Last modified: 31 May 2024

AXS Pte Ltd (“AXS”) is a solution provider and operator of an Electronic Service Delivery Network (“ESDN”). AXS operates the AXS network (“AXS Network”), comprising of the AXS mobile application (“AXS Mobile Application”), AXS Drive mobile application (“AXS Drive”), the AXS website at www.axs.com.sg (the “AXS Website”), the AXS Selection website at www.axs-selection.com.sg/ (the “AXS Selection Website”) and the AXS physical self-service kiosks (the “AXS Stations”).

AXS offers you an alternate electronic channel where you can perform bill payment transactions over the Internet or using our physical AXS kiosks. With new electronic channels you will be able to make bill payments at your convenience.

AXS respects every individual’s right to privacy. Whether you are an AXS customer, a registered user or visitor, we understand the importance you place on the privacy and security of information that personally identifies you or your account information. We refer to and treat this information as “personal information.” AXS is committed to protecting your personal information. We are open about our personal information and data collection practices.

Unless restricted by applicable law including the Personal Data Protection Act 2012 (“PDPA”), you agree that any and all personal information relating to you collected by AXS from time to time may be used and disclosed for such purposes and to such persons as set out in this Privacy Policy.

This Privacy Policy covers only your personal information which AXS collects, uses and discloses for AXS’ own purposes, which include uses related to the website, recruitment, and the provision of services which require you to register with an account with AXS, such as AXS Plus and AXS Receive.

This Privacy Policy does not cover your personal information which AXS collects, uses and discloses in the course of processing your personal information as a data intermediary on behalf of a third-party (e.g., an organisation which had instructed us to collect personal information from you so that you may make payment to that organisation). Where AXS processes your personal information as a data intermediary on behalf of a third-party, the privacy policy of that third party applies to you.

While AXS has put in place the necessary security practices and measures to safeguard against these risks, AXS is still unable to guarantee the complete security of your transactions against any attacks from malicious programmes.

We may revise this Privacy Policy from time to time without any prior notice. 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 AXS Network after the changes constitute your acknowledgement and acceptance of such changes. If you have any queries, please contact our Data Protection Officer at dpo@axs.com.sg.

1. COLLECTION AND USES OF PERSONAL INFORMATION

1.1 We do not sell personal information to anyone.

1.2 You may generally access the AXS Network without the need to give us any of your personal information. AXS collects personal data when you interact with our services and provide your own personal data voluntarily.

1.3 We may collect information when you browse the AXS Website, AXS Mobile Application, AXS Drive, and AXS Selection Website. Such information includes without limitation:

• Search queries;
• Internet protocol addresses; and
• Cookies that may uniquely identify your browser for the purposes of internal analytics.

1.4 We collect personal information when you register an account with AXS such as:

• Name;
• Email Address;
• Contact number;
• Vehicle registration number (VRN);
• In-vehicle Unit (IU) number;
• National Registration Identity Card (“NRIC”)/ Foreign (“FIN”) number;
• Date of birth;
• Gender; and
• Registered ddress

1.5 We may collect additional personal information when you authorise us to do so. This may include personal information collected when you authorise us to access any external databases containing your personal information via Singpass/Myinfo or any other API service.

1.6 We collect personal information that you provide to us when you contact AXS for recruitment and related purposes. Such personal information is collected, used, and disclosed by AXS in accordance with AXS Personal Data Protection Policy for Job Applicants, a copy of which is published here.

1.7 If you choose not to provide the above-mentioned personal information, you are still allowed to generally access the AXS Network and access and use the services and content available on the AXS Network. However, some AXS services, where AXS acting as data owner such as AXS Receive, AXS Plus, and AXS Drive, will not be available to you.

1.8 If you contact AXS, we may keep a record of your communication to help to resolve any issues that you may be facing.

1.9 All personal information and other information collected may be used by AXS in the aggregate or individually and may be combined with other information for purposes including but not limited to the following:

• Responding to and taking follow-up action on complaints;
• Performing office administrative matters;
• Seeking feedback and comments on AXS’s business and operational matters;
• Marketing activities, events and services of AXS and its business partners;
• Providing you with updates on AXS;
• Providing you with services that you have requested for (e.g. AXS Plus and AXS Receive services);
• Contacting you to seek instructions or inform you on any services that you have requested for;
• Conduct profile analysis of your preferences to implement customer segmentation strategy to develop and improve product and services;
• Any other purposes for which you have provided the information; and
• Purposes relating to any of the above.

1.10 Where your NRIC number/ FIN is collected, AXS will use and disclose the NRIC number/ FIN only for the purposes of the following:

• Using your NRIC number/ FIN as an identifier for making payment to organisations which AXS is acting as a data intermediary for, where those organisations have represented to AXS that the use, collection and disclosure of your NRIC number/ FIN is permitted under the PDPA and applicable guidelines by the Personal Data Protection Commission (“PDPC”);
• Providing refunds to you using your NRIC number/ FIN where the transfer services that AXS relies on to make the refunds uses your NRIC number/ FIN as an identifier (e.g. PayNow);
• For the purposes of retrieving personal information as authorised by you through Singpass/MyInfo, or any other API service which uses your NRIC number/ FIN as an identifier.

1.11 AXS corporate policies stipulate that any employee with access to confidential customer information is not permitted to use or disclose such information except for business purposes. All employees are required to safeguard such information as specified in their confidentiality agreements with AXS.

1.12 For the aforementioned purposes, AXS may need to provide your information to its business partners, legal advisors and service providers. In all cases, your personal information is protected by a strict confidentiality agreement. We have arrangements in place to ensure your personal information is not retained by AXS’s business partners, legal advisors and service providers for longer than is necessary for the purpose of providing you with the product, service or information you request.

1.13 If you are providing the personal information of another individual to AXS, you warrant to AXS that you are validly acting on behalf of that individual for the collection, use or disclosure of that individual’s personal data on the terms of this Privacy Policy.

2. DISCLAIMERS

2.1 Through the services and content on the AXS Network, you may be introduced to a variety of third parties. The privacy policies of these third parties are not under AXS’s control and may differ from AXS’s and you should read the privacy policies of these third parties carefully. The use of any information that you may provide to any third party, or the use of “cookie” technology by any third party, will be governed by the privacy policy of the operator of the third-party website that you are visiting. If you have any doubts about the privacy of the information that you are providing to such a third party, you should contact the third party directly for more information and review their privacy policy. AXS shall not be responsible for the actions of such third parties in any manner whatsoever, including but not limited to any violation of such privacy policies or otherwise.

3. ACCESS TO/CORRECTION AND/OR WITHDRAWAL OF PERSONAL INFORMATION

3.1 Our Data Protection Officer is responsible for ensuring that requests for access to information /correction of information and/or withdrawal of information are properly dealt with in accordance with the procedures described here.

3.2 All requests be made by completing AXS’s standard Request For Information / Correction Form (PDF available here), and sending a copy of the duly completed form to AXS via email at: dpo@axs.com.sg, or post or fax at:

AXS Pte Ltd

61 Mohamed Sultan Road

#01-11 Sultan Link

Singapore 239001

Attention: Data Protection Officer

Fax: 6636 4550

3.3 Please note that AXS will only accept and act on requests in the English language that comply with this Privacy Policy, and with the applicable charge(s) paid. AXS shall be entitled to reject any request that does not comply with the above.

3.4 AXS may refuse to disclose or amend any information for the reasons set out in the PDPA.

3.5 As far as reasonably possible, AXS will respond to your request within thirty (30) days from the date of receipt of the request. If that is not possible, you will be so notified within thirty (30) days from the date of receipt of the request.

3.6 A reasonable fee may be imposed on each request for information. If so, we will inform you of the fee before processing your request. This fee is payable to AXS by way of a cheque made out to AXS Pte. Ltd., and may be subject to revision by AXS from time to time. AXS is not obliged to respond to requests for information where the applicable fee(s) are not paid after we inform you of such fees.

3.7 You understand that when a request to correct information provided by you for the purpose of performing a bill payment transaction is made, AXS may in certain circumstances determine that the nature of the request is to obtain a refund from the transaction, in which case, AXS may require you to file a request for a refund of payments made instead.

4. SAFEGUARDING YOUR ACCESS

4.1 At AXS, we are committed to protecting the security and confidentiality of your information so as to provide you with a safe and secure online environment. Our website uses commercially proven security hardware and software products. These security products include routers, firewalls, intrusion detection systems and secure operating system to safeguard your interest.

4.2 Industry standard Secure Socket Layer (SSL) communication protocol is the de facto cryptographic standard that we use for securing data communication between the browser and the AXS Website. Digital certificate technology is used to ensure transaction privacy, message integrity and server-side authentication.

4.3 AXS’s channel is regularly reviewed and audited by external and internal auditors to ensure that your interest is safeguarded.

4.4 Apart from the security measures put in place, you play an equally important role in ensuring your online security and account information is not compromised.

4.5 You should adopt the following recommended practices (non-exhaustive) in protecting the security of your system:

• Do not share your account information with anyone.
• Do not display your account information in a manner that is visible to others and your PC should never be left unattended. For your protection, the web application will automatically terminate your session if there is no activity for a period of time.
• Always use the recommended browser. All browsers and application software should be upgraded to support SSL 256-bit encryption.
• Always check that the website address changes from http:// to https:// and a security icon, usually in the form of a lock or key, appears when authentication and encryption is expected.

5. RETENTION

5.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

5.2 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.

6. LEGITIMATE INTERESTS

6.1 In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of AXS or another person. In relying on the legitimate interests exception of the PDPA, AXS will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

6.2 In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:

• Fraud detection and prevention.
• Detection and prevention of misuse of services.
• Network analysis to prevent fraud and financial crime, and perform credit analysis.

7. MISCELLANEOUS

7.1 Notwithstanding anything in this Privacy Policy, AXS may release your personal information when it believes that such release is necessary to:

• Comply with any applicable laws;
• Enforce terms of any agreement between you and AXS; and
• Protect the rights, property and safety of AXS, other users of the AXS Network, or any other party.