Takes Effect on 2020/02/20
Last Updated on 2020/03/04
- INTRODUCTION AND PURPOSE OF THIS POLICY
You are at liberty to not provide any personal data to us. Your provision to us of your personal data for any reason such as in connection with your subscription or use of our Services are subject to your acceptance of the terms and conditions of this Policy. Accordingly you are asked to read and follow the content of this Policy carefully, if you are providing or have provided to us your personal data in connection your subscription or use of our Services.
We will respect and protect your personal data privacy in accordance with this Policy and the mandatory requirements under the applicable laws such as (if you are protected under the European General Data Protection Regulation of the European Union (“GDPR”)) the GDPR (“Laws”), and we otherwise reserve all rights under the Laws.
In order to ensure your personal data privacy, the personal data you provided to us is collected, stored, processed, used, disclosed, disposed, deleted, transmitted nationally or internationally, and/or shared/transferred with/to the authorized Company employees, contractors and agents in connection with any of the foregoing (collectively “Handle”, “Handled” or “Handling”, as appropriate), only in the manner and for the purposes described in this Policy.
- PERSONAL DATA COLLECTED AND STORED BY US
For the purpose of your subscription or use of our Services, we collect and store the following (among other) personal data (“Personal Data”) from you:
- your phone number, actual name, shipping address, billing address, username, IP address, location data, online identifier, and cookie identifier; and
- your username, email address, and phone number, indirectly through links from a third party platform such as Google, Facebook or Instagram (through whose platform your account with us was/is created).
The Personal Data we collected from you are stored in your terminal unless you share the Personal Data to the cloud storage service provided by Google Cloud Platform or other comparable cloud service provider(s).
You are asked not to provide any “special category data” to us, such as data on or related to your ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, sex life or sexual orientation, or any personal data relating to criminal offences and convictions, and we may delete it/them if any such special category data is/are provided to us.
You are asked not to provide and we may assume that you have not provided any inaccurate or misleading information to us. You are asked to promptly update or correct and we may assume you have updated and/or corrected, as applicable, your Personal Data which you have provided to us.
Unless provided otherwise in this Policy, we may decline to collect and may remove or delete any Personal Data or outdated Personal Data provided or attempted to be provided to us by any Users as permitted or required by the Laws.
- HOW WE COLLECT PERSONAL DATA
You subscribe for our Services by creating and registering an account with us through a third party platform such as Google, Facebook or Instagram, and in the process we collect and store Personal Data from you.
In addition, we may collect your Personal Data:
- when you contact us and volunteer your Personal Data;
- if we need your Personal Data to respond to your request(s) and you provide such Personal Data;
- when you complete a customer survey or provide feedback on any of our message boards or via emails; or
- when you use/view our website(s) via your browser’s cookies.
- HOW AND WHY WE USE PERSONAL DATA
In connection with your subscription for or use of our Services, we may process your Personal Data for some or all of the following “specific purposes” (“Specific Purposes”):
- signing you up to our Services;
- provide our Services to you;
- improve our Services to you;
- manage invoices, payments and arrears related to your account with us for our Services;
- fraud detection;
- respond to contact requests, inquiries or comments from you;
- monitor your use of our Services, primarily on interactive behavior with our Services, such as your journey, frequency of use, total use time, crash report, hit rate, etc.;
- identify violations of this Policy or the relevant service policies;
- identify your breach of the terms and conditions of the Services contract;
- carry out our administrative, operational, enforcement and other tasks or actions in connection with or ancillary to any of the above specific purposes; and/or
- Handle your Personal Data in connection with or ancillary to any of the above specific purposes.
In addition, we may use the collected Personal Data for legitimate business purposes permitted by the Laws, including without limitation, to provide e-letters, marketing or promotional materials or other information on or for our product(s)/service(s), organization or business plan. You may tell us via the contact details provided below in this Policy to cease providing any such e-letters, marketing or promotional materials or other information.
- LEGAL BASIS FOR PROCESSING PERSONAL DATA
In connection with your subscription or use of our Services, we may process your Personal Data under any of the following “legal basis”:
- you have given consent to the processing for one or more Specific Purposes;
- processing is necessary for the performance of the contract between the User and the Company in relation to the Company’s provision of our Services to you, such as the Services contract;
- processing is necessary for compliance with a legal obligation to which the Company as the controller is subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest; or
- processing is necessary for the purposes of the legitimate interests pursuit by the Company as the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of your Personal Data. Such “legitimate interests” refer to those legitimate interests permitted by the Laws, including without limitation, processing to provide e-letters, marketing or promotional materials or other information on or for our product(s)/service(s), organization or business plan).
- HOW LONG WE RETAIN PERSONAL DATA
We keep your Personal Data only for as long as your subscription to use our Services is maintained or the Services contract is not terminated. We erase your Personal Data from our storage and record as soon as possible after your subscription is closed and the Services contract is terminated, except to the extent a necessary longer period of storage and/or record is permitted or required by the Laws.
- LINKED WEBSITES
As a gratuitous service to the Users, our website(s) may provide hyperlinks to potentially valuable resources that are related to our product(s)/service(s). These hyperlinks, which are highlighted words, URLs or icons within a hypertext document that may, when clicked, take you to another place within the document or to another document altogether, or to a third-party website not controlled by us. Such hyperlinked third-party website(s) may handle or process information collected in a manner or for a purpose that is different from our practice or in violation of the Laws. We are not responsible for the handling or processing of information exchanged between any Users and any of these third-parties, and we expressly disclaim any and all responsibilities, obligations and/or liabilities related to or arising from such handling or processing by any third-parties or the accuracy of the information provided by any third parties.
We do not collect any Personal Data from any Users who click on these hyperlinks located on our website(s).
We do not intend to provide product(s)/service(s) to any minors who are below the age of 16 years or who are not legally eligible to transact business or give consent in relation to his/her Personal Data (“Minors”).
We do not knowingly collect Personal Data from Minors. You are asked not to provide or permit to provide Personal Data of Minors to us. You provide or permit to provide Personal Data of Minors at your risk and liability.
If you believe that Personal Data of any Minor has been provided to us, please contact us at our contact details provided below in this Policy so that the Personal Data can be promptly removed.
- keep you signed in;
- understand how you use our website(s); and
- recognize you and remember your previous activities on our website(s), including to remember the content you viewed, information about your browser, device and your IP address, and your previously selected preferences such as the language you prefer and the location you are in.
- HOW WE MANAGE YOUR COOKIES
You can set your browser not to accept cookies.
- DATA SECURITY AND PROTECTION
We endeavor to have security measures in place to Handle Personal Data under our control in accordance with this Policy and the Laws. We have implemented bio-authentication for App access. We will continue to revise policies and implement additional security features as appropriate and required by this Policy and the Laws.
No data transmission over the Internet is 100% secure. We make no representations or warranties with regard to the sufficiency of our security measures. We shall not be responsible or liable for any actual or consequential damages, or any other damages or liabilities of any kind whatsoever, from a security breach or technical malfunction by any third party not controlled by us, including Google Cloud Platform.
- DATA TRANSFERS TO OTHER JURISDICTIONS OR ENTITIES
We endeavor to restrict access to your Personal Data to our selective authorized employees and our servers, located inside or outside the country or jurisdiction you are located in or resident of.
You agree for us to transfer or transmit your Personal Data, within or outside the Company group, to Google Cloud Platform or other comparable third party data processor(s), within the same jurisdiction or from one jurisdiction to another, to countries or jurisdictions that may or may not have been recognized by the European Commission as providing adequate personal data protection, for any of the Specific Purposes or legitimate business purposes, or otherwise as permitted by the Laws.
If we transfer your Personal Data to countries or jurisdictions that have not been recognized by the European Commission as providing adequate personal data protection, we will ensure suitable safeguards are in placed as required by the Laws, such as by:
- binding corporate rules;
- standard data protection clauses adopted by the European Commission;
- standard data protection clauses adopted by a supervisory authority and approved by the European Commission;
- an approved code of conduct, together with binding and enforceable commitments of the controller or processor in the third country to apply the appropriate safeguards, including as regards data subjects’ rights;
- an approved certification mechanism, together with binding and enforceable commitments of the controller or processor in the third country to apply the appropriate safeguards, including as regards data subjects’ rights; or
- contractual clauses between the controller or processor and the controller, processor or the recipient of the Personal Data in the third country or international organization.
- CHANGES TO THIS POLICY
From time to time, the Company may update or modify this Policy and publish the same on our website(s). The Company endeavors to give at least 30 days advance notice of the update or modification unless a shorter period is necessary or for cause. You should check our website(s) periodically to review the most recent Policy.
The most recent Policy shall govern and prevail with effect from the effective date of the most recent Policy. To the extent any update or modification of this Policy materially and adversely affect your rights or obligations under the Services contract you entered into with the Company, you are entitled to terminate the Services contract without liability with written notice to the Company with immediate effect, provided that the termination does not affect the rights and obligations of the parties under the Service contract accrued prior to the effective date of termination.
- YOUR DATA PROTECTION RIGHTS
If your Personal Data is provided to and collected by us, you have the following data protection rights in accordance with and subject to the Laws:
- The right to access: You have the right to access your Personal Data under certain conditions. We may charge you a reasonable fee or reimbursement for this service.
- The right to rectification: You have the right to correct and complete any inaccurate or incomplete Personal Data.
- The right to erasure: You have the right to erase your Personal Data under certain conditions.
- The right to data portability: You have the right to transfer your Personal Data to another organization, or directly to you, under certain conditions.
- The right to restrict processing: You have the right to restrict the Company’s processing of your Personal Data under certain conditions.
- The right to object to processing: You have the right to object to the Company’s processing of your Personal Data under certain conditions.
The above data protection rights are not necessarily absolute, as provided in the Laws. The Company reserves all rights permitted under the Laws.
If for any reason you cannot or do not wish to exercise any of the above rights directly on the Company’s system through operation of your account with us (to the extent such a mechanism is available), you may make a request to the Company by contacting us at the contact details provided below in this Policy, and we will respond to you within one month or otherwise as required by the Laws.
If you erase, restrict or object to our processing of your Personal Data, and such erasure, restriction or objection impairs our provision of Services to you, we will not be able to provide our Services to you, in which case, we are entitled to terminate the Services contract without liability with written notice to you with immediate effect, provided that the termination does not affect the rights and obligations of the parties under the Services contract accrued prior to the erasure, restriction or objection.
The information in our website(s) shall not be construed as a legally binding offer for the sale or purchase of our Services or any other product(s)/service(s). References made on our website(s) to any and all third party product(s)/service(s) are for information purposes only and do not expressly or impliedly constitute our endorsement or recommendation of such product(s)/services(s).
- HOW TO CONTACT THE APPROPRIATE AUTHORITIES
Should you wish to report a complaint or if you feel that this Policy has not addressed your concern in a satisfactory manner, you may contact the relevant data protection authority in your locality.
- CONSENT; WITHDRAWAL OF YOUR CONSENT
If your Personal Data is provided to and collected by us in connection with your subscription or use of our Services, consent(s) from you on terms and conditions set forth in this Policy are required.
You have the right to withdraw your consent(s) by writing to us at our contact details above in this Policy at any time:
- in respect of any consent(s) you have given to our processing for one or more Specific Purposes;
- in respect of any consent(s) you have given to our transfer of your Personal Data to any third parties or other country/ies; or
- to the extent the Laws require us to respect your right to withdraw your relevant consent(s).
We will respond as permitted or required in this Policy and the Laws.
Your withdrawal of your consent(s) does not affect the lawfulness of processing based on consent(s) before your withdrawal.