Privacy Policy

Our Privacy Policy

31st October 2025

1. Our Privacy Policy

We endeavour to be open and transparent in how we serve you.

Circle Wallet Pte Ltd and CDV Wealth. (collectively “Companies”, “we”, “us”, or “our”) collect, use, disclose and process information about you to understand your needs better. This helps us to improve our products & services and the way we communicate with you.

We conduct our business in compliance with the Personal Data Protection Act 2012 (“PDPA”) and have implemented additional measures to protect your personal information.

This Privacy Policy (“Policy”) sets out the basis for collecting, using, disclosing or otherwise processing personal data of our Customers in accordance with the PDPA. This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose and/or process personal data for our purposes.

2. Personal data

2.1 Definitions as used in the Notice:

“Customer” –  means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“Personal data” – means data, whether true or not, about a Customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, photograph from onboarding, employment information, financial information and identification number.

2.3. Other terms used in this Policy shall have meanings given to them in the PDPA (where the context so permits).

3. Collection, Use and Disclosure of Personal Data

3.1 How we collect your personal information

We generally do not collect your personal data unless:

  1. It is provided to us voluntarily by you directly or via a third party who has been authorised by you to disclose your personal data to us (your “authorised representative”) after: (i) you (or your authorised representative) have been notified of the purposes for which data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection, processing, disclosure and usage of your personal data for those purposes; or
  2. Collection, processing, disclosure and use of personal data is permitted or required by the PDPA or other laws.

3.2 We may collect your personal information when you Download and register for a CDV Wealth Account

  1. Sign up for alerts or newsletters;

  2. Contact us with a question or request for assistance;

  3. Share your details while participating in a competition, referral campaign or survey; and

  4. Visit our website and CDV Wealth App (through the use of cookies, mobile advertising IDs and/or other technologies).

3.3 The information we collect

  1. Your Identity – This includes photo identity documents such as, Passport, name, alias, address, telephone number, e-mail address, gender, date of birth, occupation, income, photo, any form of biometric and additional information that you may have submitted, as well as device ID and IP addresses;

  2. Your Engagement with CDV Wealth – Emails or live chat history or discussion on our # CDV Wealth Community channels or other records of any contact you have with us;

  3. Your CDV Wealth Transactions – Transactions that you make with your CDV Wealth Account or CDV Wealth Visa Debit Card, including, but not limited to, purchases, money transfers, etc; and

  4. Your Preferences – Based on how you use CDV Wealth, what you share with us, and how you would like to be contacted, and your preferred products, services, and lifestyle activities, for example.

3.3 Information from other organisations

These organisations include fraud-prevention agencies, business directories, credit reference agencies, or individuals we believe you have authorised to provide your personal details on your behalf.

3.4 How we may use your personal data

We may use your information to:

  1. Help you on your Customer journey and achieve your financial goals;

  2. Performing obligations in the course of or in connection with our provision of goods and/or services requested by you;

  3. Verifying your identity;

  4. Managing your relationship with us;

  5. Offer you relevant and personalised products and services that would meet your life stage and lifestyle needs;

  6. Process your requests and activate or deactivate services;

  7. Processing payments and transactions including trading in your precious metals or ETF vaults;

  8. Responding to, handling and processing  enquiries,  requests, applications, complaints, and feedback from you or people you have authorised;

  9. Inform you about service upgrades, security issues, and prevent and detect financial crimes;

  10. Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

  11. Any other purpose for which you have provided the information;

  12. Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

  13. Any other incidental business purposes related to or in connection with the above;

  14. Conduct market research, Customer satisfaction surveys, statistical analysis, develop new products, as well as personalise the services we offer you;

  15. Offer rewards and promotions, and share promotional benefits and loyalty programs which you may qualify for;

  16. Conduct internal and external audits; and

  17. Evaluation of creditworthiness.

3.6 When we may disclose your personal data

We may disclose  your personal data :

  1. Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;

  2. To affiliates, subsidiaries, group companies, business partners, third-party service providers, agents and other organisations we have engaged whether in Singapore or overseas to perform any of the functions with reference to the above-mentioned purposes;

  3. Industry regulators and other government organisations, as required by local laws and regulations;

  4. Financial institutions for purposes such as facilitating GIRO payments;

  5. Research institutions for market analysis purposes; and

  6. Credit reference bureaus for the purpose of preparing credit reports or evaluation of creditworthiness.

3.6 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

4. Withdrawing your consent

4.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

4.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (subject to the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

4.3 While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods and services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 4.1 above.

4.4 Please note that withdrawing consent does not affect our right to continue to collect, use, process, and disclose personal data where such collection, processing, usage and disclosure without consent is permitted or required under applicable laws.

5. Access To And Correction of Personal Data

5.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use, process or disclose your personal data, or (b) a correction request to correct or update any of your personal which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

5.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

5.3 We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your request within thirty (30) business days after receiving your request, we will inform you in writing within thirty (30) business days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

6. Protection of Personal Data

6.1 How we protect your information. To safeguard your personal data from unauthorised access, collection, processing, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:

  1. Minimised collection of personal data;

  2. Authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.);

  3. Encryption of data, up-to-date antivirus protection;

  4. Regular patching, and operating system and other software

  5. Securely erase storage media in devices before disposal;

  6. Web security measures

  7. Securely erase storage media in devices before disposal;

  8. Web security measures against risks, usage of one-time password (OTP)/2-factor authentication (2FA) to secure access; and

  9. Security review and testing performed regularly.

6.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

6.3 At CDV Wealth, we will make all reasonable efforts to maintain up-to-date anti-virus and anti-spyware software and are committed to safeguarding the privacy and security of your personal information.

6.4 The term malware encompasses all types of malicious software. You are solely responsible for protecting your device and data by installing firewall and anti-malware software.

6.5 Apps downloaded outside the official App Store may expose you to malware and enable scammers to gain remote access to your device to steal personal information and banking credentials. Only download Apps from official App Stores, and address security vulnerabilities by keeping software and applications up to date.

6.6 You understand and agree that Circle Wallet is not responsible for Malicious Software (MALWARE) that gains access to your device or any damage resulting therefrom.

6.7 Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

6.8 Transfers of Personal Data Outside of Singapore

We may transfer your personal data to countries and jurisdictions outside of Singapore, deemed to provide adequate levels of data protection. By using our services and accepting our terms and conditions and privacy policy, you are deemed to have provided your consent to such transfers of your personal data. These transfers will be done in accordance with the legal requirements.

6.9 Retention of Personal Data

  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, unless extended retention is necessitated by lawful requirements.; and

  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.

7. Questions?

Feel free to contact our Data Protection Officer at vignesh.manu@circledv.com.

8. General information

We may amend or modify this Policy from time to time, such as in response to changes to legislation or regulatory requirements or with respect to specific offerings. We remain committed to safeguarding your information and being open about our data protection practices.