Updated: November 25, 2020
Information Collected by Us
We will be collecting personal information (“Personal Data”) from you when you use or access our Services, which includes any information relating to an individual, whether recorded in a material form or not and whether true or not, who is or can be identified either from that information (whether directly or indirectly), or from other information to which we have or are likely to have access. The information includes, without limitation, your name, age, nationality, telephone number, residential address, bank account details, debit or credit details, email address, your image, government-issued identification numbers, biometric data, race, religion, marital status, date of birth, health information, personal interests, employment information, financial information and other information related to the individual (whether sensitive or not).
In addition, we may also collect information about your use of the Platform (“Informational Data”) including but not limited to (i) electronic communication protocols; (ii) web pages visited; (iii) user preferences and privileges; (iv) Cookies (as defined below); (v) third-party monitoring related to web traffic; (vi) location data; and (vii) other information that are relevant to the provision of our Services.
For ease of reference, Personal Data and Informational Data shall be collectively referred to as “Privacy Information” in this Policy.
Purpose of Us Collecting Your Privacy Information
We understand that the collection of your Privacy Information should be as transparent as possible, and therefore this section will explain why we collect your Privacy Information, although our Platform is not primarily designed to collect any substantial personal information.
Your Privacy Information is collected to, without limitation, (i) verify your identity; (ii) provide support for the provision of our Services; (iii) enable us to deliver the Services to you in an efficient and friendly-user manner; (iv) improve, develop and market new Services; (v) carry out requests made by you on the Platform in relation to our Services; (vi) investigate or resolve inquiries or disputes; (vii) comply with any applicable law; (viii) enforce our agreements with you; (ix) protect the rights and property belonging to us and other third parties; and (x) use as otherwise permitted by law.
Sources of Collection of Your Privacy Information
We may also collect your Privacy Information through other sources, including (i) online registration of user account, (ii) automated means such as communication protocols and Cookies; (ii) third party sources of information including any social network information; (iv) communications and interactions on our Platform (whether online or offline); (v) information maintained on your device; (vi) usage and device information; (vii) location information; (viii) log information; (ix) Cookies and other similar technologies; (x) third-party analytics tools; and (xi) obtaining your consent in accordance with this Policy and/or any applicable law.
How will Your Personal Information be Used?
We collect, use, store, process, disclose and share your Privacy Information for the following purposes:
Provision of Service and Support
We may collect, use, store and process your Privacy Information to facilitate your use of the Services or the Platform, and to enable us providing the Services (including the administration of your account), product updates and similar notices.
Product Development and Security
We may use your Privacy Information for testing, research, analysis and product development to enhance your user experience. This also allows us to understand and analyse your needs and preferences, protect your Privacy Information, improve and enhance the safety of our Services and the Platform, and develop new features, products and services.
We may use your Privacy Information to provide you with notices relating to product releases and service developments that addresses your needs and requirements in a timely manner (provided you have opted to receive such information).
We may communicate such marketing to you by post, telephone call, short messaging service, online messaging service, email and/or push notification by hand.
We may collect and share your Privacy Information with our affiliates, which include any site hosting providers who assist us in operating our Platform, conducting our servers or serving our customers. We may also collect and share your Privacy Information with some or all of our business partners from time to time.
We may use your Privacy Information derived from Cookies, location data (if you allow it) or your behaviour on the Platform to allow us and third parties to provide you with targeted advertisements when you use our Platform. We may also use third-party advertising companies to serve advertisements when you visit our Platform. These companies may use your Privacy Information (including your visits to other websites) in order to provide advertisements about products of interest to you.
Usage of Cookies
We may place or recognise cookies, web beacons, tags, scripts, local shared objects, advertising identifiers and other similar technology (“Cookies”) in connection with your use on our Platform. Please note that Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may also transmit your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be persistent or stored only during an individual session. Additionally, in the course of serving advertisements to this Platform, our third-party advertising companies may also do the same.
However, you can choose block, deactivate or reject the Cookies by adjusting your browser or device’s settings, but you may not be able to access certain areas of our Platform.
Transactions for Our Services
We may collect and store your Personal Data (including purchase details and payment information) as part of the transaction history if you decide to purchase certain features or packages of our Services. This may include transferring some or all of your Personal Data to third-party payment service providers.
Selection of Content
We may collect and use your Privacy Information to create website and/or mobile application contents and navigation that is user-friendly and most relevant to you.
Response to Your Inquiries and Complaints
We may collect, store and use your Privacy Information to process your complaints, feedbacks or inquiries related to the Services or the Platform. This includes investigating and resolving claims or disputes, or as allowed or required by any applicable law.
Additionally, we may use your Privacy Information in connection with any mergers, acquisitions, joint ventures, sale of company assets, restructuring, consolidation, amalgamation, financing, business asset transactions, or acquisition of all or part of our business by another legal entity.
Usage of Log Files
We use log files on our website servers, which include internet protocol addresses, internet service provider, browser type, referring/exit pages, date/time stamp, platform type and the number of clicks to analyse trends, administer the Platform, detect or track users’ movement, and collect and store broad demographic information for aggregate use.
Subscription for Our Newsletters
We may request for, collect and store your Personal Data if you wish to subscribe to our newsletters. If you no longer wish to receive our newsletters and promotional communications, you may also opt out of receiving these communications by unsubscribing them in the email.
Our Communication with You
In the course of the provision of our Services, we may communicate with you via your email or other means as deemed appropriate on a regular basis.
We may also collect, use, store, process or disclose your Privacy Information for any other purpose to which your consent has been obtained, and to conduct automated decision-making processes in accordance with any of the above purposes.
For the avoidance of doubt, where the use of your Privacy Information requires your consent, we will seek your consent at the time of us collecting your Privacy Information.
Collection of Minor’s Data
As the Service was not designed for, nor it is intended for use by, anyone under the age of 18, or the age of legal majority in your jurisdiction (if different than 18), we do not intend to collect Privacy Information from any person to our actual knowledge who is a minor.
As a parent or legal guardian, please do not allow minors under your care to submit their Privacy Information to us. In the event that such Privacy Information of a minor is disclosed to us, you hereby consent to our use of the minor’s Privacy Information and accept and agree to be bound by this Policy and take responsibility for his or her actions.
Enforcement of Your Rights in Relation to Your Privacy Information
In accordance with the applicable laws and regulations, you may enforce your rights as a data subject as follows:
You will be given the opportunity to opt out of our collection, usage, storing, processing, and sharing of your Privacy Information. If we have requested your consent to processing and you later choose to withdraw it, we will respect your choice in accordance with our legal obligations. However, we may still be able to continue to process your Privacy Information to the extent required or otherwise permitted by applicable laws and regulations, even after you have chosen to withdraw your consent. Additionally, you may also request the restriction of the processing of your Privacy Information, or object to that processing.
If you communicate your withdrawal of your consent to our collection, use, storing, processing, disclosing or sharing of your Privacy Information or the purposes and in the manner stated in this Policy, please note that we may not be in a position to continue providing the Services to you, and we will not be liable in the event we do not perform the Services. Our legal rights and remedies are expressly reserved in such an event.
Clarification, Correction, Deletion or Deactivation
It is important that the Personal Data you provide to us is accurate and complete for you to continue using the Platform and for us to provide the Services. Therefore, you are responsible for informing us of any change of your Personal Data, or in the event you believe that your Personal Data hereby collected by us is inaccurate, incomplete, misleading or out-of-date. You can update your Personal Data anytime by accessing your account on the Platform or by contacting us.
You may also enquire about the ways in which your Privacy Information may have been collected, used, stored, processed, disclosed or shared by us, and request a copy of your Personal Data from us.
Additionally, you may request the correction of any error or omission of your Privacy Information which we have collected. However, we may refuse such correction request if required by law or deemed unreasonable by us. In certain instances (subject to the applicable law), you may also request for the deletion and/or deactivation of your Privacy Information.
Photos or Images Submitted by You on the Platform
The Platform may contain links to other websites operated by other parties, such as our business affiliates, third-party advertising companies, or other merchants. We are not responsible for the privacy practices of websites operated by these other parties. You are strongly advised to check on the applicable privacy policies of those websites to determine how they will handle any information including the Privacy Information collected by them from you.
Retention of Your Privacy Information
Unless otherwise instructed by you or any regulatory body or law enforcement organisations, we retain your Privacy Information for the period necessary to fulfil the purposes outlined in this Policy. Once your Privacy Information is no longer necessary for the Services or the purposes outlined in this Policy, or we no longer have a legal or business purpose for retaining your Privacy Information, we take steps to erase, delete, deactivate, destroy, anonymise or prevent access or use of such Privacy Information for any purpose other than compliance with this Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of any applicable law.
Protection of Your Privacy Information
As a data controller, we will take reasonable legal, organisational and technical measures to ensure that your Privacy Information is adequately and sufficiently protected at all times. This includes measures to prevent Privacy Information from getting lost, or used or accessed in an unauthorised way.
We also limit the access of our authorised employees to your Privacy Information strictly on a need-to-know basis only. If any of our authorised employees are instructed to process your Privacy Information, they will only do so in an authorised manner and are required to treat your information with the strictest confidential treatment.
Notwithstanding the foregoing, there are circumstances that the transmission of information via the Internet is not completely secure. Despite mobilising our best efforts to protect your Privacy Information, we cannot guarantee that your Privacy Information is always transmitted in a risk-free manner.
Changes to this Policy
If you have any questions or queries on this Policy, or if you have any questions on personal data protection or data privacy not addressed in this Policy, or you would like to exercise your rights set out in this Policy, please contact us by sending an email to firstname.lastname@example.org.