PRIVACY POLICY PROSEGUR

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how ChangeGroup collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. 

Controller

ChangeGroup is part of a group of companies registered within various geographical regions and includes The Change Group International Plc, The Change Group Corporation Ltd, ChangeGroup ATMs, The Change Group London Ltd., Prosegur Change UK Ltd., Prosegur Change SG Pte. Ltd., Prosegur Foreign Exchange Pty Limited or any of their subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time (referred to below as "ChangeGroup", "we", "us" or "our").

Within Singapore 

For the purposes of compliance with the Personal Data Protection Act 2012 of Singapore and any applicable data protection laws, Prosegur Change SG Pte. Ltd. (“the Company”) is the Data Controller and responsible for your personal data and adhering to data protection and privacy laws within Singapore. 

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer using the details set out below. 

Contact details

Full name of legal entity: Prosegur Change SG Pte. Ltd. 

Postal address: 60 Airport Boulevard, #B1-57, Changi Airport Terminal 2, Singapore 819643

To the attention of the Data Protection Officer

Email address: privacy.sg@prosegur.com (please ensure to include lopd@changegroup.com in the CC field).

You have the right to make a complaint at any time to the appropriate data protection supervisory authority Personal Data Protection Commission (PDPC), the Singapore supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority, so please contact us in the first instance. 

Changes to the privacy notice or to your personal data

This version was drafted in September 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified and/or other information which we have or likely to have access. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together:

• Identity Data includes first name, last name, username or similar identifier, title and date of birth.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes payment card detail addresses your login data, browser type and version, time zone setting and location, browser plug-in types and version, operating system and platform, and other technology on the devices you use to access this website. 
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) 
• Profile Data includes your username and password, purchases or orders made by you, your interests, feedback and survey responses.  
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in Singapore law as this data does not directly or indirectly reveal or is linked to your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us via our website, or by post, phone, email or otherwise. This includes personal data you provide when you:

1. apply for our products or services;
2. create an account on our website;
3. subscribe to our service or publications; 
4. request marketing to be sent to you;
5. enter a competition, promotion or survey; or
6. give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.  Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below: 

1. Technical Data from analytics providers or search information providers.
2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
3. Identity and Contact Data from data brokers or aggregators.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

You have the right to withdraw consent to marketing at any time by contacting us. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal. 
 

Purposes for which we will use your personal data

We will only collect, use, or disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances and where we have informed you of the purposes of such collection, use or disclosure of the personal data on or before collecting the personal data. 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below:

Marketing 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). 

You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for promotion and, in each case, you have consented for us to use your personal data in this way and you have not opted out of that marketing. 

Third-party marketing 

We will get your express opt-in consent before we share your personal data with any other company outside ChangeGroup for marketing purposes. 

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy. 

Change of purpose 

We will only use your personal data for the purposes for which we collected it. If you wish to get an explanation, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your consent, in compliance with the above rules and the laws of Singapore, where this is required or permitted by any applicable law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above. 

• Internal third parties. These include other ChangeGroup companies and organisations acting as joint data controllers or processors and who are based in Australia, Europe, Singapore, and USA. 
• External Third Parties.  These include:
  • IMX Software (UK) Ltd, who provide us with Point of Sale and Reserve and Collect systems.
  • Microsoft Azure for the purposes of holding data in the Cloud. 
  • Zen Managed Services, who maintain our IT managed services.
  • Altispex Limited, who provides us with website development services.
  • Other external third parties such as Partnerize, Google Ads, Meta and Google Tag for marketing purposes. 
  • Professional advisers including lawyers, bankers, auditors and insurers who provide various professional services to us.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If that happens then the new owners may use your personal data in the same was as set out in this privacy policy.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Change Group is a global group and we share data amongst different parts of that group where it is necessary and appropriate to do so. We may therefore share your personal data within The Change Group International Plc group of companies and organisations. Due to the locations in which these are based, this may involve transferring your data outside of Singapore. Data sharing agreements are in place within The Change Group International Plc group of companies.

Whilst we do not currently transfer your personal data to companies within our group or to service providers outside of Singapore, it is possible that if we change our service providers or engage a new service provider then they may be based outside of Singapore.  In this case we will ensure that they must provide a similar degree of protection to your personal data by ensuring at least one of the following safeguards is implemented: 

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. 
• Where we use certain service providers, we may use specific contracts terms approved for use which give personal data the same protection it has in Singapore.  

Please contact our Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of Singapore.  

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider whether the purpose for which that personal data was collected is being served by retention of the personal data; and whether retention is necessary for legal or business purposes. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. 

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see Section 9 below to find out more about these rights: 

• Request access to your personal data.
• Request correction of your personal data.
• Request restriction of processing your personal data.
• Right to withdraw consent.

• If you wish to exercise any of the rights set out above, please contact us. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Officer in writing.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days if your request is particularly complex or you have made several requests. In this case, we will notify you within 30 days of the same and keep you updated. 

9. Glossary

LAWFUL BASIS

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. To make a subject access request please contact our Data Protection Officer via email at privacy.sg@prosegur.com including lopd@changegroup.com in the cc field.  

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. We will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made. 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data where you wish to withdraw your consent to the same. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing based on your consent carried out before its withdrawal. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.