Website are used or visited, by how many people and other activity within our Website. We may link cookie information to Personal Data. As and when you view pages on our Website, access other software on our Website or the Services, some information may be sent to us such as the IP Address, operating system, the content or advertisement viewed and/or software installed by the Services and the Website and time.

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  1. You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Website or the Services.

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  1. PROCESSING AND DISCLOSURE OF PERSONAL DATA

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  1. Your Personal Data is processed only for specific purposes, and the processing is limited to what is necessary in relation to these purposes. We may process or disclose your Personal Data for the following purposes:

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  1. to provide the Services to you;

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  1. to process the information provided by you for the purpose of providing the Services to you, including the verification of your Personal Data;

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  1. to manage and maintain your records with us during the provision of the Services to you, including facilitating any transactions with you;

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  1. to carry out the Company’s obligations and duties under the Terms & Conditions, including to prevent or investigate any actual or suspected violations of our Terms & Conditions, any applicable agreements, or any negligence, misconduct, fraudulent or unlawful acts or omissions whether relating to your use of our Services or any other matter arising from your relationship with us;

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  1. to communicate with you including responding to your requests, enquiries and/or complaints, and resolving disputes;

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  1. for identification, verification, due diligence, or know-your-customer purposes;

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  1. to perform assessments and analysis for purposes of improving our Services and the customer experience;

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  1. for marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to the Services that we may be providing, marketing or promoting;

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  1. to meet the Company’s legal, regulatory and contractual obligations under any applicable law, such as anti-money laundering, counter-terrorist financing, anti-tax evasion and prevention of fraud regulations, automatic exchange of information, including disclosures to regulators, tax authorities, and other governmental or judicial authorities;

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  1. for the Company’s prudential and operational management (including risk management, audit, compliance, outsourcing of services, business and financial decision-making);

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  1. to collect any debt due or owing and to enforce your obligations to the Company;

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  1. to ensure or enhance network and information security; 

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  1. to respond to any threatened or actual claims asserted against the Company or other claim that any content violates the rights of third-parties;

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  1. to store, host, back up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside of your jurisdiction;

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  1. to manage credit provided to you (where applicable);

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  1. to arrange for the payment of third party services on behalf of you (where applicable); and/or 

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  1. for any other purpose which the Company may notify you of from time to time,

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(collectively, the “Purposes”).

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  1. For the avoidance of doubt, any unsolicited information or materials (even if they may be Personal Data) sent to the Company whether via the Website or other communication channels, regardless of whether the Company is the intended recipient, will not be considered confidential or proprietary. 

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  1. In conducting our business, we may need to use, process, disclose and/or transfer your Personal Data to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third-parties, for one or more of the Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third-parties would be processing your Personal Data either on our behalf or otherwise, for one or more of the Purposes. We endeavour to ensure that the third-parties and our affiliates keep your Personal Data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your Personal Data only for as long as your Personal Data is needed for the Purposes. Such third-parties include, without limitation:

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  1. our subsidiaries, affiliates and related corporations; 

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  1. service providers under contract with us who help with the Company’s business operations and the provision of the Services;

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  1. third-parties to whom disclosure by us is for one or more of the Purposes and such third-parties would in turn be collecting and processing your Personal Data for one or more of the Purposes; 

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  1. a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going-concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Data held by the Company about our Users is among the assets transferred, or to a counterparty in a business asset transaction that the Company or any of its affiliates or related corporations is involved in; and/or

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  1. governmental, regulatory or judicial authorities, or any person connected to the exercise, enforcement or preservation of the Company’s legal and contractual rights.

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  1. We will destroy or anonymize your Personal Data when we have reasonably determined that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; or (ii) retention is no longer necessary for any legal or business purposes; or (iii) no other legitimate interests warrant further retention of such Personal Data.

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  1. RIGHTS IN RELATION TO PERSONAL DATA

  1. Rights of access, correction and deletion

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  1. You are entitled to review, correct, amend or delete any part of your Personal Data provided to the Company which is inaccurate, incomplete, misleading or not up-to-date. You may do this at any time by contacting us via the email provided in paragraph 13 below for data that is not available for change on the Website, and we will correct or update the data as soon as practicable.

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  1. You have a right to request for a copy of your Personal Data provided to the Company. This information will be provided without undue delay subject to a reasonable fee (as permitted by applicable law), unless such provision adversely affects the rights and freedoms of others. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

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  1. When handling data access, correction, restriction, deletion, or portability requests, the Company shall be entitled to check the identity of the requesting party to ensure that he is the person entitled to make such request. We may also refuse such request in accordance with applicable laws. 

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  1. Right to restrict, object, or withdraw consent

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  1. You have the right to restrict, object to, or withdraw your consent for, the processing of your Personal Data by the Company at any time by writing to us.

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  1. Any such restrictions, objections or withdrawal will not affect the lawfulness of the Company’s processing of your Personal Data based on consent obtained before the restriction, objection or withdrawal. This shall also not affect the lawfulness of the Company’s continued processing of your Personal Data if it is necessary and/or permitted under applicable law. 

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  1. Upon receipt of such a request, the Company reserves the right to take necessary actions, including to cease or limit the provision of Services and/or access to the Website to you, and to terminate any agreements you may have with us. The Company’s legal rights and remedies are expressly reserved in such event. 

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  1. Right to erasure

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  1. You have the right to request erasure of your Personal Data subject to limitations by applicable law relevant to data protection.

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  1. For the avoidance of doubt, you shall not have such right to request erasure if the deletion of such data may result in loss of data integrity and auditable records, and therefore be necessary for the Company to comply with applicable law or for the establishment, exercise or defence of legal claims. You expressly acknowledge and agree to the non-erasure of your Personal Data in such circumstances. 

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  1. Upon receipt and approval of such a request, the Company shall insofar as the data is stored in electronic form, take steps to ensure that it is securely deleted, erased or destroyed. The Company shall require a reasonable amount of time to process and effect any erasure of data. Depending on the nature of your request, the Company reserves the right to take necessary actions, including to cease or limit the provision of Services and/or access to the Website to you, and to terminate any agreements you may have with us. The Company’s legal rights and remedies are expressly reserved in such event. However, the Company can continue to process your Personal Data if it is necessary and/or permitted under applicable law. 

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  1. Right to data portability 

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You may elect to receive copies of your Personal Data in a structured, commonly used and machine-readable format, and to have the Company transfer your Personal Data directly to another party, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others (e.g. where providing the Personal Data we hold about you would reveal information about another person). We are not responsible for the security of the Personal Data or the processing of the same once received by a third-party.

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  1. Right to lodge a complaint

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  1. If you believe that your rights have been infringed in any way, we encourage you to first contact the Company via the email in paragraph 13 so that we can try to resolve the issue or dispute amicably. 

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  1. Subject to paragraphs 7.2 and 7.3 below, you may also complain about the Company's processing of your Personal Data to the relevant governmental agency. 

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  1. COMPLAINTS UNDER THE EUROPEAN GENERAL DATA PROTECTION REGULATIONS AS APPLICABLE TO PERSONAL DATA OF EU PERSONS

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  1. As the Company serves customers globally, we may collect Personal Data from individuals and institutions located within the European Economic Area, and the Company is responsible for ensuring that it uses such Personal Data in accordance with the General Data Protection Regulation (“GDPR”).

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  1. Where the GDPR applies to you, by accessing the Website and/or the Services, or sending us any Personal Data, you hereby acknowledge and agree not to make any complaint to any governmental agency unless you have first brought the complaint to the Company’s attention and followed the process in paragraph 7.3 below.

 

  1. For any issues which you may have with the Company with regard to your Personal Data, you agree to the following process: 

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  1. You shall inform the Company of your issue or complaint in writing via the email given at the end of this Privacy Policy or on the Website. Your email shall set out in sufficient clarity and detail your issue or complaint. 

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  1. The Company shall use reasonable endeavours to work with you to resolve the issues or complaints raised in your email within ninety (90) days. You agree to co-operate fully with the Company, which shall include providing the Company with any requested information or documents in a timely manner. 

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  1. If parties fail to resolve the said issues or complaints within ninety (90) days, you shall then have the right to settle any disputes in accordance with these Terms & Conditions.

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  1. INTERNATIONAL TRANSFERS OF PERSONAL DATA

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Your Personal Data may be transferred to, stored or processed outside Singapore for one or more of the Purposes. We will only transfer your Personal Data overseas in accordance with applicable laws.

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  1. SECURITY

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  1. The Company has implemented technical and organisational security measures to ensure the confidentiality, integrity and accountability of all Personal Data collected and to protect it from unauthorised access and disclosure, loss, misuse, alteration or destruction. However, we cannot guarantee the security of any Personal Data collected from or about you.

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  1. Where your consent has been obtained, or where the Company is obliged to pass on Personal Data to third-parties to provide you with a requested service or in the carrying out of our obligations under applicable law, the Company will request that the same levels of technical and organisational security measures be applied, where possible. However, the Company is not responsible for any security breach on the part of such third-party service providers.

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  1. In the event of a security breach or the failure of the measures of protection of such Personal Data in our systems or that of any engaged third-party service providers, the Company will notify you in accordance with this Privacy Policy and/or the Personal Data Protection Act 2012. 

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  1. You acknowledge that you play a vital role in protecting your own Personal Data. The Company cannot guarantee or warrant the security or confidentiality of information you transmit to us or received from us by internet or wireless connection (including email, phone, or SMS). If you have reason to believe that your Personal Data is no longer secure, you should notify the Company immediately via the email in paragraph 13 below.

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  1. You are responsible for your own security when dealing with third-parties, including third-parties who may make themselves out to be the Company or related to the Company. If you discover any fraud, phishing, or scam which impersonates the Company, you should notify the Company immediately via the email in paragraph 13 below.

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  1. MARKETING

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  1. You consent to the use of your Personal Data to be processed for direct marketing by the Company.

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  1. With such consent, the Company may send information from time to time to you including promotions for the Company’s products or Services, events that the Company is hosting or participating in, or product updates and features. 

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  1. You have the right at any time to revoke and object to such use of your Personal Data for the use of direct marketing by contacting the Company via the email stated below.

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  1. CREDIT REPORTING

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  1. By using the Services, where credit terms may be provided, you agree that the Company may obtain from a credit-reporting agency a credit report which may contain personal credit information about you in relation to credit that we may provide.

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  1. The Personal Data may also be used by us to notify other credit providers of a default by you, to exchange information with other credit providers as to the status of this credit account and to assess your credit worthiness.

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  1. You consent to us being given a consumer credit report to collect overdue payment on commercial credit.

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  1. CHANGES TO THIS PRIVACY POLICY 

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  1. This Privacy Policy may be supplemented, varied or amended from time to time at the Company’s discretion by publishing the revised Privacy Policy on the Website. Such revised Privacy Policy shall be effective immediately and shall apply and bind parties from the date of its publication on the Website. You should therefore carefully read the Privacy Policy each time you visit the Website so that you are apprised of such changes. 

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  1. If you do not agree to any terms of the revised Privacy Policy, you should not continue to visit, access, or use the Website, or any Services. For the avoidance of doubt, your continued use of the Website and/or Services shall be deemed to be your unconditional acceptance and acknowledgment of, and consent to be bound by, the prevailing terms of this Privacy Policy.

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  1. CONTACTING THE COMPANY

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If you have any questions or complaints about or relating to the Personal Data collected by the Company or wishes to contact the Company under the terms of this Privacy Policy, you may contact us using the “Contact” details on the Website or at contact@pinnacleoakinvestments.com.

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  1. CONSENT AND ACKNOWLEDGEMENT

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  1. By visiting, accessing or using the Website or any Services, you warrant and represent that you have the legal capacity to consent to, and agree to be bound by, this Privacy Policy in its entirety, and that any information or documents provided by you shall be true and accurate to the best of your knowledge.

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  1. By providing us with your Personal Data, you hereby consent to the processing of your Personal Data in accordance with this Privacy Policy. You warrant and represent that you have the right or have otherwise obtained the necessary authorisation to provide the information provided to us. You acknowledge that it may an offence under the applicable laws to request access to or change another person's information without being authorised by that person.

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