Terms and Conditions

Users are required to read these Terms and Conditions carefully in their entirety, and may contact PT Abadi Singapay Indonesia (“PT ASI” or “Singapay” or “We/Us”) with any further questions. These Terms and Conditions govern the User’s use of and access to the application, content, and products provided by Us, as well as the payment services provided by Us. By accessing or using the Singapay service application, the User agrees and binds themselves to comply with these “Terms and Conditions” (hereinafter referred to as the “Terms and Conditions”), as well as the “Privacy Policy” set out on a separate page, which constitutes an integral and inseparable part of these Terms and Conditions.

Definitions

1. Non-Premium Account means a Singapay Account held by a Non-Premium User.
2. Premium Account means a Singapay Account held by a Premium User.
3. Singapay Account means any account registered with Singapay by the User and controlled by the User to make use of the facilities provided by Singapay.
4. Singapay Application means the platform provided by PT ASI, within which there are various service features supporting the User’s activities as a payment system service in the form of (server-based) electronic money as well as other supporting services, on a mobile basis, which can be used through a Telecommunications Device.
5. Bank means a business entity that collects funds from the public in the form of deposits and channels them to the public in the form of credit and/or other forms.
6. Calendar Day means every day from Monday through Sunday, including public holidays, under the Gregorian calendar.
7. Business Day means a day (other than Saturday or Sunday or a national public holiday) on which banks in Indonesia are generally open for normal banking business transactions.
8. Merchant means any party, whether a legal entity, business entity, or individual, that serves Transactions using Singapay under a cooperation agreement with PT ASI or another form of cooperation.
9. Mobile Number means the cellular telephone (handphone) or smartphone number registered by the User to access Singapay services.
10. User means any person registered as the holder of a Singapay Account, whether a Non-Premium Account or a Premium Account, as well as the holder of a Singapay Balance as recorded in the Singapay Application.
11. Non-Premium User means a Singapay User who has not yet completed, or does not complete, the verification requirements.
12. Premium User means a User who has completed the verification requirements by uploading a facial photograph and national identity card (KTP) to the User’s account or by other means determined by Singapay from time to time.
13. Telecommunications Device means a mobile phone or cellular phone (handphone), or smartphone, a personal computer in tablet form, or other telecommunications device, running the Android or iOS operating system whose technology supports Singapay services.
14. Promotion or Promo means an offer of promotional benefits and/or incentives for the use of features and services on Singapay payments, which is subject to specific terms and conditions applicable to such offer of promotional benefits and/or incentives. The determination of the type and terms of a Promotion is at PT ASI’s absolute discretion. Information and terms and conditions relating to each promotional and/or incentive program will be made available through media that can be easily accessed by the User.
15. Escrow Account means a fund-holding account at a Bank registered with Singapay, which is used solely for the utilization of the Singapay Application features.
16. Singapay Balance means the amount of electronic money recorded and stored in the Singapay Application. The money underlying the issuance of the electronic money will be held in the Escrow Account and may be used by the User to carry out transactions using the Singapay Application.
17. Transaction means all transactions that can be carried out by the User using Singapay, whether already available through the features of the Singapay Application or transactions to be developed in the future.
18. Top-up Transaction means a transaction to load electronic money into the Singapay Balance.
19. Transfer Transaction means a transaction to send electronic money from one User to another User or from a User to a Bank account.
20. Bill Payment means the payment/purchase of bills or products available in the Singapay application.

General Provisions

1. Singapay may only be used after the User has agreed to the Terms and Conditions and the Privacy Policy in the Singapay Application, and has carried out activation or registration using a Mobile Number (handphone) and provided the required information.
2. Each Mobile Number (handphone) may only be used for 1 (one) registration of the Singapay Application.
3. The User may carry out any Transaction provided they have a sufficient Singapay Balance. The Singapay Balance is limited to:
   a. Rp2,000,000 (two million Rupiah) for a Singapay Account held by a Non-Premium User;
   b. Rp20,000,000 (twenty million Rupiah) for a Premium Account.
4. The maximum limit for incoming Transactions in 1 (one) Account within 1 (one) calendar month is:
   a. Rp20,000,000 (twenty million Rupiah) for a Singapay Account held by a Non-Premium User;
   b. Rp40,000,000 (forty million Rupiah) for a Premium Account.
5. We may delay or reject a Transaction if Our security system deems the Transaction to be unusual, for security reasons. The status of the User’s transaction will be communicated directly to the User through the transaction page in the Singapay Account.

Activation

1. The User may open an account for the first time by downloading the Singapay Application directly onto their Telecommunications Device as available on the Google Play Store (for Android) and the App Store (for iOS) and installing it on the Telecommunications Device.
2. After installation on the Telecommunications Device, the User may carry out the activation process by following the instructions and providing information, including:
   a. The User’s account name;
   b. A PIN chosen by the User.
3. Upon first registration, the User’s status is a Non-Premium Account. If the User intends to upgrade from a Non-Premium Account to a Premium Account, the User will be requested, and agrees, to upload a facial photograph and personal national identity card (KTP). Each such Premium Account registration request will be deemed a valid request from the User.
4. All data or information submitted by the User for Premium Account registration will be stored by Us for the purpose of verifying the User’s Premium Account request, and will be used for the Facial Verification authentication method as governed in these Terms and Conditions. Specifically for biometric data (including facial photographs and facial recognition data), which constitutes specific Personal Data, its storage and use for the Facial Verification authentication method is carried out on the basis of the User’s explicit consent, given separately from consent to these Terms and Conditions through a dedicated consent screen at the time of Premium Account registration/upgrade, accompanied by information on the purposes of processing, the storage (retention) period, and the User’s rights as the subject of the Personal Data, including where the verification process is carried out in cooperation with a third-party identity verification (e-KYC) service provider.
5. Approval and/or rejection of the User’s verification application is at Our absolute discretion, having regard to applicable laws and regulations.
6. We may postpone, reject, or cancel approval of the User’s verification application if any of the following is found, among others:
   a. Misuse of the User’s identity;
   b. An identity that does not comply with applicable laws and regulations.
7. The User must guarantee the truth and accuracy of all data and information submitted by the User for the purposes of Singapay account activation and Premium Account verification. The User is fully responsible if it is later found that any data or information submitted by the User is inaccurate, incorrect, and/or false.
8. Singapay, at its discretion, is entitled to reject a User’s registration application if there is any indication of a mismatch in the User’s identity or profile pursuant to applicable laws and regulations. Information on the User’s registration status will be notified to the User through a page in the Singapay Application.
9. By activating a Singapay account and/or verifying a Premium Account, the User understands and agrees to grant Us access to the names and mobile phone number contacts on the User’s electronic device, to be used on a limited basis in connection with activities in the Singapay Application, namely the Transfer between Users feature and/or other features requiring contact access as communicated in the Singapay Application.
10. To carry out transactions in the Singapay Application, the User must first perform a Top-up Transaction.
11. Singapay does not store information used by the User in carrying out transactions in relation to passwords (PIN) or other security codes in any form, whether temporarily or permanently, in Our system. The transaction validation process carried out through a Bank or transaction operator will be performed directly by the relevant Bank or transaction operator.
12. The process of a Top-up Transaction through a Bank or a Transfer Transaction to a Bank will be taken over by and processed through the banking system. We will only pass on the “Successful” or “Failed” Transaction status from the Bank.
13. Where a Top-up Transaction is declared “Successful”, the User’s balance in the account at the relevant Bank will automatically decrease while the Singapay Balance will increase by the corresponding amount. If the Singapay Balance has not increased, the User may contact Us through the services provided by Us.
14. The User understands that Top-up Transactions carried out through third-party channels may experience system and/or network disruptions from time to time beyond Our control. We will make reasonable efforts to resolve disruptions with third-party channels.

Features of the SingaPay Application

The User may carry out various Transactions through the features available in the Singapay Application, which in broad terms are as follows:
a. Singapay Balance
b. Top Up (Balance Loading)
c. Bill Payment
d. Top-up Product Purchases
e. Transfer between Users
f. Bank Transfer

Withdrawal and/or Redemption of Singapay Balance

The User is entitled to redeem and/or withdraw part or all of the Singapay Balance at any time, through a Transfer Transaction to a Bank account in the User’s name, provided that the User holds Premium Account status and subject to the applicable transaction limits and provisions.

Status of Singapay Balance and Float Funds

The Singapay Balance constitutes electronic money value and is not a deposit as referred to in the laws on banking, and therefore no interest/return of any kind is provided on it, and it is not covered by the deposit guarantee program of the Indonesia Deposit Insurance Corporation (LPS). The funds underlying the issuance of the Singapay Balance (float funds) are administered and placed in accordance with Bank Indonesia provisions.

Handling of Failed Transactions, Refunds, and Transaction Notifications

1. Where a Transaction has a failed status but the Singapay Balance has been debited, Singapay will return the funds to the User’s Singapay Balance automatically, or no later than 2 (two) Business Days from when the failed status is identified. If the refund has not been received after such period, the User may submit a complaint through Singapay’s official channels.

2. For payment Transactions to Merchants (including via QRIS), refund requests for goods/services shall be submitted by the User to the relevant Merchant. Singapay will process the refund to the Singapay Balance based on the request/approval of the Merchant or relevant operator, in accordance with the applicable mechanism and timeframe.

3. Singapay provides notifications of every successful or failed Transaction through the Singapay Application. The Transaction history is available in the Singapay Application and may be used by the User as supporting evidence when submitting a complaint.

Term

The User’s Singapay Account will remain valid for as long as the account is not permanently closed, whether by the User or by Singapay.

AML/CFT/CPF Compliance and Fraud Prevention

1. Singapay is authorized and/or obligated to postpone or reject Transactions, to immediately block the Funds and/or Singapay Account of a User whose identity is listed in the List of Suspected Terrorists and Terrorist Organizations (DTTOT) and/or the List of Funding of Proliferation of Weapons of Mass Destruction, and to request additional data, information, and/or documents for the purpose of Enhanced Due Diligence (EDD), in accordance with the applicable AML/CFT/CPF provisions.

2. Singapay operates a fraud detection and prevention system (fraud management system) in accordance with Bank Indonesia provisions. Where the system identifies an indication of fraud, Singapay may postpone, hold, or reject the Transaction and will inform the User of such status through the Singapay Application, along with an opportunity for the User to provide clarification through official channels.

Blocking of SingaPay Accounts

• A Singapay Account may be blocked in whole or with respect to certain features, in accordance with Our policy, in the event that:
  a. The User enters an incorrect PIN 3 (three) times in a row;
  b. The User submits an official request, whether due to a report by the User that their mobile phone has been lost, stolen, or hacked. The User must include additional information/documents relating to the purpose of the User’s request.
  c. Blocking is carried out unilaterally by Singapay due to an indication of harm to Singapay and/or an indication of a violation of applicable legal provisions, with or without prior notice to the User, namely:
  i. There is a request from a state authority or an authorized law enforcement authority, or;
  ii. The User uses Singapay services in a manner that results in a violation of the Terms and Conditions and/or the Privacy Policy, or;
  iii. The User provides untrue or misleading data/information and statements at the time of registration or while using the Singapay Application, or;
  iv. There is an indication of misuse for activities that violate applicable laws and regulations, or;
  v. The Singapay Account is declared inactive (dormant) because it has not been used for a minimum period of 24 (twenty-four) consecutive months, i.e., it has no transaction activity (incoming or outgoing transactions) and/or no activity on assets and/or liabilities of financial services products in the Singapay Application.
• Reactivation of an account blocked for the reasons referred to above is entirely within Singapay’s authority, and We also have full authority to temporarily or permanently disable the User’s access to some or all Singapay services/features.
• Singapay will inform the User of the account blocking and its reasons through the Singapay Application and/or Singapay’s official channels, unless such notification is prohibited under laws and regulations (including the tipping-off prohibition under AML/CFT provisions). The User may contact Singapay Customer Service to make further inquiries or file an objection to such blocking.
• A User whose account is blocked may file an objection/clarification through Singapay’s official channels accompanied by supporting documents. Singapay will review the objection and communicate the outcome within the applicable complaint handling timeframe. The blocking will not be continued if, based on the review, the cause of the blocking has ended, unless otherwise required by the competent authority.

Closure and/or Deletion of SingaPay Accounts

1. A Singapay Account may be closed and/or deleted upon the occurrence of any of the following:
   a. An official request from the User submitted through Our official complaint channels and/or through the delete account feature on Singapay, subject to completion of the process and requirements requested by Us;
   b. A request from an authorized law enforcement authority;
   c. A Singapay policy that does not conflict with applicable laws and regulations;
   d. A Force Majeure event lasting 3 (three) consecutive months or more; and/or
   e. The cessation of PT ASI’s operational activities for any reason.
2. We will return the Singapay electronic money balance to the User upon such closure and/or deletion after deducting any outstanding fees (if any), unless, based on Our judgment, it is necessary to withhold a certain portion of the Singapay balance, for example due to a reasonable belief that such portion is related to or arises from fraud, misuse of the Singapay Account, indications of other legal violations, or a breach of these Terms and Conditions.
3. In connection with the closure and/or deletion of a Singapay account, the User and Singapay agree to waive the applicability of Article 1266 of the Indonesian Civil Code, to the extent it requires a court decision for the closure of a Singapay account and/or the termination of these Terms and Conditions.
4. Where the closure and/or deletion of a Singapay Account is at the User’s request, the User is entitled to close/delete the Singapay Account and end their relationship with Us, subject to the following:
   a. The User submits an official request to Us by logging into the Singapay Application and completing the available steps.
   b. The User is obligated and responsible for withdrawing all of their remaining funds in the Singapay Account before the User closes the Singapay Account, including but not limited to withdrawing and/or emptying their Singapay Balance;
   c. The User understands and agrees that a request to delete the User’s Singapay Account through the Singapay Application is made by the User themselves as the authorized holder of the Singapay Account, and the User will be asked to verify the deletion of the Singapay Account.
   d. The User is required to provide reasons, suggestions, and feedback during the account deletion request process.
   e. As an account security measure, the User must enter their PIN code when processing the account deletion.
   f. Singapay has the authority to determine the time limit for processing the User’s account deletion through to completion.
   g. Singapay will process account deletion requests submitted by the User through the Singapay Application or other official channels. Singapay may reject or postpone an account deletion request only where:
   (i) there is still a Singapay Balance in the account whose return has not been settled; (ii) there are Transactions, transfers, top-ups, or refunds that are still in pending status; and/or
   (iii) the User is in the process of resolving a complaint or dispute.
   For each rejection or postponement, Singapay will provide the reasons together with the steps the User needs to take so that the request can be processed, and will continue the deletion process once such conditions have been met.
   h. During the review and approval process of the account deletion, the User may still access the Singapay electronic money platform but may not carry out any transaction activities.
   i. The User is given the opportunity to cancel the account deletion request as long as the account deletion process has not been completed.
   j. If the User cancels the account deletion request, Singapay will immediately stop the review process of the account deletion request.

Limitation of Liability

1. To prevent misuse of the User’s data or Singapay Account, the User must remember and keep confidential the data information they hold, namely the Mobile Number (handphone) used on the Singapay account or the alternative Mobile Number, the PIN or verification code or OTP Code, or other data provided by or received by the User in connection with a Transaction or with respect to any activity or Transaction occurring/carried out by the User, and must not disclose it to any party. The User is fully responsible for all consequences and risks arising in connection with the User’s negligence in maintaining the confidentiality of the data information they hold.
2. The User must safeguard the information referred to above against events including loss, damage, misuse by irresponsible parties, or forgery. The User hereby acknowledges and agrees to release Singapay from liability and compensation of any kind to the User or any party for matters occurring outside the fault and/or negligence of Singapay, including but not limited to the following:
   a. Loss of or damage to the Telecommunications Device or Mobile Number by the User;
   b. Unauthorized access to the User’s personal information occurring outside the scope of Our responsibility or on/through third-party applications;
   c. Any loss arising from the User being indicated to have violated the law and/or from misuse by other unauthorized parties.
3. The User is hereby required to check, ensure, and guarantee that all information and data registered or provided while using Singapay is accurate, true, and complete, and not misleading. Accordingly, the User indemnifies and releases Us from any form of lawsuit, claim, and/or compensation, whether from the User or any party and in any form, in connection with the User’s negligence and/or failure to comply with all provisions of these Terms and Conditions.
4. Where a Transaction has been successfully completed in accordance with the information, data, and/or instructions entered and confirmed by the User, the User hereby acknowledges and agrees that such Transaction is final and cannot be cancelled or withdrawn, including where there is an error by the User in entering the amount, destination number, or other Transaction data, unless it is proven that there is a system failure or an error in the performance of the service and/or Transaction that results in a disruption of the service and it is established that this was not caused by the User, in which case Singapay will correct such error no later than 1 (one) Business Day and at the latest 3 (three) Business Days from when the error is discovered, without prejudice to the User’s right to submit a complaint through Singapay’s official channels.
5. The User will be charged fees in connection with Singapay services in accordance with the provisions applicable at Our end, including Transaction fees and other fees, which will be communicated to the User in accordance with Bank Indonesia Regulations. Users of Singapay services must use data telecommunications services, and the User is responsible for arranging such data telecommunications connectivity, including with respect to the data access rates for such connectivity. The fees and terms of use will be governed by the telecommunications service operator used by the User.
6. The User is responsible for all losses arising from the User’s own errors or negligence, including but not limited to:
   a. Failure to maintain the confidentiality of the PIN, OTP, password, and/or the User’s device;
   b. Errors by the User in entering data, amounts, destination numbers, or Transaction instructions;
   c. Use of the Singapay Application in violation of these Terms and Conditions or laws and regulations.
7. All losses, including late fees or other charges, interest, damage, or losses of any form or kind (including personal injury, emotional distress, and loss of data, goods, revenue, profits, use, or other economic benefit) that occur due to a system failure or an issue at a Bank or Singapay partner beyond Our control, to the extent We have processed it, shall be the responsibility of the User.
8. Other than as stated above, any losses incurred by the User caused by Singapay’s negligence will be borne by Singapay, which may be pursued by way of a complaint through the media provided, namely Singapay’s official email cs@singapay.id and the number 021-38929036.
9. Singapay is obligated to notify all changes and developments to its products, official channels, and any aspects affecting the User, no later than 30 business days before the change takes effect.

Force Majeure

Non-performance or delay in the performance of part or all of Our obligations under the Terms and Conditions will not be deemed a breach of the Terms and Conditions if caused by an event beyond Our control, commonly referred to as Force Majeure, namely:
a. natural disasters
b. fire, labor strikes, war, riots, insurrection, or other military actions
c. actions of authorized parties/agencies affecting the continuity of the provision of telecommunications services
d. actions of third parties that prevent Us from providing telecommunications services
e. decisions of authorized agencies or changes in government decisions affecting the delivery of Singapay services, including changes to the tariffs applied to Users
f. outbreaks, epidemics, and/or pandemics of disease

The User agrees to release Singapay from any claim if We are unable to fulfil the User’s instructions through the Singapay account, in whole or in part, due to a Force Majeure event.

Transaction Security and Confidentiality

1. We pay close attention to the security and comfort of Users when using Singapay services. Therefore, We maintain a security system for when Users conduct transactions to provide assurance to Users that their Transactions are secure and that Users’ information and personal data are stored and used in accordance with the Privacy Policy We have established, subject to applicable laws and regulations.
2. We use adequate servers to safeguard the security of Users’ confidential information. All sensitive information will be transmitted using Secure Socket Layer (SSL) technology, whereby such data can only be accessed by personnel with special authorization who are required to always maintain the confidentiality of such information.
3. We implement reasonable measures to ensure the User’s PIN is not known by anyone other than the User, in order to avoid misuse by other parties. Accordingly, the User is fully responsible for the confidentiality of their PIN.

Representations and Warranties

1. The User represents and warrants that, under applicable laws and regulations, the User is legally competent to use the services provided by Us.
2. Upon carrying out a Premium account upgrade, the User hereby represents and warrants that the User is an individual legally capable of being bound by an agreement or other form of cooperation under the laws of the Republic of Indonesia, and specifically bound by these Terms and Conditions. The User, at the time of accessing, registering for, and/or using the Singapay Application, is at least 17 (seventeen) years of age and is not under guardianship (conservatorship).
3. Use of the Singapay Account and/or Singapay services constitutes the User’s acknowledgment of and agreement to be bound by (i) the Terms and Conditions; (ii) the Privacy Policy; and (iii) all applicable laws and regulations.
4. The User represents and warrants that the User will use the Singapay Application reasonably in accordance with these Terms and Conditions and the laws and regulations applicable in the Republic of Indonesia, and will not take any action intended to circumvent, penetrate, and/or exploit gaps in the security system or cause disruption and/or damage to the Singapay system, misuse the Singapay Account or the products and features in the Singapay Application, or cause losses to Singapay and/or other Users. The User is responsible for all consequences of violating this provision.
5. The User represents and warrants that the funds used in Transactions are not funds derived from criminal offenses prohibited under the laws and regulations applicable in the Republic of Indonesia, that the opening of the Singapay Account is not intended and/or aimed at committing the criminal offense of money laundering or terrorism financing under the laws and regulations applicable in the Republic of Indonesia, that Transactions are not carried out with the intent of deceiving, obscuring, or evading reporting to the Indonesian Financial Transaction Reports and Analysis Center (PPATK) under the laws and regulations applicable in the Republic of Indonesia, that Transactions are not carried out to make payment for Transactions whose nature or object violates the laws and regulations applicable in the Republic of Indonesia, and that the User is fully responsible for, and releases Us from, any claims, demands, or compensation of any kind if the User is found to have committed the criminal offense of money laundering under the laws and regulations applicable in the Republic of Indonesia.
6. The User hereby represents and warrants that they will always use the Singapay Account securely, and will maintain the confidentiality of their User ID number, PIN, OTP, and other information that might cause their Singapay Account to be misused.
7. The User hereby declares their willingness to complete all data or requests for additional data or documents submitted by Us in connection with any follow-up investigation/examination of suspected suspicious transactions and/or indications of violations of the Terms and Conditions, the Privacy Policy, or laws and regulations.
8. The User will not grant rights, authority, and/or power of attorney in any form and under any circumstances to any other person or party to use their data, account, and/or PIN. The User is, for any reason and under any circumstances, prohibited from transferring their Singapay Account to any person or party.
9. The User is entitled to request access to, correction of, and/or deletion of data/documents that have been submitted to Us in accordance with the laws and regulations on personal data protection, provided that Singapay may refuse deletion requests for data that must be retained under laws and regulations during the applicable retention period, accompanied by the provision of reasons to the User. We are entitled to use such data and information in connection with Transaction services or matters relating to the administration of the User’s account with Singapay in accordance with the Privacy Policy and applicable laws and regulations.
10. The User represents and warrants that they will update and notify Us of any changes to the User’s data that has been registered and/or submitted to Us.
11. By carrying out Transactions through Singapay, the User understands that all communications and instructions from the User received by Us will be treated as authentic evidence even if not made in the form of a written document or issued in the form of a signed document. The User hereby represents and warrants that the User does not and will not deny the validity and enforceability of electronic communications and instructions submitted by the User through Singapay as authentic evidence.
12. The User hereby declares that they understand and agree that the services provided through Singapay are provided “as is” and “as available”, without any warranty from Us that the services provided through Singapay are fit for any particular purpose or need of the Customer. In this regard, Singapay does not warrant that:
    a. the use of Singapay will meet all of the Customer’s needs,
    b. the Singapay Application will be available continuously without disruption/error,
    c. every nonconformity in the Singapay Application will be corrected to meet the User’s wishes.
    Nevertheless, We will continue to use Our best and reasonable efforts to provide the best service for Users.

Complaint Submission

To submit a complaint, the User may do so through Singapay’s official channels, namely:

1. Email: cs@singapay.id
2. Telephone: 021-38929036
3. Singapay Application

The timeframe for resolving User complaints refers to Bank Indonesia Regulations, namely a maximum of 20 business days, depending on the type of complaint.

Miscellaneous

1. These Terms and Conditions are subject to, governed by, and performed in accordance with the laws of the Republic of Indonesia.
2. These provisions apply to all Users who access and/or use any or all of the Singapay services available in the Singapay Application, together with the related services, provided through the Singapay Application and/or other applications issued by Us from time to time.
3. In the event of a dispute over the interpretation or implementation of the Terms and Conditions, We and the User agree to resolve such dispute through amicable deliberation. Where amicable settlement is not reached, the User may also submit a complaint through a dispute resolution body or institution or to Bank Indonesia. If the above methods are unsuccessful, the dispute will then be resolved through the Tangerang District Court.
4. Singapay, including its name and logo, code, design, technology, and business formulas, is protected by copyright, trademark, patent, and other intellectual property rights and is subject to the laws and regulations applicable in the Republic of Indonesia.
5. Our failure or delay in taking immediate action, imposing sanctions, or exercising Our rights or obligations, and/or filing a lawsuit or claim for a violation of these Terms and Conditions, does not extinguish the User’s obligations and does not constitute a waiver of Our right to take any necessary action in the future.
6. The User is prohibited from and/or may not assign their rights and obligations under these Terms and Conditions without Our prior consent, at Our sole judgment and discretion. The transfer of all or part of the Singapay Balance by the User to any other party does not constitute a transfer, or any form of transfer, of the Singapay account.
7. If any provision of these Terms and Conditions is found to violate applicable laws and regulations, in whole or in part, then the provision deemed to be in violation shall be severed from these Terms and Conditions, and the remaining terms and conditions shall remain valid and binding.
8. These Terms and Conditions, in whole or in part, including the features or services offered by Us, may be amended, updated, and/or supplemented from time to time based on the policies applicable at Singapay. Any changes to these Terms and Conditions will be communicated to the User.
9. The User hereby acknowledges and consents to Our use of the User’s personal data/information in the features available in the Singapay Application for the development of Singapay’s service types/models and usage, with due regard to the provisions of the Privacy Policy and applicable laws and regulations.
10. The management of the User’s personal data is governed by the Privacy Policy, which constitutes an integral and inseparable part of these Terms and Conditions, and the User accordingly hereby declares that the User accepts and agrees to the related Privacy Policy.
11. User Transactions carried out through Singapay are stored automatically on Singapay’s servers. The User acknowledges and understands that We have used Our best efforts to maintain the security of Our system. Nevertheless, in the event of any discrepancy or inconsistency between the User’s data, balance, or Transaction records, the User agrees that the data, balance, or Transaction records that prevail and are recognized are those held by Us.
12. The User understands that in using Singapay, the User’s personal data will be collected, used, and displayed so that the User can enjoy Singapay services to the fullest.

Closing Provisions

The User understands and agrees that these Terms and Conditions constitute an agreement in electronic form, and the User’s action of pressing the register button or the login button or ticking the consent box when accessing Singapay constitutes the User’s agreement to be bound by an agreement with Us, such that these Terms and Conditions are legally valid and binding and remain in effect for as long as the User uses Singapay. We may assign Our rights under these Terms and Conditions by providing information and/or notice (notification) to the User.