Website terms and conditions

Platform Terms (Corporate)

1. Scope

These terms apply to the HSBC Thrive Benefits platform, including the website located at https://thrivebenefits.hsbc.com.sg as well as the apps, communications and other services that state that they are subject to these terms (together, the “Platform”).The services provided by HSBC Bank (Singapore) Limited (“HSBC”) in connection with the Platform shall be referred to as the “Services” under these terms, which include providing access to any platform or communication or administration services (relating to benefits, rewards and/or any other matters). The Platform and Services shall be provided by HSBC in accordance with its prevailing operational, technical, internal and/or other rules, procedures, guides and requirements (if any) (“Rules”).

By using or continuing to use the Platform and the Services, you (the corporate, employer or subscriber of the Platform) acknowledge and agree to be bound by these terms.

We live in a rapidly changing world. Sometimes this means we need to update our terms. These updates include amendments to:

Fees and charges.
Operational, technical, internal or other rules, procedures, guides and requirements
Our partners, benefits or partnership offers/benefits

We may amend or supplement our fees, charges and terms, if it is reasonably necessary to:

Reflect changes to our operational costs, business operations or systems and processes, or our arrangements with third parties;
give effect to:
1. applicable law, rule, regulation;
2. a change, recommendation, order, requirement, notice, direction, code, circular or guidance issued by any regulatory, supervisory, governmental, statutory authority, stock exchange, self-regulatory, or resolution body having jurisdiction over us or a court of competent jurisdiction;
Reflect changes to industry or market conditions or practice;
align with standards or expectations including in respect of:
1. banking and financial services practices;
2. environmental, social and governance practices;
3. consumer and investor protection practices;
4. cyber, digital, technology (including financial technology (FinTech)) practices e.g., those relating to crypto-assets, digital assets, virtual assets, asset tokenisation and artificial intelligence (including generative artificial intelligence and machine learning);
5. operational resilience and data management practices; or
6. taxation and transfer pricing practices; or
otherwise protect our legitimate interests.

To the extent reasonably practicable, we’ll give you reasonable notice of any changes

thereof before they take place.

We can choose how to give this notice to you. This may include:

contacting you directly through email
publishing the change on our website or app; and
using any other method we think is reasonably appropriate.

If you don’t agree with a change, you can inform of us of your desire to cancel your subscription to the Services and Platform and pay all amounts you may owe us.

2. Eligibility and Registration

To access the Platform and Services, you need to satisfy HSBC’s prevailing eligibility criteria and create a Platform account, and also release to us personal data of your eligible employees (which may include your officers, directors and contract or other staff, subject to HSBC’s acceptance at its discretion), obtain the requisite consents from your eligible employees for such personal data to be released to us and inform each of your eligible employees to expect a registration email from HSBC and create their own personal Platform account, all in accordance with the Rules and our prevailing Privacy Policy found here (https://thrivebenefits.hsbc.com.sg/terms#privacy-policy). You shall inform us in writing immediately after becoming aware that an individual will cease or, in the case of immediate termination, has ceased to be your eligible employee, and you shall terminate the individual’s access right to the Platform and Services when they ceased to be an employee. Further, we shall also have the right at any time without liability to forthwith terminate that individual’s access to the Platform and Services. We shall not have any liability for allowing an individual to continue to access their personal Platform account until and unless we were informed in writing that the individual is no longer an employee and we have completed the account termination process thereof.

3. Representation

You represent and warrant to us on a continuing basis that: (a) you have full power, authority and legal right to enter into, accept and perform your obligations under these terms and have taken and obtained all necessary corporate or other action and consents to authorize the execution and performance under these terms; and (b) your acceptance of these terms and performance by you of any of your obligations hereunder will not conflict with or result in a breach of any law, regulation, judgment, order, authorization, agreement or obligation applicable to you, including, without limitation, any provision of your constitutional documents.

4. Undertaking

You undertake and agree on a continuing basis that you and your employees, representatives and agents will at all times:

a) comply with all applicable laws, regulations, rules, regulatory directives, contractual obligations and HSBC’s policies including anti-money laundering and anti-corruption regulations and good and fair business practice policies;

b) comply with the Rules and forward to HSBC any document that it may require from you in relation to the Platform and/or the Services;

c) provide us with accurate information about you and/or your business when registering to use the Platform and the Services and update such information including the Platform account information in order to ensure that it remains accurate;

d) not disclose information available to you pursuant to the Platform including quotations of products and product terms (unless they are in the public domain) or your Platform account password to anyone and will notify us immediately of any unauthorized use of your Platform account, be responsible for all activities that occur under your Platform account whether you know about them or otherwise, and immediately notify us if you believe that your Platform account is no longer secure;

e) not sell, rent, lease, share or provide access to your Platform account to anyone else (except to your authorized officers agreed with us);

f) provide us with such information or data (including personal data) in relation to any service, benefit or product you have taken up with any third party (including insurers) for the purpose of having such information or data uploaded or reflected on the Platform; you further authorize us to approach any such third party to request for the information or data and authorize such third party to disclose such information or data to us upon our request without the need for the third party to refer to you; we are authorized to share this authorization from you with the third party; and

g) not access the Platform and the Services on behalf of anyone else or create a Platform account in a name other than your own.

5. Your activity on the Platform and under the Services

Any engagement between you and any other service, benefits or product provider (“Other Provider”) on the Platform and pursuant to the Services is independent of our involvement and will be subject to separate terms and conditions agreed between you and the Other Provider and you acknowledge that we will have no liability or responsibility to you, your employee or any other person in connection with any service, benefit or product of Other Provider or any breach or alleged breach, claim, loss or action arising from any agreement, contract or relationship between you and the Other Provider. The Other Provider is not an agent nor representative of HSBC. Neither HSBC or any of its subsidiaries or affiliates is soliciting, advising or recommending any action, makes any representations or warranties or accepts any liability, in relation to any service, benefit or product of any Other Provider.

6. Fees, Charges and invoicing

6.1
Access to and/or use of the Platform and Services are subject to HSBC's applicable prevailing fees, charges and taxes (including any good and services tax where applicable). In addition, certain products or services offered through the Platform and the Services may require your payment of fees or charges ("Paid Services"). Fees and charges for such Paid Services will be available from within the platform and from your sales representative. If you access and/or use Paid Services, you agree to pay HSBC and/or the relevant third party providers the applicable prevailing fees, charges and taxes (including any good and services tax where applicable) and acknowledge that additional terms specific to the Paid Services may be applicable.

6.2
We reserve the right at any time to change the fees or charges for the Platform, Services or Paid Services or charge for any of the other services or products offered through the Platform and the Services in accordance with Clause 1. Complimentary products/services can be withdrawn by us at any time.

6.3
Any payment by you shall be made in good funds, without delay as per the invoiced terms and without any withholding or deduction, unless any withholding is required by law, in which case, you shall make such further payment(s) to us so that we received the full amount as if no such withholding is made in the first place.

6.4
Your or any of your employees' sign-up with any third party provider will be subject to the fees, charges and costs of each third party provider which will be a matter between you/your employees and each third party provider.

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7. The right to use the Platform and the Services

(A) Ownership of the Platform, the Services and any published content

You agree that all title, ownership and intellectual property rights (including copyright, trademarks and patents) in respect of the Platform and the Services are owned by us or the relevant licensors with whom we have an agreement and you do not have any ownership interest in the Platform, the Services, any HSBC Content or Third-Party Content (as defined below). All trademarks, service marks, images and logos included on the Platform and the Services (“Marks”) are the property of HSBC or third parties, and you may not use such Marks without the express prior written consent of HSBC or the applicable third party. You agree not to remove, alter or obscure any copyright, trademark, service mark (including the Marks) or other proprietary rights notices incorporated in or accompanying the Platform and the Services.

You retain ownership of any material which is wholly owned by you and which you transmit or post through the Platform and the Services (“User Content”), except to the extent that such material is, is based on or is derived from HSBC Content or Third-Party Content. You agree that you are solely responsible for, and warrant, the accuracy, lawfulness, acceptability, appropriateness, quality, content and legality of all User Content, including the means by which User Content is acquired and the transmission of User Content outside of the Platform and the Services. By providing the User Content to the Platform and the Services, you represent and warrant that you have all rights (including the right to use any intellectual property right of any party) necessary to transmit User Content through the Platform and the Services and to otherwise have User Content used as part of the Platform, the Services or as otherwise contemplated herein, and you agree the User Content may be viewed by other users. You grant to us a perpetual, irrevocable, transferable, royalty-free, worldwide, non-exclusive right and license, including the right to grant sublicenses to third parties, to use, reproduce, publicly display, publicly perform, prepare derivative works from and distribute the User Content, without any further consent, notice and/or compensation to anyone, for any purpose in connection with the Platform and the Services.

Without limiting the generality of the foregoing, all data, information and materials (“Material”) available on the Platform and the Services, including any application programming interface (“API”) of HSBC, excluding Third Party Content and User Content (collectively, “HSBC Content”), are the copyrighted works of HSBC, and HSBC expressly retains all right, title and interest in and to the HSBC Content, including, without limitation, all intellectual property rights therein and thereto. You acknowledge and agree that use of HSBC Content for purposes other than as expressly permitted in these terms may constitute an infringement of HSBC's intellectual property rights.

The Platform contains and provides access to Material provided by third parties, including third party APIs (collectively, “Third Party Content”). Third Party Content is the copyrighted work of its owner, who expressly retains all right, title and interest in and to the Third Party Content, including, without limitation, all intellectual property rights therein and thereto. Third Party Content may also be subject to different or additional terms of use and privacy policies of such third parties. HSBC is not a party to the sales contract or user agreement between you and any third party provider. You acknowledge and agree that it is your responsibility to review the third party provider's terms before accepting them, or to contact the appropriate third party provider for further information regarding the terms applicable to Third Party Content. You acknowledge that acceptance of the third party provider's terms or use of their Third Party Content creates a binding agreement between you and the third party provider, and HSBC does not bear any liability or responsibility for the third party provider's content or actions. The third party provider of any Third Party Content is solely responsible for its content or warranties, and any claims that you may have related to the same. Although HSBC is not obligated to monitor access to or use of the Platform and the Services or to review or edit any Third Party Content, HSBC has the right to do so for the purpose of operating and publishing the Platform and the Services, to ensure compliance with these terms, to protect the health or safety of anyone that HSBC believes may be threatened, to protect HSBC's legal rights and remedies, to report a crime or offensive behavior, or to comply with applicable law. HSBC may elect to remove or disable access to any Third-Party Content, at any time and without notice.

(B) Your relationship with us and User Content

HSBC may restrict, modify, or limit access to and use of certain User Content or any or all the Platform and the Services, depending on where a user is located.

We have no control over the content generated in connection with the Platform and the Services and assume no responsibility for your actions and/or conduct (whether online or offline) or any content that you share. You hereby agree to defend and indemnify us and keep us indemnified for any claims, liabilities, damages, consequences and losses incurred by us in connection with your provision of User Content or breach of any of these terms.

For the avoidance of doubt, any content generated by you (including any User Content) is not endorsed in any way by HSBC and does not represent us in any way.

Nothing in these terms creates any joint venture, relationship of partnership or agency between you and HSBC. You shall not, at any time, act or purport to act as HSBC's agent.

(C) Your right to use the Platform and Services

You shall use the Platform and Services in accordance with these terms solely and strictly for your internal business purposes. Other than the rights expressly granted to you under these terms, you shall not have any rights to any intellectual property rights of HSBC and/or its affiliates. All other rights not expressly granted to you under these terms are hereby reserved to HSBC (or its relevant licensors).

The Platform is supplied on a software-as-a-service basis as part of the Services, and nothing in these terms grants to you any right to receive a copy of any of the software comprising the Platform, or to deal with the Platform in any way, except and only to the extent implied by the means of access to the Platform provided by HSBC (for example, through a web browser accessing the HSBC website or a mobile device app published by HSBC).

(D) Use of Platform Content and User Content

For the purposes of these terms, “Platform Content” means HSBC Content and Third Party Content.

HSBC reserves the right, but does not undertake the obligation, to monitor and manage any posting or uploading of, access to and use of the Platform, the Services, User Content and Platform Content (including for the purpose of complying with applicable law, regulations, the directions by courts and regulatory authorities), and to investigate and take appropriate legal action against any party that uses the Platform, the Services or Platform Content in violation of these terms or applicable law. HSBC reserves the right to accept, reject, withdraw, close, terminate or modify any Platform Content or User Content at any time at its discretion without notice, but assumes no liability based on/for its acceptance, rejection, withdrawal, closure, termination, modification or failure to modify or service any Platform Content or User Content.

You acknowledge and agree to respect the intellectual property rights of others, and that HSBC may treat it as a breach of these terms and immediately terminate your access to the Platform and the Services if you infringe the rights of any third party.

(E) Platform usage

You agree not to use the Platform and the Services for posting any material which is incomplete, false, inaccurate, illegal, inappropriate, insensitive, obnoxious, controversial, harmful or non-compliant with our Content Policy or advertisement, promotional materials or solicitation related to any product or service that is competitive with HSBC products or services, or engage in or encourage conduct that would constitute a criminal offense, give rise to civil liability or otherwise violate any applicable law, rule, regulatory directive or regulation, or use the Platform and the Services in any way that could adversely affect or reflect negatively on HSBC, the Platform or the Services, or discourage any person from using all or any portion of the features of the Platform and the Services (such as thru the use of abusive or offensive language, spamming, social engineering, or scamming).

You further agree not to, directly or indirectly reverse engineer, decompile, disassemble or otherwise attempt to discover the source code, object code, resultant code or underlying structure, ideas or algorithms of the Platform or the Services or any software, documentation or data related to or provided with the Platform and the Services (“Proprietary Materials”), or use the Platform, the Services or Proprietary Materials outside of the scope of the rights expressly granted in these terms.

(F) Encouraging or enabling actions of others

You agree not to violate or attempt to violate the security of the Platform, the Services or HSBC's system or network security, including, without limitation, the following:

accessing data not intended for users of the Platform or the Services, or gaining unauthorized access to an account, server or any other computer system;
removing, disabling, circumventing, or modifying any technological measure we implement to protect users, third party providers or any of their associated intellectual property.

(G) Links to third party websites or other online resources

The Platform and the Services contain links and integrations with third party websites and services (including Third Party Content), and you agree that we provide links to and integrations with such websites and services solely as a convenience and we have no responsibility for the content or availability of such websites or services, and that we do not endorse such websites or services (or any products or other services associated therewith). You acknowledge and agree that it is your sole responsibility for and assume all risks arising from your use of such third-party websites or resources.

You are responsible for deciding if you want to access third-party sites that are linked from the Platform and the Services. Your use of such websites and services will be subject to the terms applicable to each such website and service including their privacy policy.

8. No reliance on Platform

You agree that:

you are solely liable and responsible for your business and other activities, and the performance thereof and the compliance with relevant laws;
the Platform and the Services are prepared on a general basis and may not be appropriate or complete for your specific circumstances or requirements and you are therefore responsible for undertaking your own inquiries to determine the suitability of the Platform and the Services for those circumstances and requirements;
the platform comes with standard security setup and hashed password protection. If required for your needs you may seek a quotation for single-sign-on capabilities for an additional fee;
the Platform and the Services are not designed nor intended to guarantee your compliance with legal, regulatory or policy compliance obligations; and
the Platform and the Services have not been designed or customized to account for your business or situation including any specific business activities, geographic location, relevant laws or regulations.

9. Use of your data on the Platform, the Services and through APIs

You acknowledge and agree that for you to enjoy the benefit of the Platform and the Services, we will via the Platform and the Services collect, process and store data about you and your business operations which may include personal information of your employees (“Personal Data”). You confirm that you have obtained the requisite consents from your employees to disclose such Personal Data to us.

We may collect, use, store or otherwise process Personal Data in accordance with our prevailing Privacy Policy.

10. Your usage of the Platform and the Services

You agree that:

the internet is a public communications network that cannot be controlled by us or any third-party provider, and interruptions or disruptions to the operation of any part of the internet may cause the supply of the Platform and the Services to be delayed or not to be delivered;
your access and use of the Platform and the Services may be interrupted at any time for any reason and without notice;
while we will attempt to provide reasonable notice of any planned maintenance or other event that is expected to disrupt or interrupt the Platform and the Services, we are not required to provide such notice;
we will have no liability for any delay, failure or error in any part of the Platform and the Services; and
your use of the Platform and the Services is entirely at your own risk, and we will have no liability to you or any other person arising from any loss or damage caused by any reliance upon the Platform and the Services.

We may modify, suspend, discontinue, terminate, cancel, substitute, replace, or limit access to any aspect or all of the Platform and the Services at any time with or without notice to you.

Subject to any applicable law, you acknowledge and agree that any data related to use of the Platform and the Services may cease to be available to you or any other person with access to that information at any time without notice from us.

11. Limitation of Liability

You shall indemnify and hold harmless HSBC and any HSBC’s affiliated entity that may be involved with the Platform or Services, and each of their respective directors, officers, employees and agents ("HSBC Indemnified Parties") in respect of any costs (including legal costs on a full indemnity basis), losses, liability, damages, claims and expenses incurred or suffered (whether in contract, or under any statute or any other cause of action) ("Losses") by HSBC Indemnified Parties arising directly or indirectly from or out of any use of the Platform, the Services or Platform Content by you, any of your employees or any person within your control (whether or not that person has an account on the Platform and the Services), except and to the extent such claim, cost, loss or liability arises as a direct result of our gross negligence or willful default.

Without limiting the aforesaid, you shall indemnify and hold harmless any of the HSBC Indemnified Parties from and against all Losses arising directly or indirectly out of or related to:

any third party claim from or arising out of a breach by you of any of your covenants, obligations, representations or warranties in these terms;
any claims relating to provision of legal, financial or other professional advice in connection with the use of the Platform and the Services; or
your or any of your employees’ access to or use of the Platform, the Services or Platform Content (including provision of inaccurate and/or untrue information whether upon registration or in connection with use of the Platform and the Services and including any misrepresentation of an individual’s authority to register on behalf of a business entity they hold themselves out to represent).

Non-Excludable Rights

Other than warranties, conditions, rights or guarantees which clearly cannot be excluded at law ('Non-Excludable Rights'), we disclaim all representations, warranties, rights, guarantees and conditions of any kind, whether express, implied or written, oral, contractual or statutory, including, without limitation, the implied warranties of merchantability, fitness for a particular purpose, title and non-infringement, and any warranties arising out of course of dealing or usage of trade.

Platform's status

You acknowledge and agree that we provide the Platform, the Services and Platform Content on an 'as is' and 'as available' basis, and we do not warrant that (a) the Platform, the Services or Platform Content are complete, suitable for your purpose or accurate or (b) you will enjoy uninterrupted use or error-free operation of the Platform or Platform Content.

Accuracy of Platform Content

We make no warranty (and hereby disclaim all express or implied warranties) regarding the quality, accuracy, timeliness, truthfulness, completeness or reliability of the Platform Content, the Platform or the Services itself or any of the components or the services offered through the Platform and the Services by us or by any third party operating through the Platform and the Services.

Our liability to you

Except for liability in relation to breach of any Non-Excludable Rights, we will not be liable in any way for any loss arising out of or in connection with these terms, the Platform, the Services or the Platform Content, or the delay or inability to use or lack of functionality of the Platform or the Services unless the loss is directly caused by our willful misconduct or gross negligence, in which event our liability shall not exceed the total fees paid or payable to us under these terms for the preceding 12 months.

For liability in relation to breach of any Non-Excludable Rights, to the extent permitted by applicable law, our liability is limited, at our option, to the cost of repairing or replacing any defect which may be discovered in the Platform and the Services.

We or any of our respective employees, officers, representatives or agents will not be liable to you for any:

special or incidental damage;
indirect or consequential loss;
loss of profits, sales, revenue, savings, reputation, goodwill or privacy;
corruption or loss of data, confidential or other information or software, including failures to transmit or receive data;
business interruption;
event or cause beyond our reasonable control including weather events and government action;

in each case howsoever arising, whether out of or in any way related to the use of or inability to use the Platform, the Services, the Platform Content or any API, or otherwise in connection with the Platform or Services, even if we have been advised of the possibility of such damages. You shall be responsible to do your utmost to inform us immediately of, and to minimize, any loss, claim or damage.

You have sole responsibility for adequate protection and back up of data and/or equipment and for undertaking reasonable and appropriate precautions to scan for computer viruses, malware or other destructive properties. We make no representation or warranty regarding the accuracy, functionality or performance of any third-party software that may be used in connection with the Platform and the Services.

The exclusions in this clause ‎11 apply even if any remedy fails to provide adequate compensation.

12. Marketing and Analytics

We may use information we collect from your use of the site (including name and contact details) for direct marketing purposes (e.g. to send marketing communications about news, offers or promotions in relation to the Platform, the Services or HSBC products and services) and we will do so in accordance with the terms of our Privacy Policy.

We may issue service-related announcements to you when necessary (e.g. when HSBC suspends a service due to system maintenance). You may not be able to opt out of these announcements which are service-related and not promotional in nature.

13. Suspension of your account

Without prejudice to any other rights we have under these terms, we have the right to temporarily suspend your and each and any of your employees’ access to the Platform and the Services if we reasonably determine that:

any applicable fees or sum remain unpaid after the due date;
there has been a breach of any of these terms; or
there is a potential or actual threat, risk or attack on the Platform, the Services or other event that may create a risk to the proper operation of the Platform, the Services, any API, or any business connected with the Platform and the Services or any user of the Platform and the Services.

We will make reasonable efforts to provide information to you about the reasons for any suspension and we will provide updates regarding resumption of your access to the Platform and the Services if we suspend your access.

We are not liable for any damage, liabilities, losses (including any loss of data or profits) or any other consequences that you may incur as a result of any suspension of your Platform account or any service you access on the Platform and the Services or any reliance you have on the Platform and the Services.

14. Termination of your account

We may terminate access to, or the availability of, the Platform and the Services, or any part of the Platform and the Services (including access to any one or more APIs or Platform Content) (a) at any time upon 30 days’ notice, without liability to you and without having to give any reason or (b) immediately if there is a breach by you or any of your employees of any of the terms relating to the Platform or Services, if you are insolvent or cease to exist, if you fail to pay any debt or amount owing when due to us or any party, if any court, arbitration or regulatory action or claim is commenced against you for any reason or if any circumstance or event were to exist or occur which in our opinion would materially impact our willingness to continue making available the Platform and/or Services to you and your employees or our assessment of the risk that we may be exposed to for so continuing to make available. For the avoidance of doubt, we do not give any representation or undertaking that the Platform or Services will be available for any term or minimum period.

Upon doing so, we may permanently delete your Platform account and any or all User Content associated with it, and we may also terminate the platform account of and access thereof by each and any employee. The notice may be provided by any means, including by means of the Platform and/or the Services.

You may also terminate the Services by giving us at least 30 days’ written notice.

Upon any termination of the Services or your Platform account the rights granted to you or your employees under these terms will automatically terminate and you and your employees may no longer exercise any of those rights, provided that nothing in these terms shall prevent us from bringing any action against you for any cause of action which may be accrued prior to the effective date of termination thereof. We shall not have any liability for any loss, damage, liability, consequence or claim whatsoever in connection with any termination of the Platform or Services including any disruption of business, planning or operations, loss of data, lack of replacement or comparable platform or services or employees’ unhappiness.

Subject to applicable law, we may, in our sole discretion, provide continued access to and use of the Platform and the Services after such termination. Except to the extent required by law, all payments and fees are non-refundable under all circumstances, regardless of whether these terms have been terminated.

We may also terminate immediately the Platform account of any individual who has ceased to be your employee.

The following clauses will survive termination of these terms: 4, 5, 6, 7, 8, 9, 10, 11, 13, 14, 18, 19. Termination of the Platform and Services shall not affect the validity of any existing contract relating to any insurance, banking or other products/services.

15. Assignment

You may not assign or novate any of your rights or obligations under these terms, whether by operation of law or otherwise, without our prior written consent. Any attempt by you or any person connected with you to assign or transfer these terms, without such consent, will be null and void.

To the extent permitted by applicable law, we have the right to transfer or assign the Platform, Services and/or these terms in their entirety to any party. Subject to the foregoing, these terms will bind and inure to the benefit of the parties, their successors and permitted assigns.

16. Communications between us

We may make, and you agree to receive, notices relating to the Platform and the Services from time to time. We will make commercially reasonable efforts to deliver such notices by email, by posting to your address, or through the Platform. We will communicate with you using the details you provide to us through your Platform account.

To help us improve our service and in the interest of security, we may monitor and/or record communications (whether over the internet, telephone, on the Platform or otherwise) between you and us. All recordings are our sole property.

17. Support services

You agree that we do not have any maintenance or support obligations with respect to the Platform and the Services, however, we will use reasonable commercial efforts to resolve problems with the Platform and the Services if we are notified that a problem is occurring. We shall have no liability or responsibility arising from or for any use, maintenance, support, lack of access or termination of any API, except if the API is a HSBC API and subject to these terms. Any problems, defects or issues with any other API are the sole responsibility of that API provider and subject to that provider’s terms and conditions.

18. Miscellaneous

Confidentiality

You hereby consent that we may disclose any information about you, your employees and/or your Platform account or banking or business relationship with us to: (a) HSBC Holdings plc or any entity that is a subsidiary, associate or affiliate (direct or indirect) of HSBC Holdings plc for any purpose in relation to the Platform or Services (including for due diligence) and to offer products/ services that may be of interest to you for marketing purposes, (b) your employees for any purpose in relation to the Platform or Services or (c) any contractor, sub-contractor, platform administrator, data processor, service provider, third party licensor, benefits, service or product provider or any third party (including their directors, employees, representatives, contractors and agents) that is assisting or engaged by HSBC or involved in the provision, administration, support or management of any aspect of the Platform or Services (including processing, information technology related, cloud solution, data analytics or customer query handling).

Entire Agreement

These terms and any other document or information referred to herein constitute the entire agreement between you and us specifically for your use of the Platform and Services and supersede all prior oral or written understandings or agreements between you and us specifically regarding the Platform and Services unless otherwise indicated by us.

Internet Banking and Mobile Banking app terms

Our prevailing HSBC Mobile Banking app Terms and Conditions and Terms and Conditions for HSBC Personal Internet Banking (or any terms that may replace the same or any terms that are applicable to online and/or mobile banking) will also be applicable to the Platform and Services and binding on you.

Language

The language of these terms is in English; any translation is for reference purpose only.

Severability

If certain provisions of these terms are held by a court or tribunal of competent jurisdiction to be invalid or unenforceable, those provisions will be enforced only to the furthest extent possible under applicable law and the remaining provisions of these terms will remain in full force and effect.

No Waiver

Our failure to enforce any right or provision of these terms will not be considered a waiver of such right or provision, which waiver will be effective only if in writing and signed by one of our duly authorized representatives.

Third Party Rights

These terms do not confer any rights to any third party under the Contracts (Rights of Third Parties) Act 2001 to enforce any of these terms.

Sanctions

You represent and confirm that you will not, directly or indirectly, use the Platform or Services:

to engage in any activities or business of or with any party, or in any country or territory, that, at the time of such use, is, or whose government is, the subject of Sanctions; or
in any other manner that would result in a violation of Sanctions by any party.

“Sanctions” mean any sanctions or similar instructions or orders administered or enforced by the US Department of the Treasury's Office of Foreign Assets Control, the US Department of State, the United Nations Security Council, the European Union, Her Majesty's Treasury, the Hong Kong Monetary Authority, the Monetary Authority of Singapore or any other applicable sanctions authorities.

Access

The Platform and Services are intended for those who access it from within Singapore and is not intended for access, distribution or use by any person in any other jurisdiction or where such access, distribution or use would be contrary to law or regulation.

Conflict

If there is any conflict between these terms and the other terms and policies on our site, these terms shall prevail.

19. Governing law and dispute resolution

The agreement between you and us for the use of the Platform and the Services set out in these terms are governed by and are to be interpreted in accordance with the laws of Singapore.

The courts in Singapore will have non-exclusive jurisdiction in respect of any dispute or matter which may arise in connection with these terms or your use of the Platform and Services.

20. Feedback

We welcome feedback, comments and suggestions for improvements to the Platform and the Services (“Feedback”). You hereby grant to HSBC a royalty-free, worldwide, transferable, sub-licensable, irrevocable, perpetual license, to use copy, modify, create derivative works based upon, distribute copies of and otherwise exploit the Feedback for any of our purposes and in any country.

If you have rights in the Feedback that cannot be licensed to us under applicable law (such as moral and other personal rights), then you hereby expressly waive your rights and agree not to assert those rights, to the extent permissible under applicable law.

You agree that you are freely giving Feedback, and that we do not have to use it, and that you will not be compensated in any way for any Feedback.

You represent and warrant that any rights you might have in Feedback is sufficient to grant us and other affected parties the rights described above, including, without limitation, intellectual property rights or rights of publicity or privacy.

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Platform Terms (End User)

1. Scope

These terms apply to the HSBC Thrive Benefits platform, including the website located at https://thrivebenefits.hsbc.com.sg as well as the apps, communications and other services that state that they are subject to these terms (together, the "Platform").The services provided by HSBC Bank (Singapore) Limited ("HSBC") in connection with the Platform shall be referred to as the "Services" under these terms, which include providing access to any platform or communication or administration services (relating to benefits, rewards and/or any other matters). The Platform and Services shall be provided by HSBC in accordance with its prevailing operational, technical, internal and/or other rules, procedures, guides and requirements (if any) ("Rules").

By using or continuing to use the Platform and the Services, you acknowledge and agree to be bound by these terms.

We live in a rapidly changing world. Sometimes this means we need to update our terms. These updates include amendments to:

Fees and charges.
Operational, technical, internal or other rules, procedures, guides and requirements
Our partners, benefits or partnership offers/benefits

We may amend or supplement our fees, charge and terms, if it is reasonably necessary to:

Reflect changes to our operational costs, business operations or systems and processes, or our arrangements with third parties;
give effect to:
1. applicable law, rule, regulation;
2. a change, recommendation, order, requirement, notice, direction, code, circular or guidance issued by any regulatory, supervisory, governmental, statutory authority, stock exchange, self-regulatory, or resolution body having jurisdiction over us or a court of competent jurisdiction;
Reflect changes to industry or market conditions or practice;
align with standards or expectations including in respect of:
1. banking and financial services practices;
2. environmental, social and governance practices;
3. consumer and investor protection practices;
4. cyber, digital, technology (including financial technology (FinTech)) practices e.g., those relating to crypto-assets, digital assets, virtual assets, asset tokenisation and artificial intelligence (including generative artificial intelligence and machine learning);
5. operational resilience and data management practices; or
6. taxation and transfer pricing practices; or
otherwise protect our legitimate interests.

To the extent reasonably practicable, we'll give you reasonable notice of any changes thereof before they take place.

We can choose how to give this notice to you. This may include:

contacting you directly through email
publishing the change on our website or app; and
using any other method we think is reasonably appropriate.

If you don't agree with a change, you can stop using the Services and Platform.

We reserve the right to charge you a fee directly for the use of the Platform and Services; we shall give you 30 days' notice of any such fee.

2. Eligibility and Registration

To access the Platform and Services, you need to satisfy HSBC’s prevailing eligibility criteria and create a Platform personal account in accordance with the Rules. You would have received your employer’s and our notice to create such an account to access the Platform and Services. If we provide to you the registration link in un-clickable text format, please ensure you switch off any device functionality that automatically converts URL-like text into a clickable link. You must inform us in writing immediately and stop accessing your Platform personal account if you would soon cease or have ceased to be an employee of the same employer based on which you were allowed to create the said Platform personal account. In such event, we have the right to terminate your access to the Platform and Services forthwith.

3. Representation

4. Undertaking

You undertake and agree on a continuing basis that you will at all times:

b) comply with the Rules and forward to HSBC any document that it may require from you in relation to the Platform and/or the Services;

c) provide us with accurate information about you when registering to use the Platform and the Services and update such information including the Platform account information in order to ensure that it remains accurate;

c) not disclose information available to you pursuant to the Platform including quotations of products and product terms (unless they are in the public domain) or your Platform account password to anyone and will notify us immediately of any unauthorized use of your Platform account, be responsible for all activities that occur under your Platform account whether you know about them or otherwise, and immediately notify us if you believe that your Platform account is no longer secure;

d) not sell, rent, lease, share or provide access to your Platform account to anyone else;

e) provide us with such information or data (including personal data) in relation to any service, benefit or product you have taken up with any third party (including insurers) for the purpose of having such information or data uploaded or reflected on the Platform; you further authorize us to approach any such third party to request for the information or data and authorize such third party to disclose such information or data to us upon our request without the need for the third party to refer to you; we are authorized to share this authorization from you with the third party; and

f) not access the Platform and the Services on behalf of anyone else or create a Platform account in a name other than your own.

5. Your activity on the Platform and under the Services

Any engagement between you and any other service, benefits or product provider (“Other Provider”) on the Platform and pursuant to the Services is independent of our involvement and will be subject to separate terms and conditions agreed between you and the Other Provider and you acknowledge that we will have no liability or responsibility to you in connection with the service, benefit or product of Other Provider or any breach or alleged breach, claim, loss or action arising from any agreement, contract or relationship between you and the Other Provider. Your sign-up with Other Provider will be subject to the fees, charges and costs of each Other Provider which will be a matter between you and each Other Provider. The Other Provider is not an agent nor representative of HSBC. Complimentary products/services can be withdrawn by us at any time. Neither HSBC or any of its subsidiaries or affiliates is soliciting, advising or recommending any action, makes any representations or warranties or accepts any liability, in relation to any service, benefit or product of any Other Provider.

6. The right to use the Platform and the Services

(A) Ownership of the Platform, the Services and any published content

The Platform contains and provides access to Material provided by third parties, including third party APIs (collectively, “Third Party Content”). Third Party Content is the copyrighted work of its owner, who expressly retains all right, title and interest in and to the Third Party Content, including, without limitation, all intellectual property rights therein and thereto. Third Party Content may also be subject to different or additional terms of use and privacy policies of such third parties. HSBC is not a party to the sales contract or user agreement between you and any third party provider. You acknowledge and agree that it is your responsibility to review the third party provider's terms before accepting them, or to contact the appropriate third party provider for further information regarding the terms applicable to Third Party Content. You acknowledge that acceptance of the third party provider's terms or use of their Third Party Content creates a binding agreement between you and the third party provider, and HSBC does not bear any liability or responsibility for the third party provider's content or actions. The third party provider of any Third Party Content is solely responsible for its content and warranties, and any claims that you may have related to the same. Although HSBC is not obligated to monitor access to or use of the Platform and the Services or to review or edit any Third Party Content, HSBC has the right to do so for the purpose of operating and publishing the Platform and the Services, to ensure compliance with these terms, to protect the health or safety of anyone that HSBC believes may be threatened, to protect HSBC's legal rights and remedies, to report a crime or offensive behavior, or to comply with applicable law. HSBC may elect to remove or disable access to any Third-Party Content, at any time and without notice.

(B) Your relationship with us and User Content

HSBC may restrict, modify, or limit access to and use of certain User Content or any or all the Platform and the Services, depending on where a user is located.

For the avoidance of doubt, any content generated by you (including any User Content) is not endorsed in any way by HSBC and does not represent us in any way.

Nothing in these terms creates any joint venture, relationship of partnership or agency between you and HSBC. You shall not, at any time, act or purport to act as HSBC's agent.

(C) Your right to use the Platform and Services

You shall use the Platform and Services in accordance with these terms solely and strictly for your own purposes. Other than the rights expressly granted to you under these terms, you shall not have any rights to any intellectual property rights of HSBC and/or its affiliates. All other rights not expressly granted to you under these terms are hereby reserved to HSBC (or its relevant licensors).

(D) Use of Platform Content

For the purposes of these terms, “Platform Content” means HSBC Content and Third Party Content.

HSBC reserves the right, but does not undertake the obligation, to manage and monitor any posting or uploading of, access to and use of the Platform, the Services, User Content and Platform Content (including for the purpose of complying with applicable law, regulations, the directions by courts and regulatory authorities), and to investigate and take appropriate legal action against any party that uses the Platform, the Services or Platform Content in violation of these terms or applicable law. HSBC reserves the right to accept, reject, withdraw, close, terminate or modify any Platform Content or User Content at any time at its discretion without notice, but assumes no liability based on/for its acceptance, rejection, withdrawal, closure, termination, modification or failure to modify or service any Platform Content or User Content.

(E) Platform usage

(F) Encouraging or enabling actions of others

You agree not to violate or attempt to violate the security of the Platform, the Services or HSBC's system or network security, including, without limitation, the following:

accessing data not intended for users of the Platform or the Services, or gaining unauthorized access to an account, server or any other computer system;
removing, disabling, circumventing, or modifying any technological measure we implement to protect users, third party providers or any of their associated intellectual property.

(G) Links to third party websites or other online resources

7. No reliance on Platform data

We do not warrant or represent that Platform Content will be complete, up to date, accurate, uninterrupted or error free or that the Service will not be suspended/interrupted by data transmission issues.

You further agree that:

you are solely liable and responsible for your activities, and the performance thereof and the compliance with relevant laws;
the Platform and the Services are prepared on a general basis and may not be appropriate or complete for your specific circumstances or requirements and you are therefore responsible for undertaking your own inquiries to determine the suitability of the Platform and the Services for those circumstances and requirements;
the Platform and the Services are not designed nor intended to guarantee your compliance with legal, regulatory or policy compliance obligations; and
the Platform and the Services have not been designed or customized to account for your situation including any specific activities, geographic location, relevant laws or regulations.

8. Use of your data on the Platform, the Services and through APIs

We may collect, use, store or otherwise process Personal Data in accordance with our Privacy Policy found here (https://thrivebenefits.hsbc.com.sg/terms#privacy-policy)

Specifically, you consent to share your name, email and employment dates as part of eligibility files for third parties including Headspace Inc.

9. Your usage of the Platform and the Services

You agree that:

the internet is a public communications network that cannot be controlled by us or any third-party provider, and interruptions or disruptions to the operation of any part of the internet may cause the supply of the Platform and the Services to be delayed or not to be delivered;
your access and use of the Platform and the Services may be interrupted at any time for any reason and without notice;
while we will attempt to provide reasonable notice of any planned maintenance or other event that is expected to disrupt or interrupt the Platform and the Services, we are not required to provide such notice;
we will have no liability for any delay, failure or error in any part of the Platform and the Services; and
your use of the Platform and the Services is entirely at your own risk, and we will have no liability to you or any other person arising from any loss or damage caused by any reliance upon the Platform and the Services.

We may modify, suspend, discontinue, terminate, cancel, substitute, replace, or limit access to any aspect or all of the Platform and the Services at any time with or without notice to you.

10. Limitation of Liability

You shall indemnify and hold harmless HSBC and any HSBC’s affiliated entity that may be involved with the Platform or Services, and each of their respective directors, officers, employees and agents ("HSBC Indemnified Parties") in respect of any costs (including legal costs on a full indemnity basis), losses, liability, damages, claims and expenses incurred or suffered (whether in contract, or under any statute or any other cause of action) ("Losses") by HSBC Indemnified Parties arising directly or indirectly from or out of any use of the Platform, the Services or Platform Content by you or any person within your control (whether or not that person has an account on the Platform and the Services), except and to the extent such claim, cost, loss or liability arises as a direct result of our gross negligence or willful default.

Without limiting the aforesaid, you shall indemnify and hold harmless any of the HSBC Indemnified Parties from and against all Losses arising directly or indirectly out of or related to:

any third party claim from or arising out of a breach by you of any of your covenants, obligations, representations or warranties in these terms;
any claims relating to provision of legal, financial or other professional advice in connection with the use of the Platform and the Services; or
your access to or use of the Platform, the Services or Platform Content (including provision of inaccurate and/or untrue information whether upon registration or in connection with use of the Platform and the Services and including any misrepresentation of an individual’s authority to register).

Non-Excludable Rights

Platform's status

Accuracy of Platform Content

Our liability to you

Except for liability in relation to breach of any Non-Excludable Rights, we will not be liable in any way for any loss arising out of or in connection with these terms, the Platform, the Services or the Platform Content, or the delay or inability to use or lack of functionality of the Platform or the Services unless the loss is directly caused by our willful misconduct or gross negligence in which event our liability shall not exceed the total fees paid or payable to us by your employer relating to the use of the Platform for the preceding 12 months.

We or any of our respective employees, officers, representatives or agents will not be liable to you for any:

special or incidental damage;
indirect or consequential loss;
loss of profits, sales, revenue, savings, reputation, goodwill or privacy;
corruption or loss of data, confidential or other information or software, including failures to transmit or receive data;
business interruption;
event beyond our reasonable control including weather events or government action;

The exclusions in this clause ‎10 apply even if any remedy fails to provide adequate compensation.

11. Marketing and Analytics

For the purposes of improving the Platform and the Services, we may track user activity such as hovers, clicks, and pseudo-anonymized recordings using a tool called Fullstory.

12. Suspension of your account

Without prejudice to any other rights we have under these terms, we have the right to temporarily suspend your access to the Platform and the Services if we reasonably determine that:

any applicable fees, charges or sums remain unpaid after the due date;
you are no longer an employee of the same employer based on which you were allowed to create the said Platform personal account;
there has been a breach of any of these terms; or
there is a potential or actual threat, risk or attack on the Platform, the Services or other event that may create a risk to the proper operation of the Platform, the Services, any API, or any business connected with the Platform and the Services or any user of the Platform and the Services.

13. Termination of your account

Upon doing so, we may permanently delete your Platform account and any or all User Content associated with it. The notice may be provided by any means, including by means of the Platform and/or the Services.

You may also terminate the Services by giving us at least 30 days’ written notice.

Upon any termination of the Services or your Platform account the rights granted to you under these terms will automatically terminate and you may no longer exercise any of those rights, provided that nothing in these terms shall prevent us from bringing any action against you for any cause of action which may be accrued prior to the effective date of termination thereof. We shall not have any liability for any loss, damage, liability, consequence or claim whatsoever in connection with any termination of the Platform or Services including any disruption of business, planning or operations, lack of replacement or comparable platform or services or loss of data.

We may also terminate immediately your Platform account should you change your employer.

The following clauses will survive termination of these terms: 4, 5, 6, 7, 8, 9, 10, 12, 13, 17, 18. Termination of the Platform and Services shall not affect the validity of any existing contract relating to any insurance, banking or other products/services

14. Assignment

To the extent permitted by applicable law, we have the right to transfer or assign the Platform, Service and/or these terms in their entirety to any party. Subject to the foregoing, these terms will bind and inure to the benefit of the parties, their successors and permitted assigns.

15. Communications between us

16. Support services

17. Miscellaneous

Confidentiality and customer information

You hereby consent that we may disclose any information about you and/or your Platform account or banking or business relationship with us to: (a) HSBC Holdings plc or any entity that is a subsidiary, associate or affiliate (direct or indirect) of HSBC Holdings plc for any purpose in relation to the Platform or Services (including for due diligence) and to offer products/ services that may be of interest to you for marketing purposes, (b) your employer for any purpose in relation to the Platform or Services, or (c) any contractor, sub-contractor, platform administrator, data processor, service provider, third party licensor, benefits or product provider or third party (including their directors, employees, representatives, contractors and agents) that is assisting or engaged by HSBC or involved in the provision, administration, support or management of any aspect of the Platform or Services (including processing, information technology related, cloud solution, data analytics or customer query handling).

Entire Agreement

Internet Banking and Mobile Banking app terms

Language

The language of these terms is in English; any translation is for reference purpose only.

Severability

No Waiver

Third Party Rights

These terms do not confer any rights to any third party under the Contracts (Rights of Third Parties) Act 2001 to enforce any of these terms.

Sanctions

You represent and confirm that you will not, directly or indirectly, use the Platform or Services:

to engage in any activities or business of or with any party, or in any country or territory, that, at the time of such use, is, or whose government is, the subject of Sanctions; or
in any other manner that would result in a violation of Sanctions by any party.

Access

Conflict

If there is any conflict between these terms and the other terms and policies on our site, these terms shall prevail.

18. Governing law and dispute resolution

The agreement between you and us for the use of the Platform and the Services set out in these terms are governed by and are to be interpreted in accordance with the laws of Singapore.

The courts in Singapore will have non-exclusive jurisdiction in respect of any dispute or matter which may arise in connection with these terms or your use of the Platform and Services.

19. Feedback

You agree that you are freely giving Feedback, and that we do not have to use it, and that you will not be compensated in any way for any Feedback.

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Privacy Policy

Your privacy

This Privacy Policy outlines how HSBC Bank (Singapore) Limited (“HSBC”), as data controller, use the personal information of individuals connected to a corporate customer of HSBC or a corporate with whom we have a business relationship (“Corporate”), in the context of the banking relationship between us and the Corporate.

Wherever we use the term "Connected Person", this means individual(s) connected to a Corporate and could include any guarantor, director, officer, employee, staff, agent, representative, nominee, shareholder, authorized signatory of the Corporate or any other persons with whom the Corporate has a relationship relevant to their relationship to HSBC.

This Privacy Policy is applicable to any Corporate or Connected Person and anyone who visits or uses our website.

This Privacy Policy explains what information we collect, how we will use that information, who we will share it with, the circumstances when we will share it and the steps we will take to make sure it stays private and secure. We may provide the Corporate or Connected Persons with separate or further information about how we collect and use information for particular products or services, in which case that information will also apply.

Corporates must direct any individuals whose personal data we may collect and process, including Connected Persons, to this Privacy Policy and make sure they are aware and have consented, prior to providing their Personal Data to us or our obtaining their Personal Data, that we are using their Personal Data as described.

Some of the links on this website may lead to HSBC or non-HSBC websites with their own privacy notices, which may be different to this notice, and you should read those notices carefully.

What data we collect

Any personal information allowing the identification of individuals, such as yourself or Connected Persons, is "Personal Data". We only collect Personal Data in line with relevant regulations and law. We may collect it from a range of sources. Some of it will come directly from Corporates, you or Connected Persons, or we may generate some of it or obtain it from our third party providers or publicly available sources.

Personal Data may include:

- personal details, e.g. name, previous names, gender, date and place of birth, photo ID, passport information, government-issued ID number, national ID card and nationality;

- contact details, e.g. address, email address, landline and mobile numbers;

- information we use to identify and authenticate individuals acting on behalf of Corporates. (e.g. their signature)
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Personal Data we collect or generate may include:

- information that you provide to us, such as when you fill out a contact or web form, or if you register to receive alerts or updates;

- information that we obtain or learn, such as information about the browser or device you use to access this site, how you use this site and the pages you visit, traffic and location data;

- information from feedback or surveys for research or similar purposes that you provided or responded to;

- information included in a Corporate’s documentation (e.g. a record of instructions);

- records about executed transactions (e.g. payment order), payment information including full beneficiary name, address and details of the underlying transaction;

- marketing and sales information;

- cookies and similar technologies we use to recognize individuals, remember them or their preferences and tailor the content we provide;

- customer due diligence and ongoing/renewal of due diligence, financial crime risk management rating, external intelligence reports, screening alerts;

- investigations data, e.g. due diligence checks, sanctions and anti-money laundering checks, external intelligence reports, content related to relevant exchanges of information between and among Corporates and Connected Persons, us and other organizations or individuals, including emails, voicemail, live chat;

- records of correspondence and other communications between us and Corporates and Connected Persons;

- information relating to complaints, including disputes/litigation (including legal strategy, document production, deposition and court transcripts);

- information that we need to support our regulatory obligations, e.g. transaction details, any suspicious and unusual activity and information about Connected Persons.
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Information we collect from other sources may include:

- information Corporates have asked us to collect for them, e.g. about transactions, accounts or holdings with other companies;

- information from third party providers, e.g. information that helps us to combat fraud;

- information relating to companies connected to Corporates such as affiliates, their activity and business.
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How we will use personal data

Purposes

Personal Data may be processed, used and stored by us and/or by third parties for the following purposes, which are carried out for our or a Corporate’s legitimate interests unless otherwise stated:

a. the provision of services and to approve, manage, administer or effect any transactions that a Corporate, Connected Person or you may request or authorize, to respond to any query, to provide you with information, products or services that you request from us or which we feel may interest you, to carry out our obligations from any contracts entered into or any business relationship between you and us, to allow you to participate in any interactive features of the site, to notify you about changes to the site, and to ensure site content is presented in the most effective manner for the device you're accessing it from;

b. allowing us to undertake data analytics to gather insights on the Corporate’s business;

c. the compliance with our legal obligations;

d. the meeting of Compliance Obligations;

e. the conducting of Financial Crime Risk Management Activity and other risk management activities;

f. the enforcement or defense of our rights or those of a member of the HSBC Group;

g. the pursuit of our legitimate business interest(s) such as to ensure compliance with our internal operational requirements or those of the HSBC Group (including credit and risk management, system or data base development, enhancement and planning, insurance, audit and administrative purposes);

h. the maintenance of HSBC or other members of the HSBC Group’s overall relationship with Corporates,

i. telling Corporates, Connected Persons or you about our products, or carrying out market research.

Automated Decision Making

We may use automated systems to help us assess credit, financial crime or fraud risk associated with the provision of products and services.
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Marketing and market research

We may use Personal Data for marketing purposes. We may send Connected Persons marketing messages in different ways (e.g. post, email, online and mobile banking or secure e-messages) with information about our products and services. We will ask for permission if required. If anyone whose Personal Data we hold asks us not to send them marketing materials, it may take us a short period of time to update our systems and records to reflect that request, during which time they may continue to receive marketing messages.

We may use Personal Data for market research and to identify trends. Market research agencies acting on our behalf may get in touch by post, telephone, email or other methods of communication to invite individuals to take part in research. Any responses provided whilst participating in market research will be reported back to us anonymously unless permission to share those details are given.
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You can set your marketing preferences
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You can contact us at any time if you don't want us to send direct marketing to you via certain channels, such as email, telephone calls, mobile messaging or post.

Tracking or recording what Connected Persons say or do

We (including through our third party service providers) may record and keep track of conversations anyone acting on behalf of the Corporates, including Connected Persons, have with us – including phone calls, face-to-face meetings, letters, emails, live chats, video chats and any other kinds of messaging. We use these recordings to check instructions, assess, analyze and improve our service, train our people, manage risk or to prevent and detect fraud and other crimes. We may capture telephone numbers that we are called from and information about the devices or software used.

Who we might share personal data with

We may share Personal Data for the above purposes with the following data recipients:

a. any HSBC Group companies, contractors, sub-contractors, agents, partners, vendors, product or service providers, or third parties who work for or provide services (including processing, cloud provider, information technology related or customer query handling) to us or other HSBC Group companies (including their employees, sub-contractors, third party service providers, partners, agents, directors and officers);

b. anyone acting on a Corporate’s behalf, payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks, clearing houses, clearing or settlement systems, market counterparties, and any companies in which Corporates have an interest in securities;

c. any party to a transaction acquiring interest in or assuming risk in or in connection with services;

d. other financial institutions, and/or credit reference agencies for the purposes of obtaining or providing credit reference and/or checks;

e. any companies where required in connection with potential or actual corporate restructuring, merger, acquisition or takeover, including any transfer or potential transfer of any of our rights or duties under our agreement with a Corporate;

f. law enforcement, government, courts, dispute resolution bodies, Tax Authorities, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;

g. other companies who do marketing or market research for us;

h. other parties involved in any disputed transactions;

i. fraud prevention agencies, who’ll also use it to detect and prevent fraud and other financial crime and to verify identity;

j. anyone who provides instructions or operates any of a Corporate’s accounts on their behalf;

k. anybody else that we’ve been instructed to share Personal Data with by a Corporate or anybody else who provides instructions or operates any of Corporate’s accounts on their behalf;

l. the Corporate or any Connected Person;

m. any member of HSBC Group in connection with or arising from any reporting obligations to any Authorities of suspicious transactions by or involving a Corporate or Connected Persons or other third connected parties.

Transferring personal data overseas

Personal Data may be transferred to and stored in locations outside Singapore, including in countries that may not have the same level of protection. When we do this, we’ll ensure it has an appropriate level of protection and that the transfer is lawful. We may need to transfer Personal Data in this way to perform our contract with a Corporate, to fulfil a legal obligation, to protect the public interest and/or for legitimate business interests.

In some countries the law might compel us to share certain information, e.g. with Tax Authorities. Even in these cases, we will only share information with people who have the right to see it.

More details of the protection given to Personal Data when it is transferred outside Singapore can be obtained by contacting us.

Sharing Aggregated or Anonymized information

We may share aggregated or anonymized information outside of the HSBC Group with partners such as research groups, universities or advertisers. For example, we may share such information publicly to show trends about the general use of our services. However, it will not be possible for individuals to be individually identified from this information.

IP addresses

We may collect information about your computer (or mobile device), including where available your IP address, operating system and browser type, for system administration or for our own commercial purposes. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

How long we will keep personal data

We keep Personal Data in line with our data retention policy. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes such as account management and dealing with any disputes or concerns that may arise. For example, we’ll normally keep core banking data for a period of seven years from the end of our relationship with a Corporate. We may need to retain Personal Data for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes, e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators, etc. If we don’t need to retain Personal Data information for this period of time, we may destroy, delete or anonymize it more promptly.

Rights of Individuals

Individuals whose Personal Data we process, including Connected Persons, have a number of rights in relation to their Personal Data. These rights include:

Request access to their data, and request for information relating to our use or disclosure of their data. We may be unable to provide them with access to some data - if so, we'll explain why not unless it's not lawful to tell them.
Correct or update the data that we hold about them..
Withdraw consent to use of their data and give feedback. If they withdraw consent, we may be unable to continue providing products or services to them. This may result in the end of some or all of our contractual relationships with them.

You can contact us

HSBC Bank (Singapore) Limited

sghdpo@hsbc.com.sg

Consequences of processing

If we, or a fraud prevention agency, determine that a fraud or money laundering risk is posed, we may refuse to provide the services and credit requested or we may stop providing existing products and services to a Corporate or Connected Persons. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services.

What we expect from customers or corporates

Corporates should ensure that any Personal Data they provide to us is accurate and up-to-date, and direct relevant individuals to this Privacy Policy and make sure they have consented to the disclosure to us and understand how we use their information as described in it prior to providing their Personal Data to us, or our obtaining their Personal Data from other sources. They should also draw their attention to the relevant section on their rights.

How we keep personal data secure

We use internal technical and organizational measures to keep Personal Data safe and secure which may include encryption, and other forms of security measures. We require our staff and any third parties who carry out any work on our behalf to comply with appropriate compliance standards including obligations to protect any information and applying appropriate measures for the use and transfer of information.

Definitions

“Authorities" includes any judicial, administrative, public or regulatory body, any government, any Tax Authority, securities or futures exchange, court, central bank or law enforcement body, or any of their agents, with jurisdiction over any part of the HSBC Group.

"Compliance Obligations" means obligations of the HSBC Group to comply with: (a) Laws, or international guidance and internal policies or procedures, (b) any demand and/or requests from Authorities or reporting, regulatory trade reporting, disclosure or other obligations under Laws, and (c) Laws requiring HSBC to verify the identity of our customers, any Corporate and/or Connected Persons.

"Financial Crime Risk Management Activity" means any action that HSBC, and members of the HSBC Group, are required, and may take as they consider appropriate in their sole and absolute discretion, to meet Compliance Obligations in connection with the direction, investigation and prevention of Financial Crime, including but not limited to: (a) screening, intercepting and investigating any instruction, communication, drawdown request, application for services, or any payment sent to or by a Corporate or on their behalf, (b) investigating the source of or intended recipient of funds, (c) combining Personal Data with other related information in the possession of the HSBC Group, and/or (d) making further enquiries as to the status of a person or entity, whether they are subject to a sanction regime, or confirming a Corporate or Connected Person’s identity and status.

"Financial Crime" means money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, and/or violations, or acts or attempts to circumvent or violate any Laws relating to these matters.

“HSBC Group” means HSBC Holdings plc and its subsidiaries, affiliates and associates (direct and indirect) from time to time.

"Laws" means any applicable local or foreign statute, law, regulation, ordinance, rule, judgement, decree, voluntary code, directive, sanctions regime, court order, agreement between any member of the HSBC Group and an Authority, or agreement or treaty between Authorities and applicable to HSBC or a member of the HSBC Group.

"services" includes, without limitation providing Corporate and Connected Person access to any employer or employee platform or communication or administration services (relating to benefits, rewards and/or any other matters).

"Tax Authorities" means domestic or foreign tax, revenue, fiscal or monetary authorities.

If you're an HSBC customer or a Connected Person or if you have a relationship with us, the following Privacy Policy will also be applicable to you https://www.hsbc.com.sg/privacy-statement/.
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Content Policy

We, HSBC Bank (Singapore) Ltd, have put in place this Content Policy to set out the details about what we would consider as sensitive or unacceptable content for our Thrive Benefits digital platform (“Platform”).

Our policy covers two general areas:

Prohibited: Content you cannot post on the Platform

Restricted: Content you may post, but with limitations

You must follow these guidelines when contributing content to the Platform.

Reporting non-compliance

If you have a concern about any content or activity on the Platform, including the behavior of another user or account, you can report this directly to us as per the contact details on the Platform.

Please note that if we determine that a report is malicious or vexatious we may elect to take action against the person making the report.

Any reported content will be reviewed by our content reviewers. After considering whether the post violates our content policy, our content reviewers will either remove the post or allow it to remain online. Our review will be conducted at our discretion in line with our prevailing policies and procedures and our findings shall be conclusive between you and all users of the Platform.

Prohibited Content

Copyright and Trademark Infringement

Each user should respect others’ work and not violate their intellectual property (IP) rights. This includes copyrights, patents, trademarks, trade secrets, or other proprietary rights. Unless a user has received authorization to use someone else’s work, they should not use it.

We may respond to complaints of alleged infringement by acting as a facilitator (at our sole discretion and without any liability) between the IP rights holder and the alleged infringer. For the avoidance of doubt, our actions in conjunction with our role as facilitator are not indicators as to the legality of any infringement case and solely facilitative of notifications between the affected parties. In appropriate circumstances and at our discretion, we may disable and/or terminate accounts of users who may infringe or repeatedly infringe the copyrights or other intellectual property rights of us or others.

Commercially or Competitively Sensitive Information

You must not distribute, share or disclose any information which could be considered commercially or competitively sensitive (such as information about pricing), whether it is your own or a third party’s, to any person, including other users of the platform, whether privately or publicly on or in connection with the Platform. This includes any information where such disclosure may give rise to a breach of applicable laws, regulations, rules, regulatory guidance or notices, codes of conduct or orders (“Laws”), including information that could compromise fair competition amongst any parties.

Commercially sensitive information includes any information of a commercially sensitive nature relating to a user or a third party, its intellectual property rights or its business or which a party has indicated to the possessor that, if disclosed, could prejudice a person’s commercial interests or cause significant commercial disadvantage or material financial loss. Examples of such information includes trade secrets, know-how, pricing structures, profit margins or market strategies.

Defamation

Defamatory statements are not tolerated. Defamation is any false statement that damages the reputation of an individual or an organization by exposing them to hate, ridicule or contempt, causes them to be shunned, and discredits their business or profession.

If you believe you have been the victim of a post on the Platform that constitutes defamation, let us know directly as per our contact details on the Platform.

Inappropriate Content

As a community that acts professionally and respectfully, we don’t allow any content that is obscene (including nudity or sexual exploitation), threatening, violent (including graphic content and content inciting, publicizing and/or promoting crimes, violence and/or hate), harmful (to others and including self-harm), hateful, discriminatory, cruel and insensitive, bullying and harassing, or illegal. All such content will be removed immediately when discovered.

Examples of inappropriate content: profane language, discrimination, nudity, sexual exploitation, hate speech, bullying or intimidation of an individual or group, graphic, adult, gambling-related content, promotion of illegal activities such as tax evasion and money laundering, extortion or blackmail, tax avoidance or tax planning not within the spirit of the applicable tax law.

Spam

We will remove all instances of spam. These behaviors are what we’d consider spam:

Posting content with no substance but to primarily redirect traffic to an external site, product, or service
Posting duplicate content, whether from a single account or across multiple accounts
Posting content by automated means in large quantities

This list is not exhaustive and content that has been flagged will be reviewed based on context.

Solicitation

The Platform may assess various user behaviors including traffic flow. We do not condone behavior that would artificially inflate rankings, skew the system and negatively impact other users’ experience. Examples of such behavior might include:

Asking for or paying for services to increase your number of interactions on the Platform
Self-promotion of your own content to artificially inflate your post’s ranking

Personal and Confidential Information

Please respect others’ privacy on our platform. Don’t post private or confidential content or information about other people without their explicit, written consent.

Don’t create false identities, misrepresent your own identity, or create an account for anyone other than yourself (except if you are authorized by an organization to do so on their behalf).

We also want the Platform users to trust that information about them will be respected and handled with appropriate care. As such, no one should misuse any such information, nor collect it for unauthorized or unclear purposes or without appropriate security measures.

Examples of user information that should be handled with care: full name; email address; mailing address; phone number; national identity, passport information such as your passport number, tax ID, health and health-care information, or driver's license number; birth date or mother's maiden name in addition to any of the above information; financial status; political affiliation and opinions; sexual orientation; race or ethnicity; religious or philosophical beliefs; trade union membership; genetic and biometric data; a natural person’s sex life or sexual orientation.

Regulated Goods

For safety purposes and due to compliance with common legal restrictions, we do not allow the Platform to be used as a platform for individuals, businesses and organizations to trade, gift, transfer, acquire, exchange or sell regulated goods such as non-medical, medical and/or pharmaceutical drugs, firearms (including any part or parts of firearms and ammunition), human organs and/or blood, alcohol and tobacco. This list of examples is not exhaustive and content that has been flagged will be reviewed based on context.

Deceptive content

Deceptive practices that take advantage of the Platform community are not allowed. These are examples which we’d consider deceptive content:

Posting content where title, thumbnails, description, or tags are used to lead users into believing the content is something it is not.
Posting content offering “get rich quick” schemes, or pyramid schemes, etc.
Posting content that sends audiences to sites that spread viruses, spyware, malware or any other malicious software or try to gather personal information illegally, or other sites that have a negative impact.

Financial services and activities requiring registration or license from regulators or authorities

Financial services and activities requiring registration or license from regulators or authorities in Singapore are not allowed (our parent company, subsidiaries, affiliates, associates or authorized providers are excluded). Regulators and authorities include but not limited to The Monetary Authority of Singapore (MAS).

Restricted Content

Sensitive/ Regulated Content

The following content categories may be reviewed by our Content team on a case by case basis.

Financial advice and professional services advice

Publishers of such content must comply with all Laws, for example, to include specific disclosures as required by law. You must comply with the Laws and we have no responsibility for your compliance (or failure to comply) with the same.

For the avoidance of doubt, tax avoidance or tax planning content which promotes a tax advantage that, although within the letter of the applicable tax law, is not within the spirit of the law, is classified as inappropriate content and prohibited.

Misinformation and false news

We understand that in certain instances the boundaries between false news and parody, caricature or opinion may be blurry. As a result, such content may be reviewed by our Content team on a case by case basis.

Further, the following content categories are beyond the Platform’s objectives.

Political content
Religious content

Advertisements and Promotions

As the Platform aims to host content that is educational and informative, hardline advertisements and promotions are not appropriate content. However, we understand that in some cases the line between hard or aggressive selling techniques and useful content marketing might be blurry, as such we will rely on the platform’s community to report content that is neither useful nor fits the purpose or aims of the Platform.

Paid or Sponsored Content

If content has been paid for or is sponsored by a third party (e.g., a third party has provided any manner of financial or other benefit in exchange for all or part of a post), we require that you prominently show an adequate disclosure in the post that identifies who paid for or sponsored the post. A post that is considered to be “paid for” or “sponsored” includes any under which a third party provides any form of compensation (whether in cash or in kind), free goods and/or services, or anything of value in connection with the topic of a post or the posting of a post itself.
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Content policy for “Offers”

Prohibited Content:

Irrelevant services

Published services should be relevant to the business that the author is posting on behalf of and help users better understand the business. Content that's irrelevant to the business or has no clear association with the business isn't allowed. Content that does not meet this standard will be removed.

Resell services and products

The offers/services on the Platform are intended to let users better understand the providers’ businesses. The platform may not be used to resell services or physical goods unless the company is an authorized reseller/distributor of the mentioned services or products.

Money-making Opportunities

The Platform does not accept content for pyramid or get-rich-quick schemes that imply or promise guaranteed employment or earnings, or otherwise provide misleading information to potential participants.

Content that facilitates or promotes gambling, contest, sweepstakes, lotteries, raffles, commercial co-venture and games of chances is also prohibited.

Fraud and scams

You must not promote products, services, schemes or offers using deceptive or misleading business practices, which includes schemes to defraud individuals for assets/information.

Examples include but are not limited to:

Using the title, thumbnails, description, or tags to trick users into believing the content is something it is not.
Phishing content
Content that promotes pyramid schemes

Credit repair services

Services that promote products, services or methods of removing items from a user’s credit report that are accurate and timely, but negative, is not permitted.

Financial services and activities requiring registration or license from regulators or authorities

Financial service activities requiring registration or license from regulators or authorities in Singapore including distributing/selling financial products are not allowed (our parent company, subsidiaries, affiliates, associates or authorized providers are excluded). Regulators and authorities include but not limited to MAS.

Restricted:

Financial and other professional services

Restriction are based on specific products or services being mentioned/promoted. We advise service providers to comply with the Laws and local and industry regulations – for example, to include specific disclosures as required by local law.

Publisher must ensure that all pricing and price claims (including services that claims to offer items for “free”) are: (a) not deceptive or misleading; (b) properly substantiated and (c) in compliance with the Laws.

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