auPay Privacy Policy

Version: v1.0

Effective Date: October 13, 2025

Governing Law: Personal Data Protection Act (PDPA) of Singapore

1. General Provisions

auPay (hereinafter referred to as “we,” “us,” or the “Platform”) places great importance on the protection of your personal data and privacy. This Privacy Policy (the “Policy”) explains how we collect, use, disclose, store, and safeguard your personal information.

Before registering for or using any services provided by auPay, please read this Policy carefully. By accessing or using our services, you acknowledge that you have read, understood, and agreed to the terms set forth herein.

2. Scope of Application

2.1 This Policy applies to all personal data collected through your use of the auPay platform, including its website, applications, and related services.

2.2 This Policy does not apply to third-party websites, platforms, or services that may be linked to or accessed through auPay. Such third parties are governed by their own privacy policies, for which we bear no responsibility.

3. Personal Data We Collect

Subject to legality, necessity, and proportionality, we may collect the following categories of personal data:

3.1 Information You Provide Directly

  • Registration details (such as name, email address, and contact information);
  • Identity verification information (e.g., identification documents, facial verification data);
  • Proof of address and source-of-funds information for compliance purposes;
  • Information submitted through customer support or communications.

3.2 Information Collected Automatically

  • Device and technical information (device type, operating system, browser type);
  • Usage data such as IP address, access time, and activity logs;
  • Data collected through cookies or similar technologies.

3.3 Information from Third Parties

Where permitted by law and with your authorization, we may obtain information from third-party service providers, such as identity verification or risk assessment providers.

4. Purpose of Data Use

We collect and use your personal data for the following purposes:

  • To create, maintain, and manage your auPay account;
  • To provide digital asset wallet and related services;
  • To perform KYC, AML, and counter-terrorist financing compliance;
  • To ensure platform security, fraud prevention, and risk management;
  • To communicate with you and improve our services;
  • To comply with applicable laws, regulations, and regulatory obligations.

We do not use your personal data for purposes unrelated to those stated above.

5. Cookies and Similar Technologies

5.1 We may use cookies or similar technologies to enhance user experience, analyze platform performance, and improve service quality.

5.2 You may manage or disable cookies through your browser or device settings; however, certain features of the platform may be affected as a result.

6. Disclosure and Sharing of Personal Data

6.1 We do not sell, rent, or unlawfully disclose your personal data to third parties.

6.2 We may disclose personal data under the following circumstances:

  • With your explicit consent;
  • To trusted service providers acting on our behalf (e.g., KYC providers, cloud service providers), solely for service delivery purposes;
  • Where required by law, regulation, court order, or regulatory authority;
  • To protect the rights, property, or safety of the Platform, users, or the public.

6.3 All third-party service providers are contractually required to protect your data and use it only for authorized purposes.

7. Data Storage and Cross-Border Transfers

7.1 Your personal data may be stored on servers located in Singapore or other jurisdictions.

7.2 Due to the global nature of our services, your data may be transferred outside your country of residence.

7.3 We take appropriate safeguards to ensure that cross-border transfers comply with applicable data protection laws, including the PDPA.

8. Data Security

8.1 We implement reasonable administrative, technical, and physical security measures to protect your personal data, including:

  • Data encryption;
  • Access control mechanisms;
  • Continuous monitoring and security audits.

8.2 While we take reasonable steps to safeguard your data, no system is completely secure, and we cannot guarantee absolute security.

9. Data Retention

9.1 We retain personal data only for as long as necessary to fulfill the purposes described in this Policy or as required by applicable laws and regulations.

9.2 When personal data is no longer required, it will be securely deleted or anonymized in accordance with legal requirements.

10. Your Rights

Subject to applicable law, you have the right to:

  • Access your personal data;
  • Request correction of inaccurate or incomplete data;
  • Withdraw your consent where applicable.

To exercise these rights, please contact us using the details provided below.

11. Minors

The Platform does not provide services to individuals under the age of 18. If we become aware that personal data of a minor has been collected, we will take appropriate steps to delete such information.

12. Policy Updates

12.1 We may update this Privacy Policy from time to time in response to legal, regulatory, or operational requirements.

12.2 Updated versions will be published on the Platform and become effective upon publication.

12.3 Continued use of the Platform following updates constitutes acceptance of the revised Policy.

13. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact us:

Email: info@aupay.one

Customer Support: As available through the Platform

14. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore.