Privacy policy

1. Introduction and scope

kimbocorp takes privacy seriously. In addition to this privacy policy, we maintain internal policies and practices designed to keep personal information secure and to ensure it is used consistently with this policy.

This policy describes how kimbocorp collects, uses, processes, and discloses the personal information of consumers, and applies to kimbocorp.com and to kimbocorp's subsidiaries and affiliates.

This policy covers both your use of the kimbocorp website and other ways you may interact with kimbocorp, for example, by phone, and describes the choices available to you regarding kimbocorp's use of your personal information. It applies globally, with specific additional provisions for Singapore residents (section 10) and individuals located in the European Union.

This policy is incorporated into kimbocorp's terms and conditions and governs your use of kimbocorp's services. By using kimbocorp's services, you accept this policy. Questions, or requests to exercise your rights over your data, can be directed to kimbocorp using the details in section 12.

2. Information we collect about consumers

The personal information kimbocorp collects depends on the nature of your interaction with us - for example, visiting the website, purchasing a plan, or being a shareholder or director of a company we service. "Personal information" means information that relates to, and is capable of being linked to, a particular person; it does not include de-identified or aggregate information.

kimbocorp may collect the following categories of information:

• Identifiers - name, postal address, online identifiers, IP address, email address, account numbers, and government identification numbers (e.g., NRIC/passport) relevant to CDD.
• Other information you provide - telephone number, financial information (including bank account and card details), and information collected as part of customer due diligence or background checks on shareholders, directors, and controllers of a company.
• Characteristics protected under law - age, nationality, citizenship, marital status, and sex, where relevant to CDD or statutory filings.
• Commercial information - records of business and property owned, and products or services purchased or considered from kimbocorp.
• Internet and device information - browsing and search history on kimbocorp's website or apps, device information, and how you interact with kimbocorp's emails.
• Geolocation information - where you reside or are otherwise located.
• Audio and visual information - call recordings, and images/video where you visit kimbocorp's premises or otherwise provide these to us.

kimbocorp does not collect biometric information, or education information held by an educational institution, and does not collect inferences about consumers directly - though we may internally generate inferences from the information described above.

3. Where we collect information about consumers

• Consumers - directly from you (forms, chat, phone) or indirectly (cookies and similar technologies - see section 6).
• Related consumers - from someone you know; for example, if you are a shareholder in a company formed through kimbocorp, we may receive your information from that company's primary member in order to complete formation.
• Service providers - entities kimbocorp contracts with to help fulfil our business needs, for example notifying us of legal mail received under our registered filing agent role.
• Professionals - independent professionals with whom you schedule a consultation through kimbocorp's advisory offerings; for example, confirmation that a consultation took place.
• Business partners and affiliates - information about a product you purchased from a partner after expressing interest in an offer presented via kimbocorp.
• Publicly or commercially available information - for example, whether your company is in good standing with a corporate registrar.
• Unrelated parties - for example, documents kimbocorp receives on your behalf in its role as your registered filing agent.

4. How we use the information we collect

kimbocorp uses collected information for the purposes below, and may combine information from multiple sources to do so. If kimbocorp wishes to use your information in a way not consistent with these purposes, we will seek your consent first, where legally required.

• Providing products and services - producing and delivering what you've purchased, administering the website, and personalising content.
• Security - maintaining appropriate security over our networks and premises, and detecting fraud or suspicious activity.
• Meeting legal requirements - satisfying CDD/screening requirements before forming a company, maintaining records required of a registered filing agent, and responding to lawful requests for information.
• Marketing - marketing to current and prospective clients (see sections 6 and 7 for how to control this).
• Product development - improving existing products and developing new ones.
• Analytics - understanding how visitors use kimbocorp's website and developing insight into client preferences and behaviour.
• Sharing with business partners - providing your information to a partner where you've expressed interest in their offer, or purchased a bundled product.
• Financial reporting - internal budgeting, projections, and reporting.
• Business transfers - in a merger, acquisition, reorganisation, or sale of assets, information may be transferred as part of that transaction; you would be notified of any resulting change in ownership or use of your information.

kimbocorp may also use de-identified or aggregate data, not linkable to any individual, for purposes beyond those listed.

5. How we share consumer information

• Service providers - who assist in the purposes listed in section 4, and are not authorised to use your information for their own purposes.
• Professionals - independent professionals accessible through kimbocorp's advisory offerings.
• Business partners and affiliates - in limited circumstances, such as where you've expressed interest in a partner offer or purchased a bundled product; these partners cannot use your information for their own marketing without your separate permission.
• Related consumers - in limited circumstances, information may be shared with your authorised contacts.
• Government entities - to fulfil products purchased (for example, filings with ACRA); certain information (company name, business address, registered filing agent) becomes public record once filed.
• Public postings - limited circumstances such as displaying customer testimonials or reviews you've provided (which you may ask kimbocorp to update or delete), or company profile information on kimbocorp's social media.
• Registered agent requests - if you appoint a different registered filing agent, kimbocorp may provide your name and contact details to them on request.
• Required by law - in response to a subpoena, lawful request by a public authority, or where kimbocorp believes disclosure is necessary to protect its rights, your safety, or to investigate fraud.
• Related parties - businesses under common control with kimbocorp, or in connection with a merger, acquisition, or asset transfer.

kimbocorp may also share de-identified or aggregate data, not linkable to any individual, with parties beyond those listed.

6. Third party links

kimbocorp's website may link to other websites, and other websites may link to kimbocorp's. This policy applies only to kimbocorp.com; other sites you visit or use to access kimbocorp may have materially different privacy practices, and kimbocorp is not responsible for their content or privacy practices.

kimbocorp's website may include social media features (for example, a "like" button or share widget). These may collect your IP address and the page you're viewing, and may set a cookie for the feature to function. Your interaction with these features is governed by the privacy policy of the company providing them.

7. How you can control your information

This section applies globally, including to individuals who believe kimbocorp may hold information about them provided by a third party. Depending on where you reside, you may have additional rights beyond those described here.

Upon a verified request, and subject to the privacy interests of others and technical limitations, kimbocorp will confirm whether it holds information related to you, and may, at its discretion (unless otherwise required by law), correct or delete it. kimbocorp may nonetheless be required, or need, to retain some information to continue providing services or to meet legal obligations.

To submit a data request, contact kimbocorp using the details in section 12; you may be asked to verify your identity. kimbocorp retains information for as long as needed to provide services and meet legal, dispute-resolution, and enforcement obligations, and may retain some data in its archives even after removal from the website.

8. Information processed on behalf of third parties

Where kimbocorp processes personal information on behalf of a third-party affiliate, and kimbocorp has no direct relationship with the individual concerned, that individual should direct requests to access, correct, amend, or delete their data to the relevant third-party affiliate (as the data controller).

9. How secure is the information we collect

kimbocorp aims to keep its servers and connections secured with current encryption and security measures, and has implemented physical, electronic, and managerial safeguards. Payment and personal information are transmitted over secure (TLS) connections. Documents may be delivered by courier, Singapore Post, or electronically.

No data transmission can be guaranteed 100% secure; kimbocorp cannot guarantee the security of information transmitted to or from its website or services, and such information is provided at your own risk. kimbocorp disclaims liability for theft, loss, interception of, or unauthorised access or damage to, your data or communications arising from use of its website and services, and you acknowledge and assume this risk.

If you believe your privacy has been breached, contact kimbocorp immediately - see section 12 for contact details.

kimbocorp periodically reviews this policy and its compliance with it, and will investigate and attempt to resolve complaints or disputes about its privacy practices.

10. Information for Singapore residents (PDPA)

This section applies specifically to Singapore residents, under the Personal Data Protection Act 2012 ("PDPA"). kimbocorp will not sell your data as defined under the PDPA, though we may share it in the course of business as described above.

10.1 Data collected during onboarding

• Name, contact information, and address
• Location
• Billing information
• Identification documents

10.2 Your rights under the PDPA

• You may register your Singapore phone number on the national Do Not Call (DNC) Registry to opt out of telemarketing.
• You decide which organisation may collect, use, and disclose your personal data.
• You may withdraw consent for kimbocorp to collect, use, or disclose your data; kimbocorp will inform you of the likely consequences before processing your request, though it is not obliged to delete data it has a business or legal need to retain.
• You may request access to your personal data and how it has been used or disclosed in the past year; kimbocorp may charge a reasonable administrative fee, or decline a frivolous request.
• kimbocorp may decline an access request where providing the data could cause serious harm to your safety or health, threaten another person's safety, reveal someone else's personal data or the identity of whoever provided your data, or be contrary to the national interest.
• You may request correction of an error or omission in your personal data; unless kimbocorp has valid reason not to, it will correct the data and, where required, inform other organisations that received it in the past year.

11. Changes to this policy

kimbocorp may update this policy to reflect changes in its information practices. Material changes will be posted on this page, together with the updated policy, before they take effect. You're encouraged to review this page periodically.

12. Contact us

Attn: Privacy team

151 Chin Swee Road, Manhattan House #02-24, Singapore 169876

Phone: +65 6950 5010

[email protected]