LEGAL
Privacy Policy
Last updated: 14 May 2026
This Privacy Policy explains how NORFH PTE LTD (the operator of Five Cents) collects, uses, discloses, and protects your personal data in accordance with the Personal Data Protection Act 2012 of Singapore.
1. Who We Are
1.1 NORFH PTE LTD ("NORFH", "we", "us", "our") is a company incorporated in Singapore (UEN: 202616626E). We operate the Five Cents brand (@fivecents.co) and the Five Cents platform, which connects consumers with licensed financial advisers under the introducer exemption in Regulation 31 of the Financial Advisers Regulations.
1.2 NORFH is the data controller for personal data collected through the Five Cents platform, including via the Five Cents Launch Campaign at launch.fivecents.co.
2. What Personal Data We Collect
2.1 When you participate in the Five Cents Launch Campaign or otherwise interact with our platform, we may collect:
Identification and contact details
- First name and last name
- Email address
- Mobile telephone number
- Birth year (used to verify age eligibility)
- Postal code (only if your Financial Wellness Review is conducted in person)
Survey responses
- Your responses to our content research questions, including life stage, household income band, financial priorities, and existing financial arrangements
Consent records
- Records of which consents you have given, with timestamps and (where appropriate) IP address
Technical data
- Information automatically collected when you visit our website (IP address, browser type, device information, pages visited, referral source) — collected through cookies and similar technologies
For the purpose of the campaign prize draw, NORFH may record the draw process on video. This recording forms part of the campaign audit trail and is retained for two years from the draw date. Where personal data (such as names) is visible in the recording, this is in service of the audit purpose only and not for any other use.
2.2 We do not collect:
- Your NRIC number (except briefly for prize claim verification — see Section 5)
- Health information or medical records
- Banking, credit card, or payment information
- Information about your immigration status or other sensitive categories of data not relevant to our purposes
3. Why We Collect It (Purposes)
3.1 We collect, use, and disclose your personal data for the following specific purposes:
Primary purposes (necessary to provide the Campaign)
- To administer the Five Cents Launch Campaign, including verifying eligibility, processing entries, conducting the prize draw, and contacting winners
- To inform Five Cents' content direction (your survey responses help us decide what to write about)
- To respond to your enquiries and provide customer support
- To comply with applicable laws and regulatory obligations
Additional purposes (subject to your specific consents)
- To disclose your contact details and relevant survey responses to Alpha Wealth Financial Advisers Pte. Ltd. (MAS Reg. No. 200606266H) for the sole purpose of arranging your Financial Wellness Review (an optional Campaign step that qualifies you for the S$10 Grab voucher)
- If you opt in to Five Cents marketing, to send you content updates, new launches, and promotional communications about Five Cents
3.2 We will not use your personal data for any purpose other than those stated, unless we obtain your further consent or are otherwise permitted by law.
4. Legal Basis (Consent)
4.1 We collect, use, and disclose your personal data on the basis of the consent you provide through clearly worded consent checkboxes during the survey and registration process.
4.2 Your consent is:
- Specific — given for each defined purpose separately
- Informed — supported by clear disclosure of who receives your data and why
- Unambiguous — captured via unticked consent boxes that you actively tick
- Withdrawable — you may withdraw your consent at any time
6. How Long We Keep Your Personal Data
6.1 We retain your personal data for as long as necessary to fulfil the purposes for which it was collected, in line with the following retention periods:
| Data category | Retention period |
|---|---|
| Survey responses (anonymised) | Retained for content research purposes indefinitely (after personally identifying details are removed) |
| Personally-identifying campaign data | 24 months from the close of the Campaign (31 July 2028) |
| Draw conduct recording | 2 years from the date of the draw (August 2028) |
| Marketing list (if you opted in) | Until you unsubscribe |
| Records of consent | 7 years (to demonstrate compliance) |
| NRIC verification records | Maximum 30 days, then permanently deleted |
6.2 After the retention period expires, we will delete or anonymise your personal data, except where retention is required by law.
7. How We Protect Your Personal Data
7.1 We take reasonable technical, administrative, and physical measures to protect your personal data, including:
- Encryption of data in transit (TLS) and at rest where appropriate
- Access controls limiting personal data access to authorised personnel only
- Regular security review of our systems and processes
- Contractual obligations on service providers and partners
- Staff training on data protection obligations
7.2 No method of transmission or storage is completely secure. Should we become aware of a data breach affecting your personal data, we will comply with our obligations under PDPA Sections 26A to 26D, including notifying you and the Personal Data Protection Commission ("PDPC") as required.
8. Your Rights
8.1 Under PDPA, you have the right to:
- Access — Request access to the personal data we hold about you.
- Correction — Request correction of inaccurate or incomplete personal data.
- Withdrawal of consent — Withdraw your consent for the collection, use, or disclosure of your personal data, with reasonable notice. Withdrawing consent may affect our ability to provide certain services or your eligibility to receive prizes under the Campaign.
- Erasure — Request that we delete your personal data, where it is no longer necessary for the purposes for which it was collected or where you have withdrawn consent.
- Data portability — Request that we provide your personal data in a portable format (where technically feasible).
8.2 To exercise any of these rights, please email us at hello@norfh.com. We will respond within thirty (30) days of receiving your request, in accordance with PDPA requirements.
8.3 If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore (www.pdpc.gov.sg).
10. Cross-Border Transfers
10.1 Some of our service providers (e.g., email delivery, form hosting, cloud storage) may store or process personal data outside of Singapore, including in regions such as the European Union, the United Kingdom, or the United States.
10.2 Where personal data is transferred outside Singapore, we take reasonable steps to ensure that the data is protected at a standard comparable to that provided under PDPA, including by entering into contractual arrangements requiring our service providers to maintain such standards.
11. Children's Personal Data
11.1 The Five Cents Launch Campaign and the Five Cents platform are intended for users aged 21 and above. We do not knowingly collect personal data from anyone under 21.
11.2 If we become aware that we have collected personal data from a person under 21, we will delete that data promptly.
12. Changes to This Privacy Policy
12.1 We may update this Privacy Policy from time to time. Material changes will be communicated through our website (with the "last updated" date refreshed at the top of this Policy).
12.2 Your continued use of our platform after such changes constitutes acceptance of the updated Privacy Policy.
13. Contact Us
Data Protection Officer
NORFH PTE LTD
Email: hello@norfh.com
Registered office: 95C Circuit Road, Singapore 373095
For any questions about this Privacy Policy or to exercise your data protection rights, please contact our Data Protection Officer.
Questions? Contact us at hello@norfh.com.
See also our Terms & Conditions.