Privacy Policy image

Privacy Policy

Paywho Pte Ltd (“we”, “our” or “us”) is committed to protecting and respecting our Users' privacy.

This policy sets out the basis on which personal data is collected from the User, provided to us by the User, as well as its usage, storage, and security. This Privacy Policy is read together with the Terms and Conditions (the “Agreement”) and adopts the same defined terms. This Privacy Policy applies to the use of the Paywho Mobile App, the web-based applications as well as the use of the Paywho Services. Please read the following carefully to understand how we ensure that our practices concerning personal data of our users comply with the applicable personal data protection and privacy laws.

By the User's continuous interaction with Paywho, such as by submitting information to us, or by using the Services, the User irrevocably and unconditionally agrees and consents that we may collect, use, disclose, share and process the User's personal data in the manner as set forth in this Privacy Policy.

The users who provide us with the personal data of their beneficiaries are deemed to have obtain consent from such beneficiaries, in the same way, we would use their personal data as stated in this Privacy Policy.

Personal Data” means information about the User, from which the User is identifiable, including but not limited to the name, nationality, address, telephone number, fax number, bank details, credit card details, gender, resident status, financial background, personal interests, email address, occupation, photos, any information about the User provided to us in registration forms, application forms or any other similar forms and/or any information about the User that has been or may be collected, stored, used and/or processed by us from time to time and includes sensitive personal data such as identification card number, driving license number, birth certificate number, passport number, race, ethnic origin, date of birth, marital status, education background, and data relating to health, religions or other similar beliefs.

The provision of the User's Personal Data is voluntary. However, if the User does not provide Personal Data, we will not be able to process the Personal Data for any Paywho Services and this may cause us to be unable to provide any services or products, or accept any payments from the User.

We may also collect information about the User's mobile phone, including where available, the IP address, operating system, and browser type, for system administration and to report aggregate information to our advertisers and merchants. This is statistical data about the User's browsing actions and patterns and does not identify any individual.

Data Protection Officer

We have appointed a data protection officer(s) (“DPO”) under the Personal Data Protection Act 2012 (“PDPA”), who can be contacted directly via email ( ). Among the various responsibilities, our DPO(s):

  • Ensures compliance of the PDPA when developing and implementing policies and processes for handling personal data
  • Fosters a data protection culture among Paywho employees and communicate personal data protection policies to Users
  • Manages Personal Data protection-related queries and complaints
  • Alerts the Paywho management to any risks that might arise with regard to Personal Data; and
  • Liaises with the Personal Data Protection Commission on data protection matters as required

If you have any questions regarding this Privacy Policy, please contact our DPO(s) via email at, or

Stored Data

The data that is collected from the User may be transferred to, and stored at, a destination outside Singapore in secure servers. It is likely that such data may be processed outside Singapore by our employees or our partners’ employees. Such employees may also be engaged in the provision of Services found on Paywho.

The User understands and consents to the transfer of their Personal Data out of Singapore. The User accepts and acknowledges that the transmission of information via the internet is not completely secure. We cannot guarantee the security of the User’s data transmitted to Paywho or in relation to any of the Services. The User undertakes to accept all risks involved in the use of the Services and/or Paywho pertaining to their Personal Data stored on Paywho and/or in relation to the Services found on Paywho.

Purpose of Use and Processing of Personal Data

We may use and process the User’s Personal Data for Paywho and/or the Services. In general, we may use a User’s Personal Data for:

  • Responding to enquiries from the User
  • Communicating to the User for any of the purposes listed in this Privacy Policy
  • Internal administrative purposes, such as auditing, data analysis, database record
  • The purposes of detection, prevention, and prosecution of crime
  • Maintaining the safety and security of Paywho and/or the Services; and/or
  • Complying with our obligations under the law
  • To provide you with information about other similar goods and services we offer
  • To permit selected third parties to offer you information about goods or services we feel may interest you

Further, we may use the User’s Personal Data in relation to any payment and financial services activities which shall include, without limitation the following Reasons:

Where the User is registered on Paywho and/or uses the Services:

  • To perform our obligations in respect of any transactions entered with the User
  • To provide the User any of the Services requested
  • Where the User has requested to download and use the Paywho Mobile App to process their request, to deliver the Paywho Mobile App to the User and to provide the User a license for the use of the Paywho Mobile App
  • To process the User’s participation in any promotions, polls, or surveys
  • To process, manage or verify the User’s registration on Paywho and to provide the Services
  • To validate the User’s use of the E-Wallet and/or the process of any payments in relation to any Services requested
  • To identify and verify the User’s identity, protect against any potential fraud, and to comply with applicable laws with regards to anti-money laundering, financing of terrorism and/or other illegal activities
  • To understand and analyze the User’s activity as well as identifying the preferences and needs of each User; and/or
  • To develop, enhance and provide Services to meet a User’s needs
  • Sending alerts, newsletters, updates, or mailers to the User to notify the user about updates and changes to our Services
  • Sharing the User’s Personal Data amongst its subsidiaries, associate companies and jointly controlled entities as well as with its agent, vendor, supplier, partner, contractor or service provider who may communicate with the User to alert the users of any special promotion and event which may be of interest to the user by way of telephone call, short message service, online messaging services or email

The User agrees and consents to us using and processing the User’s Personal Data for the Purposes and Reasons aforementioned and in the manner as identified in this Privacy Policy.

Disclosure to Third Parties

The User's personal data may be transferred, accessed, or disclosed to Third parties for the Purposes and Reasons. Further, we may engage other companies, service providers or individuals to perform functions on our behalf, and consequently may provide access or disclose to the User's Personal Data to such service providers or Third parties. The Third parties include, without limitation:

  • Our partners, which include parties with whom we collaborate with for certain Services and/or activities
  • Service providers, including, information technology service providers for infrastructure, software, and development work
  • Professional advisors and external auditors, including legal advisors, financial advisors, and consultants
  • Other entities associated with us; and
  • Governmental authorities to comply with statutory, regulatory, and governmental requirements

The User's Personal Data may also be shared in connection with a corporate transaction, such as the formation of a joint venture, a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.

Accuracy of the User’s Personal Data

The User undertakes to ensure that the Personal Data provided to us is current, complete, and accurate. The User is responsible for informing us if there are changes to their Personal Data as it may affect the provision of the Services.

Unsubscribe and Revocation of Consent

Should the User decide to unsubscribe to the processing of their Personal Data for the Purposes or Other Purposes, the User can inform us via sending an email to:; or to our DPO via

Access To and Correction of Personal Data

Subject to applicable laws and regulations, the User may request for access to their Personal Data that is in our possession or under our control, as well as information about the ways in which such Personal Data has been or may have been used or disclosed by us.

The User's right of access can be exercised in accordance with applicable laws and regulations. Any access request may be subject to a reasonable fee to meet our costs in providing the User with details of the information we hold about the User. We will try to respond to all access requests within one month. However, we reserve the right to refuse the User’s requests to access and/or make any correction to the User's Personal Data for the reasons permitted under law, such as where the expense of providing access to the User is disproportionate to the risks to the User's or another person's privacy.

In the event that the User decides to withdraw his/her consent with regards to the User's Personal Data, this may result in us being unable to provide our Services to the User, and may be deemed as a notice to terminate the Agreement with us. In such an event, we shall notify the User of such effect of the withdrawal of consent accordingly before we proceed to terminate the User's Account.

Changes to Privacy Policy

We may revise and update our Privacy Policy to take into account changes in our business and/or any changes in legal or regulatory requirements. We shall notify you via e-mail or through an announcement on our website, and you are advised to read and accept the new terms before you continue using the Paywho Mobile App or the Services.


If you have any questions regarding this Privacy Policy, we welcome your comments and feedback to be sent to our DPO via email to or to our customer support