Privacy Policy

Effective Date: 1st September 2020
Revised as of: 1st September 2020

If you access the Gorilla Services in any way, or are a registered Account Holder of the Gorilla Services, you will be deemed to use and be a user of the Gorilla Services. Gorilla will collect the Personal Data of all users of the Gorilla Services, but will do so in compliance with the PDPA and GDPR. This policy highlights the key information pertaining to what we collect when you use Gorilla Services. It also highlights the key information about how we store, use, share, transfer, and delete that information. It further includes information about how you may manage that information. For full details of how your Personal Data will be collected and processed by Gorilla from the Gorilla Services, please refer to the PDPA or the GDPR, if you are a resident of the EU.

In general, the Personal Data which is collected from you shall be processed in compliance with the PDPA and the GDPR. We share your data with our Data Intermediaries or other third-party service providers used by us to the extent necessary for them to provide their services. We use these Data Intermediaries or other third-party services solely to process or store your information for the purposes described in this policy.

Unless the context otherwise requires, the definitions and interpretative provisions in Schedule 1 apply throughout this Privacy Policy.
    1. When you use the Gorilla Services or register an Account with Gorilla, and as you continue to use the Gorilla Services, we collect certain types of information from you, including but not limited to the following:
      1. full name;
      2. Passport, NRIC, or Identification Number or Information;
      3. mailing address;
      4. Email;
      5. telephone number;
      6. credit history;
      7. geographical location;
      8. device identifiers;
      9. profile picture;
      10. your network usage data or other information gathered automatically by our systems, including computer IP address, links visited, and other activities conducted online;
      11. information about how you use the Gorilla Services; and
      12. other information which you may provide to Gorilla from time to time.
    2. If you provide us with any Personal Data relating to a third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Privacy Policy.
    3. You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our ability to provide you with the Gorilla Services you have requested.
    1. When you visit the Gorilla Services, we send one or more cookies to your computer and other devices. The information obtained from such cookies may be used by us for storing user preferences and to enable Gorilla to display targeted advertisements which may be of interest to you.
    2. We also collect information which is sent to us by your web browser. When you browse the Gorilla Services, we automatically receive your computer’s IP address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.
    3. Other information we may collect include the address of the web page you were visiting when you accessed the Gorilla Services and the date and time of your visit. The type of information we collect depends on the settings on your web browser.
    1. We use this information to:
      1. provide the Gorilla Services and its features to you, including:
        1. ensuring the contents of the Gorilla Services are presented in the best way for you and your computer (or mobile device);
        2. providing you with information about products or services that you request for or which we consider may be of interest to you;
        3. allowing you to use various features of the Gorilla Services;
        4. measuring and improving the Gorilla Services and its features;
      2. provide you with customer support;
      3. provide you with service-related announcements;
      4. prevent potentially illegal activities;
      5. enforce our T&Cs;
      6. generate aggregate, non-identifying information about how people use the Gorilla Services; and
      7. for any other purpose for which Gorilla has specifically obtained your consent.
      8. provide, test, improve, promote and personalize the Gorilla Services
      9. fight spam and other forms of abuse;
      10. comply with any applicable rules, laws, regulations, code of practice guidelines, issued by any legal or regulatory bodies which are binding on Gorilla (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence, and investigations); and
      11. for any other purposes which are reasonably related to any of the above purposes, or for any other purpose which we may notify you at the time of obtaining your consent.
    2. If you are an Account Holder, we collect and use your Personal Data for the following purposes:
      1. Opening or continuation of Account and establishing or providing you with the Gorilla Services (including Gorilla GO Token) you purchase (including but not limited to service activation, service operations, service delivery, and order processing);
      2. facilitating the continuation or termination of your usage to the Gorilla Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);
      3. facilitation the daily operation of the Gorilla Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
      4. facilitating third party services if purchased, obtained, administered, or processed through us;
      5. managing and executing our service-level agreements with you (if any);
      6. processing of payment instructions, GIRO, direct debit facilities and/or credit facilities requested by you;
      7. enforcement of repayment obligations (including but not limited to debt collection, filing of claims, retrieval of payments from losses made by our service partners);
      8. administering and processing any insurance claims and payments arising under the respective policies;
      9. credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
      10. generating internal reports (including but not limited to annual, operational and management reports);
      11. processing referral payments and commission fees to our external partners;
      12. administering fee adjustments, refunds and waivers;
      13. notifying you of your entitlements under any loyalty and reward programmes with us;
      14. analysing your use of the Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and
      15. purposes which are reasonably related to any of the above purposes, or for any other purpose which we may notify you at the time of obtaining your consent.
    1. Gorilla will send you marketing communications by email if they relate to goods and services similar to those you have expressed an interest in and if you have consented to us contacting you in this manner.
    2. You have the right to unsubscribe to the marketing communications by clicking the corresponding link featured in each marketing communication email sent to you.
    3. You have the right to request that Gorilla does not use the Personal Data collected for marketing purposes or refrain from transferring the data to third parties for marketing purposes, by notifying Gorilla of the same via, or .
    1. By registering an Account with Gorilla, you may make available to the public certain Personal Data from your Account, and through interactions on the Gorilla Platforms.
    2. Where such Personal Data may reveal special category protected data, it is processed on the basis that you have manifestly made it public.
    3. If you do not agree with and accept the risk of such use of your Personal Data, you will not be permitted to use the Gorilla Services as an Account Holder.
    1. You may at any time object to the use of your Personal Data by notifying Gorilla of the same via, or . Your Account will be suspended in the meantime whilst investigations are underway for any alleged misuse of your Personal Data.
    1. The Gorilla Services are hosted in Singapore. By using the Gorilla Services, you hereby authorise the transfer, storage, and use of your Personal Data in Singapore and to the extent that is allowed by the PDPA and the GDPR.
    1. You may at any time access and modify your Account Information through your Account. It is your responsibility to ensure that the information therein is accurate and kept up-to-date at all times.
    1. You may at any time delete your Personal Data by deleting your Account by sending an email request to . Gorilla will notify you of the acceptance/confirmation of termination of your Account. Your Account will be considered terminated once your Account becomes unrecoverable. Your Account will become unrecoverable from the date of notice of confirmation of termination. All your Account Details will be deleted from our systems, save as to aggregated data and to the extent required to facilitate compliance with global industry standards of data retention.
    1. Gorilla retains Personal Data associated with your Account for the entire duration which your Account remains active, and your consent is not withdrawn. In the event that your Account is deleted, or consent is withdrawn, Gorilla will only retain your Personal Data to the extent required by law and to the extent permitted by the PDPA and GDPR.
    1. We may disclose your Personal Data if we are required by law to do so or if it is necessary to facilitate any investigation for breach of our T&Cs or to enforce our rights under the T&Cs.
    2. By using the Gorilla Services, subject to the provisions of the PDPA and GDPR, Gorilla may share your Personal Data:
      1. with parties whom you have consented for Gorilla to share such information;
      2. with Gorilla’s partners, affiliates or subsidiaries;
      3. in the event of a sale, transfer of ownership of the shares or assets of Gorilla, merger or other similar transaction;
      4. where we provide services jointly with other companies or Data Intermediaries;
      5. to give search engines access to publicly available information; and
      6. as otherwise set forth in this Privacy Policy.
    3. Information about you may also be shared where you have made that information public by uploading it on or to the public areas of Gorilla Platforms.
    1. In general, the Data Intermediaries or other third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. Gorilla shall ensure that they do so within boundaries of the PDPA and GDPR.
    2. This Includes the following categories of recipients:
      1. hosting, storage, and other infrastructure;
      2. security;
      3. Analytics;
      4. network providers and partners; and
      5. communication and support.
    3. However, when you click on links available on the Gorilla Services, they may redirect you away from the Gorilla Services. Once you exit the Gorilla Services or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s T&Cs.
    4. We are not responsible for the privacy practices of these Data Intermediaries/service providers and encourage you to read their privacy policies in order to understand the manner in which your personal information will be handled by these providers.
    5. In particular, please note that certain providers may be located in or have facilities that are located in a different jurisdiction. Thus, if you elect to proceed with a transaction that involves the services of a third-party service provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
    1. Gorilla collects and stores your Personal Data only on the legal basis set out in the PDPA and GDPR. Consent is obtained when you provide us with Personal Data to register your Account and consciously tick the box to agree to this Privacy Policy.
    2. If we wish to use your Personal Data for a purpose other than as set out in this Privacy Policy, we will ask you for your express consent.
    1. Gorilla does not knowingly provide access to the Gorilla Services to anyone under the Age of Majority or collect any Personal Data in relation to any such person.
    2. By using the Gorilla Services, you represent that you are at least the Age of Majority in your country/state/province of residence, where applicable.
    1. You may withdraw consent by deleting your Account at any time by requesting to terminate your Account through, by sending an email request to Gorilla will notify you of the acceptance/confirmation of termination of your Account. Your Account will be considered terminated once your Account becomes unrecoverable. Your Account will become unrecoverable from the date of notice of confirmation of termination. Doing so will erase your Personal Data save as to aggregated data and to the extent required to facilitate compliance with global industry standards of data retention.
    1. To protect your Personal Data, we take reasonable precautions and follow industry practices to ensure that such information is not lost, misused, accessed by unauthorised persons, disclosed, altered or destroyed.
    2. Nonetheless, you should be aware that transmission of information via the internet is not entirely secure and Gorilla cannot guarantee the security of any data transmitted to our Gorilla Services via the internet.
    3. You should take steps to keep your data secure by protecting your password and other account credentials for your Account and any other account which is accessed through the Gorilla Services.
    4. In the event that there is a data breach, Gorilla shall notify you within 72 hours with a relevant breach notification.
    1. Gorilla reserves the right to modify this Policy at any time to ensure that it is consistent with its business development or changes in applicable legal or regulatory requirements. Changes and clarifications will take effect immediately upon their publication on the Gorilla Services. We will notify you about significant changes to our Privacy Policy. Should you no longer agree to this Privacy Policy, you can opt out of any such changes to our Privacy Policy by deleting your account.
    1. This privacy policy forms part of the T&Cs of the Gorilla Services and shall be governed and construed in accordance with laws of the Republic of Singapore. Any dispute arising out of or in connection with this privacy policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved exclusively by the courts of Singapore.
    1. If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact us via, or send an email to