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Privacy Policy

Last updated: October 20, 2025

This Data Protection Policy (the "Policy") applies to the collection, use and disclosure of personal data arising from goods and/or services offered by BTT Pass.

1. General

1.1 Policy Statement

This Policy provides information on the obligations and policies of BTT Pass in respect of personal data. BTT Pass undertakes to use reasonable efforts in applying, where practicable, the principles and processes set out herein to its operations.

1.2 Staff Obligations

BTT Pass's officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, BTT Pass.

1.3 User Consent

By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to BTT Pass as well as to its respective representatives and/or agents (collectively referred to as "we", "us" or "our") collecting, using, disclosing and sharing your Personal Data in the manner set forth in this Policy.

1.4 Additional Consents

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5 Definition of Personal Data

For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the "PDPA"), "Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information which an organisation has or is likely to have access to.

2. Contacting the Data Protection Officer

2.1 Access and Correction Rights

Where you legitimately request access to and/or correction of Personal Data relating to you which is in the possession and control of BTT Pass, we shall provide and/or correct that data in a reasonable time and manner in accordance with our standard procedures.

2.2 How to Contact

To ensure that BTT Pass receives your complaints and enquiries, please send them via email to our Data Protection Officer (DPO) at: shawnli@digitadvisory.info

2.3 Third-Party Referrals

Please note that if your personal data has been provided to us by a third party (e.g. via a referral process), you should contact that individual to make queries, complaints, and access and correction requests to BTT Pass on your behalf.

2.4 Opt-Out Options

Should you not wish BTT Pass to use your Personal Data for any of the purposes listed below, or not to receive promotional materials from BTT Pass, you may opt out by sending a clearly worded email to the DPO via the email address provided above. Your request shall be processed within a reasonable time.

3. Statement of Practices

3.1 Types of Personal Data Collected

As part of its day-to-day activity, BTT Pass may collect from you, through various means including via our websites, mobile applications, and registration forms, some or all of the following Personal Data:

3.2 Purpose of Collection

The Personal Data mentioned above is collected for the following purposes:

3.3 Disclosure of Personal Data

In order to carry out the functions described above, BTT Pass may disclose your Personal Data to our affiliates, subsidiaries, and related companies.

3.4 Third-Party Disclosure

BTT Pass may also disclose your Personal Data to the following third parties:

3.5 Circumstances for Disclosure

BTT Pass may disclose your Personal Data in the following circumstances:

3.6 Optional Personal Data

In some instances, you may be requested to provide optional Personal Data to improve our services. Failure to provide this optional data may prevent us from providing certain personalized services. This optional data includes age, gender, employment details, etc.

3.7 Call Recording

Under certain circumstances, telephone calls made to any of our service or inquiry numbers may be recorded for quality control, staff training, and development purposes. By agreeing to this Policy, you give your clear and unambiguous consent for such recordings.

4. Transfer of Personal Data Overseas

Your Personal Data may be processed by BTT Pass, its affiliates, agents and third-party service providers in jurisdictions outside of Singapore. In this event, BTT Pass will comply with the terms of the PDPA and ensure appropriate safeguards are in place.

5. Accuracy of Personal Data

Where possible, BTT Pass will validate data using generally accepted practices and guidelines. To assist in ensuring the accuracy of your Personal Data, please inform us of any updates by sending an email to the DPO at shawnli@digitadvisory.info.

6. Protection of Personal Data

BTT Pass uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data. However, we cannot ensure or warrant absolute security, and you transmit information to us entirely at your own risk.

7. Access and Correction of Personal Data

7.1 Your Rights

You have the right to check whether BTT Pass holds any Personal Data relating to you and obtain copies of such data, or require BTT Pass to correct any inaccurate Personal Data.

7.2 Administrative Fees

BTT Pass reserves the right to charge a reasonable administrative fee to process your requests. Upon payment of the requisite fee, your request shall be processed within a reasonable time.

7.3 Identity Verification

Our security procedures may require proof of identity before we reveal information. You are responsible for keeping your account information safe, as you will be responsible for any action taken in response to a request using your details.

8. Storage, Deletion and Retention

8.1 Data Retention

BTT Pass will delete or anonymise Personal Data when it is no longer required for reasonable business or legal purposes, in accordance with our internal procedures and applicable laws.

8.2 Account Deletion

To request permanent deletion of your account and personal data, please email shawnli@digitadvisory.info. Please note that deletion cannot be undone, and we will not be able to recover any of your data in the future.

9. Communications and Do Not Call Registry

By agreeing to this Policy, you grant BTT Pass your clear and unambiguous consent to contact you using all communication methods you have provided, even if your numbers are listed on the Do Not Call Registry, for the purposes stated in this Policy.

10. Children's Privacy

BTT Pass does not target and is not intended to attract children under the age of 18 years old. We do not knowingly solicit personal information from children under 18. If you are under 18 years of age, your parent or legal guardian MUST contact us at shawnli@digitadvisory.info to obtain appropriate consent forms before using our services.

11. Changes to This Policy

BTT Pass reserves the right to alter any clauses contained herein in compliance with local legislation and/or to meet its policy requirements. You should review these terms regularly. If you do not agree to modified terms, please inform us as soon as possible.

12. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.

13. Third-Party Websites

This Policy only applies to the collection and use of Personal Data by BTT Pass. It does not cover third-party sites to which we provide links. BTT Pass does not share your Personal Data with third-party websites and is not responsible for their privacy practices.

14. No Sale of Personal Information

BTT Pass will not sell your personal information to any third party without your permission. However, we cannot be responsible for the actions of third-party sites which you may access through our website.

15. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: shawnli@digitadvisory.info