Privacy Policy

This Privacy Policy describes how Autopilot Technologies Pte. Ltd., and its affiliates and subsidiaries (“Autopilot”, “we”, “us” and “our”) processes information about you in connection with our business.

It covers personal information that is provided to us via websites that link to this Privacy Policy (the “Websites”) and your use of our products and services (collectively, the “Services”). It also covers certain information (such as account data and usage data, as described below) that is provided to us via your use of our Software-as-a-Service (SaaS) offering. This Privacy Policy also describes certain rights that you have with regard to our processing of your personal information. We provide the Services to authorized users pursuant to a merchant license agreement between Autopilot and the applicable merchant.

By accessing the Services, you represent and warrant to us that you have read, understood and agree to the terms of this Policy. You will also be deemed to have provided your consent to Autopilot to use your Personal Data for the purposes outlined in this Policy. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

If you do not agree to the terms of this Policy, you must not access the Services or provide any Personal Data (as defined below) to us. In addition, if you are a customer of Autopilot (“Merchant”) or representative of the Merchant, you must notify the Autopilot in writing of your decision to reject this Policy using the Contact Us details below. Your rejection of this Policy or withdrawal of your consent to the collection, processing, use and/or disclosure of your Personal Data (as defined below) may affect the Services which Autopilot is able to provide to you.

This Privacy Policy does not apply to data that authorized users upload or otherwise ingest into the Services or otherwise provide to us in connection with support or professional services (collectively, “Content”). We process such Content pursuant to instructions provided by the merchant (i.e., the merchant is the “controller”, and we are the “processor”) and our processing is governed by the applicable merchant agreement. To the extent that your personal information is included as Content that is provided to us by a merchant, you should refer to the applicable merchant privacy statement regarding the merchants’s processing of your personal information and your rights with respect to such processing.

GENERAL
From time to time, Autopilot may collect data which enables a natural person to be identified ("Personal Data"). Some examples of Personal Data are:
1. Personal particulars (e.g. name, contact details, address, date of birth, identity card/passport details);
2. Images and biometrics (e.g. voice and video recordings of you, including our conversations with you for verification or other purposes);
3. Employment details (e.g. occupation, directorship, share ownership);
4. Your personal opinions made known to us (for example, through feedback or surveys);
5. Information relating to your activities, habits, preferences and interests arising from your use of the Platform and the products and services of Autopilot, our partners or vendors; and/or;
6. Other electronic data or information relating to you such as IP addresses, cookies, activity logs, online identifiers and location data through your usage of our products and services or as part of their delivery to you.
ACCURACY OF PERSONAL DATA
1. We generally rely on Personal Data provided by you (or your authorised representative). Please ensure that the Personal Data provided by you is current, complete, and accurate at all times. To update us if there are any changes to your Personal Data, inform our legal team in writing or via email using the Contact Us details provided below.
PERSONAL DATA PROVIDED TO AUTOPILOT
1. Where you provide Personal Data to us, you represent and warrant to us that (i) the relevant individual has been notified of the purposes for which the data will be collected, processed, used and disclosed; and (ii) you have obtained the relevant individual's consent for the collection, processing, use and disclosure of such Personal Data by Autopilot, and have been duly authorised by the relevant individual to provide the Personal Data to us.
2. You must promptly inform us upon becoming aware of the withdrawal by the relevant individual of his/her consent to the collection, processing, use and/or disclosure by Autopilot of the Personal Data provided to Autopilot. The withdrawal of such consent may affect the Services which Autopilot is able to provide to you.
3. Any consent given in relation to Personal Data provided to us shall, subject to applicable laws and regulations, survive the death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of any account in connection with the use of the Services.
PROTECTION OF PERSONAL DATA
1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection and encryption to secure all storage and transmission of Personal Data by us. We also disclose Personal Data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
2. You should still be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure.
USE OF PERSONAL DATA
1. We may use your Personal Data for our business purposes, such as:
  1. To develop, improve and provide payments facilities, products or services (whether made available by us or through us), including but not limited to:
    1. Executing payments, commercial or other transactions and requests, including processing, settlement, clearing or reporting on these transactions;
    2. Carrying out research, planning and statistical analysis; and
    3. Analytics for the purposes of developing or improving our products, services, security, service quality, advertising or customisation strategies.
  2. Assessing and processing applications, instructions or requests from you;
  3. Communicating with you, including providing you with updates on changes to products, services and payments facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and payments facilities and their terms and conditions;
  4. Managing our infrastructure, business operations and complying with internal policies and procedures;
  5. Responding to queries, complaints or feedback;
  6. Addressing or investigating any complaints, claims or disputes;
  7. Verifying your identity for the purposes of providing payments facilities, products or services;
  8. Conducting credit checks, screenings or due diligence checks as may be required under applicable law, regulation or directive;
  9. Complying with all applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
  10. Monitoring products and services provided by or made available through us;
  11. Complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
  12. Creating and maintaining credit and risk related models;
  13. Financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
  14. Enabling any actual or proposed assignee or transferee, participant or sub-participant of Autopilot’s rights or obligations to evaluate any proposed transaction;
  15. in connection with any sale, acquisition, merger or restructuring of Autopilot's business;
  16. For the marketing of products and services ancillary or related to the use of the Platform;
  17. To detect, prevent and investigate fraud;
  18. Enforcing obligations owed to us;
  19. in connection with performance of our duties and obligations when seeking consultancy or professional advice, including legal advice; and/or
  20. Administering benefits or entitlements in connection with our relationship with you or arising from your participation in events, campaigns, or marketing promotions by us or in conjunction with our partners. This will include the administration of loyalty, rewards programmes, lucky draws, and/or sending gifts and awards.
  21. For service personalization and improvement using artificial intelligence (large language models), including:
    1. Personalizing your experience by analysing your usage of our platform and tools to offer improved feedback, recommendations, insights and relevant features;
    2. Improving our products and services by using aggregated data to train our models, helping us to enhance security, develop new features, and improve service quality;
    3. Conducting automated checks for purposes such as customer due diligence, fraud detection and risk management to protect your account and comply with our legal obligations.
2. In addition to the above purposes, we may also use Personal Data for purposes set out in the terms and conditions that govern our relationship with you.
DISCLOSURE AND SHARING OF PERSONAL DATA
1. Where necessary to fulfil our obligations in the course of or in connection with our provision of the goods and services requested by you, or to fulfil our business purposes stated above, Autopilot may from time to time disclose Personal Data to other members of Autopilot and third parties such as the following whether inside or outside of Singapore:
  1. Regulatory authorities, courts, dispute resolution tribunals, and governmental agencies;
  2. Any agent, affiliate, business partner, supplier, vendor and sub-contractor which provides products and services to Autopilot in connection with the Services (for example, vendors who we engage to perform fraud detection and monitoring, payment intermediaries who we work with to provide payments services, and data visualisation tools);
  3. Any actual or proposed assignee of Autopilot or transferee of Autopilot's rights in respect of all or any part of the assets, properties or business of Autopilot;
  4. Any credit bureau as well as the members of such credit bureau (for example, banks, financial intermediaries, payment intermediaries, card network members and insurers);
  5. Financial institutions and other business partners with whom Autopilot jointly offers or develops Services (but they may not use your Personal Data to independently market their own products or services to you unless you consent that they can do so); and
  6. Analytics and search engine providers that assist us in the improvement and optimisation of the Services; and
  7. Anyone we consider necessary in order to provide our Services; and
  8. Technology and AI Service Providers, including Large Language Models who provide the tools and infrastructure for data analysis, machine learning, and AI-powered features, under strict confidentiality and data protection agreements.
2. We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and any other applicable data protection laws. We will also ensure that your Personal Data will continue to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PORTABILITY
1. You may request that we transmit to another organization your Personal Data stored with us, and we will comply if all the relevant requirements under the PDPA are satisfied.
2. If we are unable to comply with your request, we will notify you of our refusal and the reasons for our refusal.
3. Subject to the PDPA, Autopilot reserves the right to charge such fees as it may, in its sole and absolute discretion, deem appropriate for the grant of such data transmission. You will be notified of such a fee before we process your request.
MARKETING COMMUNICATIONS
1. If you should consent, you may, from time to time, receive a variety of communications, including but not limited to newsletters, emails, WhatsApp and text messages (the "Marketing Communications"), that may include service updates, product advertising and offers related to the Services which we believe you may be interested in.
2. You may, at any time, change your Marketing Communications preferences by contacting Autopilot.
3. Apart from Marketing Communications, you may receive important service information that we believe is critical to your use of the Services. In such exceptional circumstances, such information will be sent to you regardless of your preferences.
OTHER WEBSITES
1. Our Platform may contain links to other websites which are not maintained by Autopilot. This privacy policy only applies to the Services. When visiting these third party websites, you should read their privacy policies which will apply to your use of the websites.
COOKIES AND TRACKING TECHNOLOGIES
1. We use cookies and similar tracking technologies to personalize your experience and improve our services. A cookie is a small text file placed on your computer or mobile device when you visit a website or use a mobile application. Cookies collect information about users and their visit to the website or use of the mobile application, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or mobile application. We also use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our mobile application.
2. If you wish to deny the use and saving of cookies from the Services on to your computers and/or other electronic devices, you should take the necessary steps within your internet browsers’ security settings to block all cookies from the Services. You can choose to delete the cookies at any time. However, do note that when you enable blocking of cookies, certain features and functions may be limited in your use of our websites or mobile application. Where legally required, we obtain your consent before setting non-essential cookies.
AI GOVERNANCE AND SAFEGUARDS
1. Autopilot follows the principle of data minimisation across use-cases by sending only the specific fields required for the AI models used. We also apply confidence thresholds (e.g., accepting responses only above a set confidence level) and conduct back-testing to ensure reproducibility and reliability of results.
2. Autopilot conducts testing of LLM models used against industry standards and frameworks to validate AI system security which includes injection and prompt manipulation attacks, and technical validation that models used cannot be manipulated into revealing Sensitive Information Disclosure.
3. Autopilot conducts vendor due diligence and enforces contractual controls with our external LLM providers to obtain assurance that Autopilot's merchant data is secured.
RETENTION OF PERSONAL DATA
1. Personal Data is retained as long as the purpose for which it was collected remains.
2. Without limiting the generality of the foregoing, in the event the Merchant terminates its relationship with us, we may retain the Personal Data provided to us for so long as we deem reasonably necessary for our business or audit purposes or to comply with applicable regulations, guidelines and directives.
3. We will cease to retain your Personal Data or remove the means by which the Personal Data can be associated with you, as soon as we deem that such retention ceases to meet the purpose for which the Personal Data was collected and any other business, audit, or legal purposes.
ACCESS AND CORRECTION
1. You may access or, where applicable, make corrections to the Personal Data held by Autopilot. To do so, please contact Autopilot as per the Contact Us details below.
2. Autopilot reserves the right to charge such fees as it may, in its sole and absolute discretion, deem appropriate for the grant of such access and to correct any such Personal Data. You will be notified of such a fee before we process your request.
3. We will respond to your request as soon as reasonably possible. Should we be unable to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.
4. 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).
5. Where we use automated processing or AI to make a decision that has a significant impact on you, you have the right to request information about how that decision was made. In certain circumstances, you may also have the right to request a review of the decision by a human.
AMENDMENTS AND UPDATES
1. We may amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way Autopilot uses your personal data or any changes to the laws and regulations applicable to Autopilot. We will make available the updated policy on our website (https://autopilot.is/legal/privacy). All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.‍
MISCELLANEOUS
1. In the event of a breach of security in respect of Personal Data and to the extent required by the PDPA, we will as soon as reasonably practicable provide notice of such breach to the relevant individual, setting out the extent of the breach, the affected Personal Data and any steps taken by Autopilot to remedy and limit the consequences of the breach.
2. Nothing in this Policy shall be construed as Autopilot providing an indemnity to any Merchant in relation to any Personal Data or use thereof. To the extent permitted by applicable law, Autopilot expressly excludes liability or any losses which the Merchant may suffer on account of Autopilot’s collection, storage, use, transfer or retention of Personal Data in accordance with this Policy. In any event, Autopilot expressly excludes any liability to the Merchant which are in the nature of indirect or consequential losses, special losses, loss of profits, loss of contracts, loss of reputation or goodwill, or other tangential or intangible losses that a Merchant may suffer on account of a breach of this Policy by Autopilot or any of its agents, partners, vendors or service providers.‍
CONTACT US
1. You can reach us by email at Legal@autopilot.is or at the following mailing address:
  1 RAFFLES PLACE, #34-04, ONE RAFFLES PLACE, SINGAPORE 048616