Privacy Policy

Last Updated: 1 April 2026
Company: WellSpend Limited

1. Introduction

WellSpend Limited (“WellSpend”, “we”, “our”, “us”) respects your privacy and is committed to protecting your Personal Data. This Privacy Policy explains how we collect, use, process, store, and share your Personal Data when you use our mobile application, website, and services (the “App”).

By creating an account or using the App, you acknowledge that we may collect, use, and process your Personal Data as described in this Privacy Policy, subject to additional rights and disclosures in the relevant country-specific supplemental privacy notices.

If you do not agree to this Policy, you must stop using the App immediately.

2. Information We Collect

We collect Personal Data necessary to operate our cashback and rewards services, verify transactions, prevent fraud, and process payouts.

2.1 Identity Data

• Mobile phone number
• Email address

We do not collect national identification numbers (e.g., HKID, NRIC, MyNumber) unless legally required for tax or anti-money-laundering, verification, or compliance purposes.

If identity verification is required for fraud prevention, compliance, or payout purposes, we may request additional documents such as a government-issued ID, proof of bank account ownership, or other verification information. Such data is processed strictly for verification, fraud prevention, compliance, and payout security purposes.

2.2 Financial Data

Used solely for processing payouts:

• Bank account number
• Bank name
• Account holder name
• FPS identifier (if applicable)

We do not collect or store credit card numbers.

2.3 Transaction Data

Provided to us by Merchant Partners, affiliate networks, or generated through your use of the App:

• Order ID
• Purchase amount
• Time and date of purchase
• Merchant name
• Cashback eligibility, reward status, and commission data
• Refund/return or cancellation status
• Purchase currency, wallet currency, or reward display currency where applicable
• Validation, confirmation, clawback, reversal, or payout-related status data

This data is essential for attributing and validating Cashback and other Rewards.

2.4 Technical & Device Data

Collected automatically:

• IP address
• Device model, OS, app version
• Browser settings, language, time zone
• Unique device identifiers
• Advertising identifiers (IDFA, GAID)

2.5 Attribution & Tracking Data

Required to determine whether a purchase is attributable to your account:

• Click timestamps
• Referral and affiliate identifiers
• Cookies and pixel identifiers
• Tracking tags and URL parameters
• In-app browser, webview, redirect, or click-through tracking metadata where applicable

This information allows us to assign commissions and calculate Cashback.

You may disable cookies or reset advertising identifiers in your device settings, though this may affect your ability to earn Cashback.

2.6 Fraud Prevention and Security Data

We may collect, generate, or infer data for fraud prevention, abuse prevention, account security, and risk monitoring purposes, including:

• device-to-account associations
• suspicious login or activity patterns
• unusual transaction timing or validation patterns
• duplicate, linked, or anomalous account indicators
• verification attempts and fraud review records

This data helps us protect users, Merchants, and the integrity of the App.

3. How We Use Your Personal Data

We process your Personal Data for the following purposes:

3.1 Service Provision

• Tracking clicks to Merchant Partners
• Validating and attributing Cashback
• Displaying your Cashback status (“Pending”, “Confirmed”, etc.)

Cashback information (including “Pending” and “Confirmed” status) is processed solely as part of a promotional rewards programme and does not represent stored value, electronic money, or a payment instrument.

3.2 Payout Processing

• Verifying payout requests
• Conducting identity verification (KYC) where required
• Transferring funds to your designated payout method
• Maintaining payout, wallet currency, and reconciliation records

3.3 Fraud Prevention

• Detecting duplicate or fake accounts
• Identifying unusual transactions
• Preventing abuse of referral systems

3.4 Communication

• Transactional updates
• Cashback notifications
• Security alerts and account notices
• Customer support communications
• Marketing communications (only with opt-in consent where required)

3.5 Service Improvement

• Debugging and troubleshooting
• Analytics and performance analysis
• Optimizing partner offers

3.6 Legal Compliance

• AML/CTF requirements
• Accounting and audit obligations
• Compliance, dispute handling, enforcement, and legal response obligations

4. Legal Basis for Processing Personal Data

Depending on your jurisdiction, we rely on one or more of the following legal bases:

• Consent (e.g., marketing, cross-border transfers where required)
• Contractual necessity (to provide the cashback service, operate account features, and process payouts)
• Legitimate interests (fraud prevention, analytics, security, and improving the App)
• Compliance with legal obligations

5. Data Sharing & Disclosure

We do not sell your Personal Data.

We may share your data with the following parties:

5.1 Merchant Partners & Affiliate Networks

For transaction validation and commission processing:

• Order ID
• Purchase date/time
• Purchase amount
• Tracking metadata

We do not share your phone number, email address, or bank account with merchants.

5.2 Service Providers

Including but not limited to:

• Cloud hosting providers (e.g., AWS Singapore)
• Analytics providers
• Fraud detection providers
• Payout processors
• Customer support tools
• Messaging, email, SMS, push notification, identity verification, or operational service providers

They are contractually obligated to protect your data.

5.3 Legal Authorities

Where required by:

• court order
• regulatory request
• applicable law

5.4 Business Transfers

In case of merger, acquisition, restructuring, or asset sale, your Personal Data may be transferred to the successor entity.

6. International Data Transfers

Your Personal Data may be transferred to or stored in jurisdictions outside your country of residence, including Hong Kong and Singapore.

These jurisdictions may have different data protection laws from your home country. We will take steps required by applicable law for such transfers, including obtaining consent where legally required or relying on other lawful transfer mechanisms.

7. Data Retention

We retain Personal Data only as long as necessary for the purposes stated in this Policy.

• Active accounts: retained while your account remains active.
• Financial and transaction records: retained for 7 years to comply with accounting, tax, AML, audit, reconciliation, and dispute-handling requirements.
• Deleted or closed accounts: we may delete, anonymize, or de-identify Personal Data where appropriate, but may retain certain records where required for legal, compliance, accounting, fraud prevention, security, audit, reconciliation, or dispute-resolution purposes.

8. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access your Personal Data
• Correct inaccurate information
• Request deletion
• Withdraw consent
• Object to processing
• Request data portability
• File a complaint with local regulators

To exercise your rights, please contact us using the details below. We may need to verify your identity before processing your request, and the scope and timing of our response may depend on your jurisdiction and the nature of your request.

Contact: privacy@wellspend.io

9. Security Measures

We implement reasonable safeguards, including:

• Encryption
• Access controls
• Secure storage
• Monitoring for suspicious activity

No system is completely secure; we cannot guarantee absolute protection.

10. Children

Our services are not intended for users under 18, or below the legal age of majority in your jurisdiction where that age is higher. We may suspend or disable accounts belonging to users who do not meet the applicable eligibility requirements.

11. Changes to This Policy

We may update this Policy from time to time. Material changes will be notified in-app or via email where appropriate. Continued use of the App after such updates signifies acceptance of the revised Policy.

12. Contact Us

📧 privacy@wellspend.io

Country-Specific Supplemental Privacy Notices

The main Privacy Policy above applies generally to all users. The following country-specific supplemental notices provide additional disclosures, rights, or legal information that apply only where required by the laws of the relevant jurisdiction.