Last Updated: 15th July 2019
Kotak Network Pte Ltd (KNPL, we, us, our) complies with the Singapore Personal Data Protection Act 2012 (Act) and the General Data Protection Regulation of the European Union (GDPR). We care about how your personal data is used and shared, and we take your privacy seriously.
For the purposes of the GDPR, our customers are the data controller when storing or otherwise processing User Data that we hold solely for the purpose of providing our SaaS service and we are the data processor. We are the data controller when storing or otherwise processing User Data that we use for our own purposes.
Personal data is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
This policy does not limit or exclude any of your rights under the Act or the GDPR. For further information on the Act, see https://www.pdpc.gov.sg/Legislation-and-Guidelines/Personal-Data-Protection-Act-Overview. or further information on the GDPR, see https://ec.europa.eu/info/law/law-topic/data-protection_en.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal data. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to firstname.lastname@example.org.
- What personal data is collected
1.1 When you use our Website, any services we provide or in your interaction with us, the personal data we may collect includes:
(a) Data collected directly from you. This may be done through this Website, over the phone, by email, or in person. Some of the personal data that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal data. While you do not have to provide us with some of the information that we may request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our products or services to you. If you require further information about the consequences of not providing us with any information, please contact us at email@example.com.
- If you register for, or login to, an account on our website or related services, we collect your name, email address, user name, password, phone number, demographic information, date of birth, address, location and any other information we require or ask for to set you up with an account. We may collect some of this information using third party authentication services (as described further in the from third party sources section below).
- When you fill in a contact or enquiry form on our website, use our live chat service, call us, meet us in person or otherwise contact us, we collect your name, email address, and phone number and any other information you choose to provide to us.
- When you purchase products or services from us, we collect your name, email address, phone number, address, business information and any other information you submit to us for billing and for the purposes of providing you our service.
- When you purchase products or services from our Merchants/Customers that they need to physically deliver to you, we collect your delivery instructions and any other information you submit to us for delivery purposes.
(b) Data collected from third party sources. Where possible, we collect personal data from you directly. However, sometimes we may collect:
- personal data that is publicly available
- personal data about you from our trusted advertising partners which may include demographic information, browsing history, location and online behavioural or profile information
- personal data included in User Data.
We may combine the personal data about you that we receive from third parties with the personal data we collect from you directly or with device and usage data we collect automatically when you visit our website.
- How is the personal data used
2.1. We may use your personal data to:
- verify your identity
- provide our website, products and services to you
- market our products and services to you, including contacting you electronically (e.g. by text or email for this purpose)
- improve our website, products and services
- internal research, product and services development, including automating aspects of our products and services
- publish things on our website
- run promotions (e.g. referral and loyalty programs, surveys and contests)
- bill you and collect money that you owe us, including authorizing and processing credit card transactions
- respond to communications from you, including enquiries, disputes and complaints
- conduct research and statistical analysis (on an anonymized basis)
- tailor content or advertisements on our website to you
- protect and/or enforce our legal rights and interests, including defending any claim
- respond to lawful requests by public authorities, including to comply with law enforcement requirements, or
- for any other purpose anonymized by you or applicable law.
2.3. Your personal data may also be anonymized for use by KNPL for other purposes.
2.4. We may transfer your information in the case of a sale, merger, consolidation, liquidation, re-organization or acquisition.
2.5. You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails.
- Disclosure of information
3.1. We will not sell your personal data to third parties.
3.2. We will only disclose your personal data to third parties where you have provided us consent, and in the situations expressly set out in in this Policy. If you have consented to receiving marketing information from us, our strategic partners and business associates, we will be disclosing your personal data to them.
3.3. Your personal data may be disclosed and shared within KNPL to allow us to provide the products and services which you have requested.
3.4. We may disclose or share your personal data with third parties who provide necessary services to us, such as:
- service providers and data processors working on our behalf and providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check, etc.; and
- our consultants and professional advisers including our accountants, lawyers and auditors.
3.5. We will also disclose your personal data to third parties in order to comply with legal obligations or industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities.
3.6. Our website may have the functionalities to allow you to share your personal data with other third parties such as other users of our website. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the website.
- International Transfers of Personal Data
4.1 A business that supports our website, products and services may be located outside of Singapore (the country where we are incorporated) and also outside of the country where you are located. This means that the personal data we collect may be transferred to, and stored in, a country outside of Singapore and the country where you are located.
If you are located in the European Economic Area (EEA), your personal data may be transferred outside of the EEA. Under the GDPR, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data if other appropriate safeguards are in place.
Where we transfer personal data outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where approved transfer mechanisms are in place to protect your personal data (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses. For further information, please contact at firstname.lastname@example.org.
4.2. You fully understand and consent that we may transfer your personal data to any location outside of Singapore for the purposes set out in this paragraph 3. When transferring your personal data outside of Singapore we will protect your personal data to a standard comparable to the protection accorded to your personal data under the Singapore Personal Data Protection Act 2012 by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data.
- Protecting your personal data
5.1 As required by applicable law, we will take steps to keep your personal data safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal data.
5.2 You play an important role in keeping your personal data secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not share your account access and/or disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
- Accessing or correcting your personal data
Subject to certain grounds for refusal under applicable law, you have the right to access your personal data that we hold and to request a correction to your personal data. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal data relates.
Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal data, we will make the correction. In all other cases, we will take reasonable steps to make a note of the personal data that was the subject of your correction request.
If you want to exercise either of the above rights, email us at email@example.com. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal data to be corrected and the correction that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal data or correcting that information.
- Other rights
- Internet Use
8.1 While we take reasonable steps to maintain secure internet connections, if you provide us with personal data over the internet, the provision of that information is at your own risk.
8.2 Our websites may contain links to other websites which are not owned or maintained by us. When visiting these third-party websites or disclosing your personal data to third parties (including buyers or sellers on our website), you should read their privacy policies, or ask relevant questions before you disclose your personal data. We are not responsible for the collection, use or disclosure of your personal data by such third parties.
5.1. We do not intend to collect personal data from or about children aged under 16. If you have reason to believe that we have collected personal data from or about a child under the age of 16, please contact us at firstname.lastname@example.org.
- Social Networks
6.1. Our website and mobile or web-based applications may provide you with social plug-ins from various social networks (such as Facebook and Twitter). If you choose to interact with a social network, your activity on our website or via our mobile or web-based applications will also be made available to social networks such as Facebook and Twitter.
6.2. If you are logged in on one of the social networks during the visit of one of our websites or mobile or web-based applications, the social network might add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter one of our websites or mobile or web-based applications.
6.3. We cannot influence this data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.
- Geo-location Services
7.1. Our website and mobile or web-based applications may offer location-enabled services, such as Google Maps or APIs by third-party providers and social services. If you use those mobile or web-based applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You are always asked if the geo-location service can be activated and you can also object to this geo-location service within the respective mobile or web-based application.
8.1. We endeavor to take precautions to ensure that the information you have provided is protected against unauthorized or unintended use, access or disclosure. However, we cannot be held responsible for unauthorized or unintended use, access or disclosure that is beyond our control.
9.1. To the maximum extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your personal data.
- Changes to this Policy
10.1 We may change this Policy from time to time. The amended Policy will be available on our Website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 15 July 2019.
- Your Rights
11.1 If you have any questions about the processing of your personal data or about our Policy, if you do not accept the amended Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your personal data, you are welcome to contact our Data Protection Officer. The contact details are:
Kotak Network Pte Ltd - Data Protection Officer
80 Changi Road, Centropod #05-13, Singapore 419715
11.2. Subject to certain grounds for refusal under applicable law, you have the right to access your personal data that we hold and to request a correction to your personal data. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal data relates. All requests for correction or for access to your personal data must be in writing. We will endeavor to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
.3. Subject to applicable law, we may charge you a fee for responding to your request for access to the personal data which we hold about you, or for information about the ways in which we have (or may have) used your personal data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
12.1. You may send complaints regarding our handling of personal data in the following ways:
in writing or by email. Such complaints must:
- be addressed to KNPL Data Protection Officer at:
Address: 80 Changi Road, Centropod #05-13, Singapore 419715
- provide the name, contact number and address of the person submitting the feedback
- provide the relevant details required such as the relevant time period, our employees or who involved, or copies of relevant documents.
12.2. All complaints will be evaluated by us in a timely manner. After KNPL has completed its evaluation, the Data Protection Officer (or a duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.
- Governing Law
13.1. This Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.
GDPR ADDITIONAL TERMS
lAWFUL basis for PROCESSING PERSONAL data
Our lawful basis for processing (as that term is defined in the GDPR) personal data that we collect, use and disclose depends on the personal data collected and the context in which we collect it.
Generally, we collect personal data from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms).
Where we process personal data based on your consent, you may withdraw your consent at any time. Despite this, we may process your personal data where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal data or need further information, please contact us at email@example.com.
Your rights under the gdpr
If you are located in the European Union, your rights in relation to your personal data include:
- right of access - if you ask us, we will confirm whether we are processing your personal data and provide you with a copy of that personal data
- right to rectification - if the personal data we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal data is rectified. If we have shared your personal data with any third party, we will tell them about the rectification where possible
- right to erasure – when your personal data is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal data and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal data
- right to withdraw consent - if the basis of our processing of your personal data is consent, you can withdraw that consent at any time
- right to restrict processing - you may request that we restrict or block the processing of your personal data in certain circumstances. If we have shared your personal data with any third party, we will tell them about this request where possible
- right to object to processing - you may request that we stop processing your personal data at any time and we will do so to the extent required by the GDPR
- rights related to automated decision-making, including profiling - you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making.
- right to data portability - you may obtain your personal data from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal data in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal data directly to another data controller
- the right to complain to a supervisory authority - you can report any concern you have about our privacy practices to your local data protection authority.
Where personal data is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please contact us at firstname.lastname@example.org. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.
By continuing to use our website and related services, you indicate your agreement for us to use the cookies described below.
WHAT ARE COOKIES
Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website. Cookies can be recognised by the website that downloaded them, or by other websites that use the same cookies. This helps a website know if the browsing device has visited that or other websites before.
Cookies can be used to collect information relating to your use of a website or your device, let you navigate between pages effectively, help to remember your preferences and generally improve your browsing experience. Cookies can also help ensure advertising you see online is more relevant to you and your interests.
Cookies can be session or persistent cookies. Session cookies are temporary and only stay on your browser until you stop browsing. Persistent cookies stay on your device until they expire or are deleted.
The cookies used on our website may be first party cookies (i.e. set by us) or third-party cookies (i.e. cookies set on our website by a person other than us). The third-party companies that place cookies on our website will have their own privacy policies.
WHAT Types of cookies DO we use
The types of cookies used by us, and most websites, can generally be categorised as follows.
Strictly necessary cookies
These cookies are essential for the full functionality of our website and related services. They enable you to navigate around our website and services and use their features e.g. accessing secure areas and enabling services that you have asked to receive. If you opt out of these cookies, you may not be able to access all the functions of our website and some services that you have asked to receive.
These cookies do not track where else you have been on the internet and do not remember your preferences beyond your current visit. These cookies are generally first party session cookies which will expire when you close your browsing session. These cookies do not collect information that could be used for marketing purposes.
These cookies allow a website to remember choices you make and provide enhanced, more personal features. e.g. these cookies allow us to remember the settings you have applied to the website (such as font size, preferences or colours), identify whether you are a returning website visitor and present you with a personalised version of the website, or eliminate the need for you to re-enter your login details. The information these cookies collect is generally anonymous and they do not track your browsing activity on other websites. These cookies may be first or third party, session or persistent cookies.
These cookies collect information about how you use a website, e.g. which pages are the most visited and if you receive any error message from any page. This information helps us improve the way our website and related services work and helps us manage the performance and design of the website and services. These cookies do not gather information that identifies you. All of the information these cookies collect is aggregated and anonymous. These cookies may be first or third party, session or persistent cookies.
Targeting cookies are used to present advertising that is relevant to you and your interests. These cookies collect information about your browsing habits e.g. the pages you have visited and the links you have followed across the internet. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. These cookies will usually be persistent but time-limited and may be placed on our website by third party service providers or advertising partners with our permission.
We use targeting cookies to present interest-based advertising on our website and for retargeting. This is a form of interest-based advertising that enables our advertising partners to build a profile of your interests and show you advertising based on your browsing activity across the internet, including to allow us to advertise to people who previously visited our website.
We use Google Analytics to collect information about visitors to our website. Google Analytics collects information related to your device, browser, IP address, network location, and website activities to measure and report statistics about your interactions on our website. We use this information to help us manage the performance and design of our website and to improve our website.
We use Google Analytics Advertising Features, including Remarketing with Analytics, Demographic and Interests reporting in Analytics and Google Ads.
We also use LinkedIn Insight Tag and Facebook Pixels for retargeting ads, and FullStory, Head Analytics, LuckyOrange and Heap Analytics to collect information about visitors to our website. Also, we use Crisp cookies for customer support and lead generation.
How to control or OPT OUT OF cookies AND TARGETED ADVERTISING
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. However, if you do this, you may have to manually adjust some preferences every time you visit our website and attempt use our services, you may not be able to access certain parts of our website or services, and some functionalities may not work.
You can find out more information about how to change your browser cookie settings at www.aboutcookies.org.uk.
To learn more about how to control cookie settings through your browser:
- click here to learn more about the Private Browsing setting and managing cookie settings in Firefox
- click hereto learn more about Incognito and managing cookie settings in Chrome
- click here to learn more about InPrivate and managing cookie settings in Internet Explorer
- click here to learn more about Private Browsing and managing cookie settings in Safari.
You may opt out of targeted advertising at http://www.youronlinechoices.eu/. You can learn more about interest-based advertising and opt out of interest-based advertising from participating online advertising companies at the following links.
- Network Advertising Initiative (NAI) – http://optout.networkadvertising.org/
- Digital Advertising Alliance (DAA) – http://optout.aboutads.info/
- Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
- DAA AppChoices page – http://www.aboutads.info/appchoices
Please note that opting out of interest-based advertising does not mean you will no longer be served advertising. You will continue to receive generic ads.
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