This policy sets out the basis on which SUBX PTE LTD (unique entity number:202117358Z) (together with our subsidiaries, our holding company, or subsidiaries of our holding company from time to time, collectively "we") collect personal data from you and how we process such data.
By visiting our website (our "Website") or usingall SUBX affiliated ecosystem applications or any other applications or software we provide from time to time (collectively our "Application"), you accept and consent to the practices set out below.
1. COLLECTION OF PERSONAL DATA
1.1 For the purposes outlined in Clause 2, we may collect and process the following personal data about you:
(a) Information you give us - information that you provide us (which may include your name, address, email address, telephone number, credit card information and other personal description) by filling in forms on our Website or in our Application, or by corresponding with us (by phone, email or otherwise), for example:
(i) when you register for an account with us on our Site or in our App;
(ii) when you report any problem to us;
(iii) when you use certain features on our Website or in our Application;
(iv) when you request any support from us; or
(v)when you complete any survey or questionnaire we send you.
(b) Information we collect about you - information automatically collected when you visit our Website or use our Application, for example:
(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
(ii) details of any transactions, purchases and payments you made on our Site or in our App; and
(iii) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website or Application (including date andtime), products you viewed or searched for, page response times, downloaderrors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
1.2 We only retain personal data for so long as it is necessary. Your personal data may be archived as long as the purpose for which the personal data was used still exists and if there are any legal or business reasons.
2. USES MADE OF THE PERSONAL DATA
2.1 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) complying with laws and regulations applicable to us in or outside of Singapore;
(f) responding or taking part in legal proceedings, including seeking professional advice;
(g) for direct marketing purposes (please see further details in Clause 2.2 below);
(h) communicating with you and responding to your questions or requests; and
(i) purposes directly related or incidental to the above.
2.2 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 1.1 above;
(b) the type of services or products that may be offered or advertised will be software as service products;
(c) the relevant information may be sent to you byemail and telegram messages;
(d) you may opt out any time byemailing us at [email protected] We will cease to send you marketing information without charge.
3. DISCLOSURE OF YOUR INFORMATION
We will keep your personal data we hold confidential but you agree we may provide your personal data to:
(a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act (Chapter 50);
(b) 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);
(c) our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
(d) persons under a duty of confidentiality to us;
(e) persons to whom we are required to make disclosure under applicable laws andregulations in or outside of Singapore; or
(f) actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Singapore.
4.3 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 Application 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).
4.4 We use the following cookies:
(a) Strictly necessary cookies - These are cookies that are required for the operation of our Website or Application. They include, for example, cookies that enable you to log into secure areas of our Website or Application, 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 or Application when they areusing it. This helps us to improve the way our Website or Application 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 or Application. 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 Website or Application, the pages you have visited and the links you have followed. We will use this information to make our Website or Application and the information displayed on it more relevant to your interests.
4.5 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 or Application.
4.6 We may use third-party web services on our Website or in our Application. 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 or Application 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.
5. THIRD-PARTY SITES
Our Website or Application 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. We encourage you to read theprivacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.
6.1 All personal data you provide to us is stored on our secure servers.
6.2 Any payment transactions will be encrypted using TLS/SSL technology.
6.3 We restrict access to personal information to our employees, service providers and contractorson a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
6.4 We review our personal data collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
6.5 Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website or Application; any transmission is at your own risk.
7.1 You have the right to:
(a) check whether we hold personal data about you;
(b) access any personal data we hold about you; and
(c) require us to correct any inaccuracy or error in any personal data we hold about you.
7.2 Any request under Clause 7.1 may be subject to a small administrative fee to meet our cost in processing your request.
We may amend this policy from time to time by posting the updated policy on our Website or in our Application. By continuing to use our Website or Application after the changes come into effect means that you agree to be bound by the revised policy.
If you have any questions, comments or requests regarding personal data, please address them to:
Joe Kawai ([email protected]), Data Protection Officer
Last updated:4th June 2021