The Services may contain links to or information about third party websites that are not within our control. We are not responsible for the privacy practices of any external website or mobile application.
B. Personal Information We Collect
"Personal Data" or "Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
We may collect and receive information from You when You register for an Account with us, when You use the features and functions on our Services, when You connect Your Account to an external third party service/application or when You contact us. The following information may be collected and processed:
- Date of birth
- Email address
- Phone number
- Transaction information (e.g. credit or debit card details, bank account information)
- Account information, such as username, password, and other identifiers or credentials used to access our Services
- Username and password
- Any other information required by us as determined in our sole discretion.
- Any information provided by You when contact the Company or otherwise share with the Company before, during or after the termination of Your Account.
Please note that in using our Services we may also automatically collect the following information from You:
- Your Internet Protocol (“IP”) address
- Your locations
- Information about Your browsing activity such as Your browser type, Internet service provider, referring/exit pages, the files viewed on the Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream datal
- Device information (such as hardware model and serial number)
- Any communications between You and another user of our Services
C. USE OF PERSONAL DATA
We may use Your Personal Data for any and all of the following purposes:
- to verify Your identity, update our records and generally maintain Your Account with us;
- to facilitate, confirm and/or provide updates or notifications in relation to any transactions;
- to verify and process transactions (including payment, collecting and managing the proceeds of the Services) and to arrange for delivery of items;
- to contact You in cases of emergency;
- to carry out additional services for billing and settlement for the provision of the Services;
- to outsource some operations including the provision of the Services and the collection of Service fees;
- to update and inform You on new products, features, services and after-sales follow-up;
- to update and inform You on marketing and promotional activities - if You wish to unsubscribe to the processing of Your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message;
- to conduct polls, surveys, analysis and research on our Services to improve and personalize our Services;
- to respond to, handle, and process queries, requests, applications, complaints, and feedback from You;
- to protect and ensure the technical functionality, security and integrity of the Services including conducting data analysis, testing, monitoring and analyzing usage and activities and performing network or service enhancement;
- for accounting, risk management and record keeping purposes;
- for internal business purposes, including marketing, sales promotion, research, analysis, testing and auditing
- to comply with applicable legal obligations and other rules, regulations, codes of practice and orders and directions of the relevant governmental authorities;
- to prevent, detect, investigate or monitor any frauds, threats, misconduct or other prohibited content, businesses or activities;
- to process or resolve any disputes arising from or in connection with our Services;
- to protect our rights and property and the rights, property and safety of others;
- any other purposes which we notify You of at the time of obtaining Your consent.
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
(collectively, the “Purposes”)
The Purposes listed may continue to apply even in situations where Your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with You).
D. DISCLOSURE OF PERSONAL DATA
We may share and permit the sharing of Your Personal Data with third parties and our affiliates for any of the abovementioned Purposes. In sharing Your Personal Data with them, we endeavour to ensure that the third parties and our affiliates keep Your Personal Data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain Your Personal Data only for as long as they need Your Personal Data to achieve the abovementioned purposes.
We may share your Personal Data with the following categories of third parties:
- Our business partners, service providers, professional advisers, vendors and agents who assist us in performing certain aspects of our Services (including processing transactions, carrying out compliance check, data storage, management and analysis, maintenance of the Services, legal, audit, insurance and marketing services). These parties will only have access to Your Personal Data to the extent necessary to perform their functions.
- Our potential investors, purchasers and commercial counterparties. We may share Your Personal Data with any person who wishes to invest in Company or whom we intend to enter into a business combination with (such as a purchase, sale, lease, merger or amalgamation, or any other acquisition, disposal or financing).
- Any third party claimants or potential third party claimants.
- Financial institutions, Your card issuing bank or payment service provider in respect of any issues arising from or in connection with a transaction through our Services.
- Governmental and regulatory authorities: We may share Your Personal Data with competent governmental and regulatory agencies in Singapore or other countries, including investigating officers and judicial authorities in the relevant jurisdictions.
We may also share Your Personal Data with other third parties if You have separately consented to such disclosure. In such case, any information which we share with such third parties shall be used for the purposes described when we obtained Your consent.
We may disclose Your Personal Data if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property or personal safety of any person. We may be prevented from obtaining Your consent for, or informing You of, such disclosure. Any information which we share in this circumstance shall be used for the purposes required or permitted under the applicable laws or regulations
E. TRANSFER OF PERSONAL DATA
F. RETENTION OF PERSONAL DATA
We may retain Your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain Your Personal Data, or remove the means by which the data can be associated with You, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
G. PROTECTION OF PERSONAL DATA
All information collected in connection with any of our Services (including information generated by cookies about Your use of the Websites) will be stored electronically on the server of our service provider in Singapore with appropriate safeguards and security measures. However, there is no guarantee that information stored by us or on our behalf may not be accessed, collected, used, disclosed, copied, modified or deleted by unauthorised parties by breach of any technical or operational safeguards in place. We will not be keeping physical files of any Personal Data.
No data transmitted via the internet can be guaranteed to be wholly secure during transmission. As such, we cannot warrant the security of any information You transmit to us or which we transmit to You before its receipt and any transmission is at Your own risk. It is important that You protect against unauthorised access of Your Account and information by choosing Your password carefully, and keeping Your password and Account secure (e.g. by signing out after using our Services).
You are at all times responsible for Your own internet privacy settings. We are not responsible for the functionality, privacy or security measures of any other organisation or third-party websites, applications or services.
H. WITHDRAWAL OF CONSENT
The consent that You provide for the collection, use and disclosure of Your Personal Data will remain valid until such time it is being withdrawn by You in writing. You may withdraw consent and request us to stop using and/or disclosing Your Personal Data for any or all of the purposes listed above by submitting Your request in writing or via email to our Data Protection Officer at the contact details provided below. However, please note that any withdrawal of Your consent may have consequences, including Your inability to use the Services.
Upon receipt of Your written request to withdraw Your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with You) for Your request to be processed and for us to notify You of the consequences of us acceding to the same, including any legal consequences which may affect Your rights and liabilities to us. In general, we shall seek to process Your request within ten (10) business days of receiving it.
Whilst we respect Your decision to withdraw Your consent, please note that depending on the nature and scope of Your request, we may not be in a position to continue providing our goods or services to You and we shall, in such circumstances, notify You before completing the processing of Your request. Should You decide to cancel Your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
I. ACCESS TO AND CORRECTION OF PERSONAL DATA
You can manage available communication preferences when You access the Website by updating Your account preferences, or, where applicable, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that You receive from us.
Subject to exceptions under applicable law and regulations, You may request access to Your Personal Data that we collected in connection with the Services and information about how we have used and disclosed Your Personal Data within a year before Your request. Subject to exceptions under applicable law and regulations, You may also request to review, correct or delete any of that Personal Data. Additional rights may also apply under applicable laws. We reserve the right to charge a nominal fee in respect of our costs in processing Your request for access to Personal Data.
If You wish to make (a) an access request for access to a copy of the Personal Data which we hold about You or information about the ways in which we use or disclose Your Personal Data, or (b) a correction request to correct or update any of Your Personal Data which we hold about You, You may submit Your request in writing or via email to our Data Protection Officer at the contact details provided below. In order to facilitate processing of Your request, it may be necessary for us to request further information relating to Your request. To protect Your privacy and security, we will take reasonable steps to verify Your identity before processing any access or correction request or withdrawal notice under this section.
Please note that a reasonable fee may be charged for an access request. If so, we will inform You of the fee before processing Your request.
We will respond to Your request as soon as reasonably possible. Should we not be able to respond to Your request within thirty (30) days after receiving Your request, we will inform You in writing within thirty (30) days of the time by which we will be able to respond to Your request. If we are unable to provide You with any Personal Data or to make a correction requested by You, we shall generally inform You of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
J. UPDATING YOUR PERSONAL DATA
We generally rely on Personal Data provided by You (or Your authorised representative). It is important that the Personal Data You provide to us is accurate, complete and up to date. In order to ensure that Your Personal Data is complete, accurate and up to date, please update us if there are changes to Your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below. In the event You believe that the Personal Data we have about You is inaccurate, incomplete, misleading or out of date, please also inform us.
L. CONTACT INFORMATION
You may contact our Data Protection Officer if You have any enquiries or feedback on our Personal Data protection policies and procedures, or if You wish to make any request, in the following manner:
DIGITAL ENTERTAINMENT ASSET PTE. LTD.
FORMLATED ON: 2019.11.28
LAST UPDATED ON: 2020.4.15