- (a) what Information we may collect
- (b) how we may use your Information
- (c) with whom we may share your Information
- (d) how we store your Information
- (e) how we protect children’s privacy
- (g) your choices about the Information we have collected
1. Your acceptance
2. Information we collect
A. The following is Information which you provide to us directly:
2.1 Personal details about yourself
In using the Website, you may submit to us your email address when you sign up to our mailing list or when you contact us to make an enquiry.
As you interact and communicate with us, you may also reveal to us other Information about yourself (e.g. your name, address, phone number etc.).
B. Other Information which we receive when running the Website:
2.2 Analytics Information
We use third-party analytics tools to help us measure traffic and usage trends for the Website. These tools collect information sent by your device, including the web pages you visit, add-ons, and other information that assists us in improving the Website. We collect and use this analytics information with analytics information from other visitors so that it cannot reasonably be used to identify any particular individual visitor of the Website.
2.3 Cookies and similar technologies
The Website contains “cookies”, clear gifs (also known as “web beacons” and “web bugs”), or similar technology. A cookie is a piece of data that is sent to your Internet browser, which will store the cookie on your computer if your browser is enabled to accept cookies. Web beacons assist in the delivery of cookies and the collection of non-personally identifiable information, such as “click path” and other data as described above.
(a) remember information about you so you do not have to keep giving it to us;
(b) help us understand how you and other visitors are using the Website;
(c) help us personalize the Website for you by remembering your preferences and settings; and
(d) find out if our emails have been read and if you have clicked a link in it.
Please note that not all cookies are deleted from your browser after you leave the Website or close your browser.
To manage the Information being collected, you can access the “Settings” in your browser and adjust the “Cookies” settings to:
(a) erase cookies from your computer hard drive;
(b) block acceptance of all or some cookies; or
(c) receive a warning before a cookie is stored.
Please note, however, that if you block cookies, some portions of the Website may not function properly.
2.4 Log file information
Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the web page or app is downloaded to your browser or device.
When you use the Website, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, number of clicks and how you interact with links on the Website, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Mailing List Subscribers which then helps us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Website.
2.5 Device identifiers
When you use a mobile device like a tablet or phone to access the Website, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device that uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us.
A device identifier may deliver information to us or to a third-party partner about how you browse and use the Website and may help us or others provide reports or personalized Content and ads. Some features of the Website may not function properly if use or availability of device identifiers is impaired or disabled.
3. How we use your Information
How we use your Information will depend on the nature of your interaction with the Website and with us. We need to have valid grounds to process your Information. Most times, we would seek your consent, like when you subscribe to our mailing list. Other times, when you reasonably expect us to use your Information, we will not ask for your consent, but only when it is legally permissible for us to do so (e.g. it is necessary for our performance of a contract or for us to comply with a legal obligation etc.).
Generally, we collect and use Information for the following purposes:
(a) to remember information so that you do not have to re-enter it each time you use the Website;
(b) to provide personalized Content to you or other interest segment updates, personalized online advertisement or other forms of marketing, like emails about products, services and other information you might be interested in. We may also contact you for market research purposes;
(c) to test, improve and monitor the Website, including diagnosing and fixing technology problems;
(d) to provide you with features and other updates, respond to your feedback, answer your queries and to otherwise communicate with you;
(e) to monitor metrics such as site traffic and demographic patterns;
(f) to respond to your requests or queries; and
(g) to comply with applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us.
Apart from the above purposes, we may also notify you of other purposes for which we process your Information and seek your consent to such purposes (e.g. when you participate in a survey, provide feedback, enter a competition etc.).
4. Sharing of your Information
(a) our related entities: These are businesses that are legally part of the same group of companies that we are part of, or that become part of that group.
(b) our service providers: These are third-party contractors. We engage them to assist us in providing and managing aspects of the Website, such as developing the Website’s features and functionality, marketing, processing data or statistics, hosting the Website, providing server space, providing push notifications and email, and legal advice.
Our main service providers are MailChimp for marketing automation and OneSignal for push notifications and email. Their privacy policies can be accessed at www.mailchimp.com/legal/privacy and www.onesignal.com/privacy_policy, respectively.
(c) our third party advertisers: We may provide Information to third party advertisers so that they can notify you of events or products which may be of interest to you. For instance, you may be notified of an upcoming concert or product release.
(d) analytics services: We use third party analytics providers and products to obtain, compile and analyse Information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data), and may provide such Information to these analytics providers for the purpose of obtaining statistics and other information about how visitors are using and interacting with the Website.
(e) We may remove parts of data that can identify you and share pseudonymized data with other parties. We may also combine your information with other information in a way that it is anonymized and no longer associated with you, and share that aggregated information.
We require that all parties with whom we share Information to implement adequate levels of protection in order to protect such Information. We also require that these parties only process your Information strictly for purposes which we engage them for and consistent with the purposes that we have described in Section 3 (“How we use your Information”) or with other purposes for which your consent has been sought and obtained.
We may also share your Information with third parties in the following circumstances:
(b) If permitted or required by law: We may disclose Information if we believe that such disclosure is required or permitted by law (e.g. responding to requests from government authorities, or disclosure pursuant to court orders or other legal demands); and
5. How we store your Information
We, our related entities, or service providers may transfer your Information to other countries in which our facilities or businesses are located, to be stored or processed. We will ensure that all entities located outside of Singapore to which we transfer information observe a standard of data protection which is comparable to that required under the Singapore Personal Data Protection Act 2012.
This includes the entities’ making of reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risk to your Information, and removing the Information as soon as it is reasonable to assume that its retention is no longer necessary.
Currently, the country to which Information is transferred for the purpose of storage on cloud servers is the United States of America. We may update this list periodically to reflect any new locations where your Information may be stored.
By using the Website, you acknowledge that the transfer of your Information to countries in which we, our related entities or service providers have facilities or businesses is necessary for us to operate the Website, and that we have provided you with a reasonable summary of how your Information would be protected when it is transferred out of Singapore.
6. Children’s Privacy
We do not knowingly collect Information from children under the age of 13 without parental consent. If you are a child under 13 years of age, you are not permitted to use the Website and should not send any information about yourself to us through the Website.
Upon becoming aware that we have collected Information from any child, we will delete that Information.
If you are a parent or guardian and you believe that your child under the age of 13 years has provided us with information without your consent, please email us at firstname.lastname@example.org and we will take reasonable steps to ensure that such information is deleted from our systems.
7. Third-party Sites
We are not responsible for and do not have control over any third-party websites, applications or platforms which you authorize to access or process your Information. If you are using a third-party website, application, you do so at your own risk.
8. Managing your Information
You can directly control your Information in the following ways:
(a) Emails: If you do not wish to receive any more emails from us, please click the “unsubscribe” link in the email that we have sent to you;
(b) Push Notifications: If you do not wish to receive notifications, you should adjust the “Notification” settings usually found in your browser’s “Settings” to block or remove the browser-based push notifications; and
(c) Cookies: If you do not wish to permit us to collect your Information via cookies and similar technologies, you should adjust the “Cookie” settings usually found in your browser’s “Settings” to erase, block or restrict cookies.
- Ivan Chen at email@example.com
If you are a resident of the European Union using the Website, you have the following rights under the General Data Protection Regulations:
(a) Right to be informed: This right means that when we ask you to provide us with your Information, we will give you details such as: what we are using it for, how and with whom it will be shared, and how you may contact us if you have any queries;
(b) Right to access: This right allows you to ask us for details of the Information we hold on you, e.g. what Information is being processed and for what reason, what Information is being transferred and to whom, what rights you have etc;
(c) Right to rectification: This right allows you to ask us to correct anything that you think is wrong with the Information we have about you;
(d) Right to erasure also known as the “right to be forgotten”: This right means you can ask us to delete your Information from our system;
(e) Right to restrict processing: This right allows you to ask us to only process your Information for those certain purposes that you specify;
(f) Right to data portability: This is the right to ask us to send you your Information electronically. You may also ask us to transmit such Information to another party;
(g) Right to object: This is your right to tell us to stop processing your Information;
(h) Right not to be subject to automatic decision-making, including profiling: We sometimes use computers to study and analyze Information. We might do this so we can understand how you and other visitors are using the Website. This allows us to improve the Website and Content for better customer experience e.g. by providing personalized Content and marketing to you. For situations that may significantly impact you, you have the right to ask us not to do this; and
(i) Right to complain, right to judicial remedy: If you feel your rights are breached, these rights allow you to make a complaint to the relevant authorities or to sue us in court.
EU residents may exercise their rights above by writing to our Data Protection Officer at firstname.lastname@example.org. The parent or guardian of a child resident in the European Union under the age of 13 years old or applicable age of consent, can request this on behalf of their child.