Updated as at: February 10, 2020
1.1. We take our responsibilities under the Singapore Personal Data Protection Act 2012 (“PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
1.4. In addition, the Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their privacy policies and you access and provide your personal data to these third party websites at your own risk. Please check these policies before you submit any personal data to any such websites.
2. Personal data we collect
2.1. We may collect and process personal data about you such as:
2.1.1. personal data that you may provide when registering an account on the Platform or submitting personal data to the Platform. Personal data includes without limitation your name, photograph(s), email address and contact details.
2.1.2. if you contact us for any reason, we may keep a record of that correspondence.
2.1.3. personal data that may be captured via any error logging and reporting tool that captures error report data and, at your option and with your consent, sends this data to us in order for us to be informed of any software errors or problems that may occur during your use of the Platform or the services provided on it.
2.1.4. details of your use of the Platform, the activities you engage in when accessing the Platform and the resources that you use on the Platform.
3.2. You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of the Platform if cookies are disabled.
4. How we use your personal data
4.1. We may use your personal data that we possess for the following purposes:
4.1.1. to process, administer and/or manage your account with us and/or your use of the Platform;
4.1.2. to contact you as may be necessary in connection with your use of the Platform;
4.1.3. to collect information relating to your use of the Platform (including, for example, your IP address and the pages you view) so that we can offer you a more consistent and personalised experience in your use of the Platform;
4.1.4. to store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Singapore;
4.1.5. for record-keeping purposes;
4.1.6. to conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve the Platform, services and facilities in order to enhance the services we provide to you, where you have consented to be contacted for such purposes;
4.1.7. to respond to legal process and managing any complaints or claims;
4.1.8. to respond to requests for information from governmental or regulatory authorities, and for audit, compliance, and investigation purposes;
4.1.9. to comply with any applicable law, regulation, legal process or government request;
4.1.10. to enforce our Terms of Services; or
4.1.11. to protect the rights, property or safety of any person (including for the purposes of fraud detection and prevention).
5. Disclosure of your information
5.1. Your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for one or more of the purposes set out above:
5.1.1. third party service providers which require the processing of your data, for example, third party service providers which have been engaged by us to: (i) to provide and maintain any IT equipment used to store and access your personal information; (ii) to host and maintain the Platform; or (iii) otherwise in connection with the provision of certain services provided to you on or via the Platform;
5.1.2. our auditors and legal advisors;
5.1.3. governmental or regulatory authorities; or
5.1.4. courts and other alternative dispute forums.
5.2. We may disclose your personal data to government or regulatory authorities if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, to enforce or apply our Terms of Services, or to protect the rights, property, or safety of any person (including for example for the purposes of fraud detection and prevention).
5.3. In certain circumstances, we may provide third parties (whether or not located in Singapore) with aggregate information about the Platform's users. This may include information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is anonymised statistical data about our users' browsing actions and patterns, and does not identify any individual.
6. Transfer of your personal data outside of Singapore
6.1. The personal data that we collect from you may be transferred to, used, processed and stored outside of Singapore for one or more of the purposes set out above. By submitting your personal data and/or using the Platform, you agree and consent to such transfer, storing or processing.
6.2. Where personal data is transferred by us to any third parties outside of Singapore, we will ensure that such transfers are compliant with the requirements under the PDPA. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the PDPA.
7. Request for access or correction of personal data
7.2. You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer using the contact details provided below at clause 10. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.
8. Administration and management of personal data
8.1. We will take appropriate measures to keep your personal data accurate, complete and updated. Where you submit your personal data on the Platform, you should try to ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal data about you.
8.2. We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
8.3. We will also take commercially reasonably efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes
10. Complaint Process
If you have any complaint regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint. Please contact our Data Protection Officer at firstname.lastname@example.org.