December 5, 2018
XMO Pte Ltd and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”) pledges to meet fully with the requirements of the Personal Data Protection Act 2012 (the “PDPA”). In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via https://book2use.com, its sub-domains, and any other websites, media platforms, or applications including the Mobile Application operated by the Company (hereinafter collectively referred to as the “Channels”) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (the “User” or the “Users”), except to the authorised persons listed in Paragraph 3 below.
1. Purpose of Collection of Personal Data
1.1 In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to benefit from and enjoy the various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so.
1.2 The Company’s purposes for collection of information and data on the Channels include but are not limited to the following:
(a) to perform the daily operation of the services provided to Users;
(b) to identify Users who have posted advertisements, materials, messages, photos, views, or comments or such other information (collectively “Information”) on the Channels;
(c) to identify Users who have viewed the Information posted on the Channels;
(d) to provide Users with marketing and promotional materials for their enjoyment of benefits as members of the Channels (for further details, please refer to Paragraph 4 entitled “Subscription of Newsletter/Promotional Materials/Marketing Materials” below);
(e) to identify Users who have enjoyed their benefits as members of the Channels by receiving and using marketing and promotional materials;
(f) to provide Users with a platform and forum for posting photos and sharing and discussing their insights;
(g) to allow members of the Channels to enjoy their benefits as members by enrolling for special events hosted by the Company;
(h) to enable the Company to select and present information that matches the needs of Users or to create personalised contents;
(i) to design and provide products and services to Users in relation to the above purposes;
(j) to compile and analyse aggregate statistics about Users’ use of the Channels and service usage by Users for the Company’s internal use; and
(k) to facilitate the Company use of Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events, and/or promotions of the Company and/or its clients.
1.3 The Company strives to collect only personal data which is necessary and adequate but not excessive in relation to the purposes set out above.
1.4 If the User is under the age of twenty-one (21), the Company strongly recommends that he or she seeks prior consent from a parent or guardian, who may contact the responsible personnel of the Company at email@example.com to register the User as member of the Channels.
1.5 If the Company requires the User’s personal data for a purpose other than those set out hereinabove, the Company may request the User’s prescribed consent to the same. If the User is a minor, the prescribed consent should be given by his or her parent or guardian.
2. Collection of Personal Data
2.1 The Company may collect personal information and/or data about the User, such as his or her name, login ID and password, address, email address, phone number, age, sex, date of birth, country of residence, nationality, education level, and work experience that is not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from the User in connection with contests, surveys, or special offers.
2.2 Only duly authorised staff of the Company will be permitted to access the User’s personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Paragraph 3 entitled “Disclosure or Transfer of Data”.
3. Disclosure or Transfer of Data
3.1 The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following conditions.
Generally speaking, the Company will only disclose and/or transfer the User’s personal information and/or data to the Company’s personnel and staff for the purpose of providing services to the User. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances:
(a) where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorised by the Company to use such information and/or data and who will facilitate the services on the Channels, under a duty of confidentiality;
(b) where the information and/or data is disclosed and/or transferred to any agents or associates of the Company who have been duly authorised by the Company to use such information and/or data;
(c) where the Company needs to protect and defend its rights and property;
(d) where the Company considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Channels; and
(e) where the Company deems necessary in order to maintain and improve the services on the Channels.
3.2 Personal data collected via the Channels may be transferred, stored, and processed in any country in which the Company operates. By using the Channels, the User is deemed to have agreed to, consented to, and authorised the Company to disclose and/or transfer his or her personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the User’s country.
4. Subscription to Newsletter, Promotional Materials, or Marketing Materials
4.1 The Company may from time to time send to members and Users of the Channels newsletters, promotional materials, and marketing materials based on the personal information and data that they have provided to the Company. The Company may use the User’s data in direct marketing and the Company requires the User’s consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
(a) the name, login ID and password, contact details, age, sex, date of birth, country of residence, nationality, education level, and work experience of the User held by the Company from time to time may be used by the Company and/or its authorised personnel or staff in direct marketing;
(b) the following classes of services, products, and subjects may be marketed:
(i) Enhancement of services provided by Book2Use mobile app.;
(ii) products and services offered by the Company and its advertisers (the names of such entities can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); or
(iii) donations and contributions for charitable and/or non-profit making purposes;
(b) the above products, services, and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or:
(i) third party service providers providing the products, services, and subjects listed in Paragraph 4.1(b) above; and
(ii) charitable or non-profit marking organisations;
(c) in addition to marketing the above services, products, and subjects itself, the Company also intends to provide the data described in Paragraph 4.1(a) above to all or any of the persons described in Paragraph 4.1(b)(ii) above for use by them in marketing those services, products, and subjects, and the Company requires the User’s written consent (which includes an indication of no objection) for that purpose; and
(d) the Company may receive money or other property in return for providing the data to the other persons in Paragraph 4.1(b)(ii) above and, when requesting the User’s written consent as described in Paragraph 4.1 above, the Company will inform the User if the Company receives any money or other property in return for providing the data to the other persons.
4.2 Suitable measures are implemented to make available to such members the options to opt out of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the registration or user account maintenance webpage, or by clicking on the automatic link appearing in each newsletter/message, or by contacting the Customer Service Representative of the Company at 67784985 or email to firstname.lastname@example.org.
5.1 Any User is entitled to request access to or make amendments to his or her own personal information and data kept with the Company by contacting the Customer Service Representative of the Company at 67784985 or email to email@example.com.
5.2 In the event that a User wishes to access or amend his or her personal information and data, the Company may request him or her to provide personal details in order to verify and confirm his or her identity. An identity card number or passport number or company registration number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to a User’s request within five (5) days of his or her request and will endeavor to do so wherever possible.
6. Cookies and Log Files
6.1 The Company does not collect any personally identifiable information from any User whilst they visit and browse the Channels, save and except where such information of the User is expressly requested. When Users access the Channels, the Company records their visits only and does not collect their personal information or data. The Channels’ server software will also record the domain name server address and track the pages the Users visit and store such information in cookies, and gather and store information like Internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring.
6.2 The Company and third-party vendors engaged by the Company use the Company’s cookies and third-party cookies, such as the Google Analytics cookies, together to inform, optimise, and serve marketing materials based on the Users’ past visits to the Channels.
6.3 The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns, and administer the Channels. Such automatically collected information and data will not be disclosed save and except in accordance with the Paragraph 3 entitled “Disclosure or Transfer of Data”
7. Google Analytics
7.1 Google Analytics Advertising Features (“Features”) are implemented on the Channels. The Features which the Company has implemented are based on Google Analytics Demographics and Interest Reporting.
7.2 Google Analytics is a web analysis service provided by Google which utilises the data collected to track and examine the use of the Channels to prepare reports on the Users’ activities and share them with other Google services. Google may use the data collected to contextualise and personalise the marketing materials of its own advertising network.
7.3 Users can opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
8. Links to Other Websites, Media Platforms, or Applications
8.1 The Channels may provide links to other websites, media platforms, or applications which are not owned or controlled by the Company. Personal information and data from Users may be collected on these other websites, media platforms, or applications when Users visit such websites, media platforms, or applications and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Channels which grants Users access to another website, media platform, or application, the protection of Users’ personal information and data which are deemed to be private and confidential may be exposed in these other websites, media platforms, or applications.
9.1 The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data is protected against unauthorised access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect, and secure Users’ personal information and data.
9.3 The Company uses third-party payment gateway service providers to facilitate electronic transactions on the Channels. Regarding sensitive information provided by Users, such as credit card numbers for completing any electronic transactions, the web browser and third-party payment gateway communicate such information using secure socket layer technology (SSL).
9.4 The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while the Company strives to protect Users’ personal information and data against unauthorised access, the Company cannot guarantee its absolute security.
10. Retention of Personal Data
Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company after deactivation of the relevant service until the User requests the Company in writing to erase his or her own personal information and/or data from the Company’s database or to terminate his or her membership of the Channels.
12. Governing Law and Jurisdiction
For any query, please contact our Customer Service Representative by email to firstname.lastname@example.org.