Your learning record is yours.

1. Personal data

6.1 We handle personal data in accordance with the Personal Data Protection Act 2012 and our Privacy Notice, which sets out what we collect, why, who we share it with and how long we keep it. The essentials, subject to our Privacy Notice:

1. (a) What and why. Account details, age and gender, Learning Record (including Discovery search history), saved bonds, adviser-request data, device and usage data, and support correspondence, to provide and secure the Service, keep your record, send Adviser Briefs you request, comply with law, and improve lessons. Marketing only if you opt in.
2. (b) Who. Service providers acting on our instructions (such as hosting, analytics and email providers); recipients only as you direct under clause 5; sponsors only under clause 8; regulators and courts where required. Where data is processed outside Singapore we ensure comparable protection as the PDPA requires.
3. (c) Your rights. You may access your data and learn how it was used in the past year, correct it, withdraw consent on reasonable notice (we will tell you the consequences), export your Learning Record, and delete your account. Withdrawal does not reach data already delivered to a recipient or sponsor, and does not by itself oblige us to delete data we must keep.
4. (d) Retention and deletion. We keep personal data only as long as needed for its purpose or as law requires, then delete or anonymise it. Account deletion is completed within 30 days, except data retained for legal claims or compliance, which we isolate.
5. (e) Breaches. We will notify the Personal Data Protection Commission and, where required, you, within the time the law requires.
6. (f) Contact. Data Protection Officer: dpo@bondguru.app, 190 Middle Road, #14-05 Fortune Centre, Singapore 188979.

Terms of Use v0.5, clause 6.1

2. Your Learning Record

5.1Your record. We keep a record of your learning progress, navigation activity and related data points, which we use to operate the Service and improve our lesson plans; your check attempts, answers and results; the lesson version and language; timestamps; notes you save; and your activity in Discovery, the bond search function in the app, including the search terms and filters you use and the bonds you open (together, your “Learning Record”). Discovery is a search tool only: results are ordered by the criteria you choose, and nothing in Discovery is a recommendation of any bond. The Learning Record is personal data about you. You can view it, export it and ask us to delete it (clause 6). We do not derive any score, rating, risk profile or suitability conclusion from it. We may use it in de-identified, aggregated form to improve lessons and to report usage statistics.

Terms of Use v0.5, clause 5.1

3. Sharing with an adviser

5.2Sharing with an adviser, on your instruction only. Your contact details and Learning Record will only be shared with an adviser or a financial institution when you choose to send a summary of them, except as otherwise expressly provided in these Terms or in our Privacy Notice (an “Adviser Brief”) to an adviser or financial institution selected by you. You decide the contents from a fixed menu; nothing is included unless you select it, and it never includes calculator inputs or any derived score. You see the complete Adviser Brief and give a separate, specific consent before it is sent, and we keep a timestamped record of that consent. The Sharing Terms, shown to you before you send, set out the details.

5.3User-directed sharing. Unless a Partner Institution is named in the app under clause 5.4:

1. (a) you enter the recipient’s details yourself, and BondGuru does not list, suggest, rank, select, recommend or verify any adviser or firm;
2. (b) BondGuru does not act for the recipient, receives no payment or other benefit from the recipient for the share, gives no advice, and never receives or handles your money or property;
3. (c) BondGuru delivers the Adviser Brief as you instruct, in the same way an email service delivers a message, and is not responsible for what the recipient does or whether it responds; and
4. (d) once sent, an Adviser Brief cannot be recalled through the app. The recipient is a separate organisation under the Personal Data Protection Act 2012 and handles it under its own obligations. We recommend that you deal only with institutions regulated by MAS.

5.4Partner Institutions and introducer disclosure. Where the app names a financial institution as a “Partner Institution”, BondGuru carries out introducing activities for it under a written introducer agreement, in reliance on the exemption in regulation 31 of the Financial Advisers Regulations. In that case, and only in that case: BondGuru and its staff do not and may not give advice or recommendations on any investment product, or arrange any contract of insurance in respect of life policies; BondGuru never receives or deals with your money or property; BondGuru does not assess your suitability for any Partner Institution or its products; where more than one Partner Institution offers the type of service you ask for, we will tell you about each of them and introduce you only to those you consent to; and before any of your particulars are passed on, you will be shown the Partner Institution’s client acknowledgment form, and we will provide no information beyond it. Depending on our arrangement with each Partner Institution, we may or may not be remunerated by it for introducing activities. The app states which applies for each Partner Institution and, if we are remunerated, we will tell you the amount if you ask. Any payment we receive helps to fund the free Service. A request to a Partner Institution is not an application for any product. Clauses 5.3(c) and 5.3(d) apply equally to Partner Institutions.

Terms of Use v0.5, clause 5.2, clause 5.3, clause 5.4

4. Sharing your watchlist and saved portfolio

5.5Sharing your watchlist and saved portfolio. You may share your watchlist and saved portfolio with a person or financial institution of your choice using the share function in the app, and the Sharing Terms apply. A shared copy is a dated snapshot created by you, not a recommendation by BondGuru or anyone else. It includes licensed Data as clause 4.2 allows, and cannot be recalled. You are responsible for who you share with and what they do with it. You must not use sharing to promote, recommend or solicit any investment, to give advice to others, or in any public medium. We may disable sharing for any account that does so.

Terms of Use v0.5, clause 5.5

5. Sponsored access

If a financial institution, employer or other organisation (“Sponsor”) provides your access, its arrangement with us governs what it pays for and which content versions it has approved; these Terms still govern your use.

A Sponsor may receive information regarding the activation of sponsored accounts and aggregated, de-identified usage statistics. We may also share your lesson completions and check results with the Sponsor where you have been notified of the purposes and extent of such disclosure and the disclosure is permitted under applicable data protection laws, including where any required consent has been obtained.

We will inform you of the categories of personal data that may be disclosed to the Sponsor before you activate your sponsored access.

Unless otherwise expressly notified to you and permitted under applicable law, the Sponsor will not receive your notes, questions, Discovery searches, saved bonds or calculator inputs.

The Sponsor is responsible for its own advice, products and data handling; we are responsible for ours. When sponsorship ends you may continue on the public Service and your Learning Record remains yours.

Terms of Use v0.5, clause 8

6. Your account, deletion and export

7.1 You may use the Service anonymously; when you sign in, your prior activity is linked to your account. Keep your credentials secure; you are responsible for activity under your account. One account per person.

12.1 You may stop using the Service and delete your account at any time.

12.4 Upon termination, your licence to use the Service shall cease immediately. Where we terminate your access or discontinue the Service, we will, where reasonably practicable, provide you with an opportunity to export your Learning Record for a period of thirty (30) days before or after the effective date of termination or discontinuation, as applicable. We may restrict or deny such access where termination arises from a breach of clauses 3 or 4, or where required by applicable law or for security reasons.

Terms of Use v0.5, clause 7.1, clause 12.1, clause 12.4

7. Age

1.2 By using the Service you accept these Terms. You must be at least 18. If you do not accept them, please do not use the Service.

6.2 The Service is not for persons under 18 and we do not knowingly collect their data.

Terms of Use v0.5, clause 1.2, clause 6.2

8. This website

The Terms of Use cover the BondGuru app and the website. These points apply only to your visit to bondguru.app.

• No cookies. The site sets no cookies and uses no analytics or advertising.
• Fonts are served from bondguru.app, so visiting the site does not contact a font provider.
• Lesson videos are embedded from YouTube in privacy-enhanced mode and load only when you press play. YouTube's own privacy policy applies from that point.
• Forms. If you join the launch list or send an institutional enquiry, we receive the details you enter by email, together with the time and your IP address for spam prevention, and send you an acknowledgement. We use them only to reply and, if you joined the launch list, to send the launch email.
• Server logs. Our hosting provider keeps standard technical logs, such as IP address and pages requested, to deliver and secure the site.

9. Contact

Data Protection Officer: dpo@bondguru.app, 190 Middle Road, #14-05 Fortune Centre, Singapore 188979.

Terms of Use v0.5, clause 6.1(f)