1. Introduction

1.1. We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “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 personal data provided to us by you.

1.2. This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any personal data.

1.3. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process personal data, please do not hesitate to contact our Data Protection Officer (“DPO”) at the contact details below.

1.4. This Privacy Policy sets out the basis on which we use and process any personal data we collect from you as a user of the Website. By accessing the Website, or any other application or software we provide from time to time (collectively our “Software”), you hereby agree to be bound by the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, you should not use the Website.

2. Information we collect

2.1. We may collect and process personal data such as:

(i) Information that you may provide when contacting us for any reason, such as your name, email address and contact details.

(ii) If you contact us for any reason, we may keep a record of that correspondence.

(iii) 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, send this data to us in order for us to be informed of any software errors or problems that may occur during the use of the Website.

(iv) Details of visits to the Website, the activities you engage in when using the Website and the resources that you access on or via the Website.

3. How we use personal data

3.1. We use your personal data for the following purposes:

(a) providing, improving and developing our services;

(b) researching, designing and launching new features or products;

(c) presenting content and information on our Website or in our Application in the most effective manner for you and for the device you use;

(d) providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;

(e) collecting overdue amounts;

(f) complying with laws and regulations applicable to us in or outside of Singapore;

(g) responding or taking part in legal proceedings, including seeking professional advice;

(h) for direct marketing purposes (please see further details in Clause 3.2 below);

(i) communicating with you and responding to your questions or requests; and

(j) purposes directly related or incidental to the above.

3.2. We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:

(a) the personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 3.1 above;

(b) the type of services or products that may be offered or advertised will be set out in our Website and may be contained in any direct marketing messages;

(c) the relevant information may be sent to you by email or other form of electronic message (WhatsApp) or by direct calls;

(d) you may opt out any time by informing us. We will cease to send you marketing information without charge.

4. Disclosure of personal data

4.1. Personal data provided to us by you may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for the purposes set out below:

(a) our headquarters, subsidiaries and group companies (whether or not they are situated in another country);

(b) third party service providers which require the processing of personal 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 personal data;

(ii) to host and maintain the Website;

(c) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services)

(d) public and governmental / regulatory authorities, statutory boards, industry associations, whether in Singapore or abroad; and/or

(e) courts and other alternative dispute forums.

4.2. In certain circumstances we may provide third parties (whether or not located in Singapore) with aggregate information about our Website’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.

4.3. We may also disclose personal data in order to comply with any legal obligation, or in order to enforce or apply our Software Terms and Conditions (where applicable); or to protect the rights, property, or safety of any person (including for example for the purposes of fraud detection and prevention).

5. Cookies

5.1. Our Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our Website.

5.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.

5.3. We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Website or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

5.4. We use the following cookies:

(a) Strictly necessary cookies – These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website, use a shopping cart or make use of e-billing services.

(b) Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.

(c) Functionality cookies – These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(d) Targeting cookies – These cookies record your visit to our Webite , the pages you have visited and the links you have followed. We will use this information to make our Website and the information displayed on it more relevant to your interests.

5.5. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Website.

5.6. We may use third-party web services on our Website. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Website and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

6. Third-Party Sites

Our Website or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and 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 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.

7. Transfer of personal data outside of Singapore for storage

7.1. 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 personal data and/or using the Website, you agree and consent to such transfer, storing or processing.

7.2. We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent the loss, misuse, unauthorized access, disclosure or modification of personal data.

8. Updating your information

8.1. Where you submit personal data to us, you should 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. You may request to update or amend your personal data by notifying us through e-mail to our Data Protection Officer (details set out in paragraph 10 below).

9. Retention of personal data

Your personal data will be retained by us for as long as the original purposes or the legal or business purposes for which your personal data was collected continues. If retention is no longer necessary, we will use reasonable efforts to delete, destroy or de-identify your personal data unless retention of the same is required to satisfy legal or regulatory requirements or to protect our interests or in accordance with our policies.

10. Your rights

10.1. You may withdraw your consent for us to collect, use, disclose and/or process your personal data for some or all of the purposes listed in this Privacy Policy.

10.2. 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. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.

11. Changes to this privacy policy

We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy Policy will be posted on our Website. You are expected to check this page from time to time to take notice of any changes we have made as they are binding on you. Your continued use of the Website following any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms.

12. Further information about protection of personal data and the Personal Data Protection Act 2012

If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your personal data is collected, used, disclosed and/or processed by us, please contact our Data Protection Officer.