1. IMPORTANT INFORMATION AND WHO WE ARE
The Website is not intended for children and we do not knowingly collect data relating to children.
ZOS Platform LTD is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).
This version was last updated on 1/1/2019.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. WHAT INFORMATION DO WE COLLECT?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Information You Give Us: We receive and store any information you enter on our Website. You provide most such information when you search some information on our Website, subscribe to our newsletters, fill out a form for any media, events or partnership inquiries, communicate with our support service. For example, you provide information when you communicate with us by post, e-mail, or otherwise. As a result of those actions, you might supply us with such information as your name, address, e-mail, phone numbers, etc.
Automatic Information: We receive and store certain types of information whenever you interact with us. For example, like many websites, we use "cookies," and we obtain certain types of information when your Web browser accesses our Website.
Information from Other Sources: We might receive information about you from other sources and add it to our account information.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. However, Aggregated Data is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you. We will collect and process the following data about you:
Information you give us. This is information about you that you give us by filling the forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• subscribe to our publications or newsletters; or
• enter a competition, promotional action or survey; or
• give us some feedback; or
• communicate with our support services; or
• do any other actions through our Website.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
(a) analytics providers such as Google;
(b) advertising networks; and
(c) search information providers.
4. HOW WE USE YOUR PERSONAL DATA ？
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
If you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
• To enable you to partake in a prize draw, competition, promotional activity or complete a survey, the data of your identity, contact, usage, marketing and communications is necessary for our legitimate interests (to study how users use our services, to develop them and grow our business).
• To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data), the technical data is necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud) and to comply with a legal obligation.
• To deliver relevant website content to you，the data of usage, marketing and communications and technical is necessary for our legitimate interests (to study how users use our services, to develop them, to grow our business and to inform our marketing strategy).
• To use data analytics to improve our website, services, marketing, customer relationships and experiences, the data of usage and technical is necessary for our legitimate interests (to define types of customers for our services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy).
• To discuss possible partnership and marketing cooperation, the data of your identity, contact, marketing and communications is necessary for our legitimate interests (to promote our products and services).
You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies you may not be able to use certain features and functions of our websites.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via e-mail [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• Third Parties who developed the Website and organize promotional and marketing activities.
• Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
We share your personal data with our contractors to fulfill the purposes we collected it for. This will involve transferring your data outside Singapore. These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax and other purposes.
However, we ensure your personal data is protected by requiring all our contractors to follow the same rules when processing your personal data.
Please contact us via e-mail [email protected]. if you want further information on the specific mechanism used by us when transferring your personal data out of Singapore.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. The transmission of data over the internet (including by e-mail) is never completely secure. So, although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances you can ask us to delete your data (Request erasure).
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:
Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us via e-mail [email protected].
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent, if one of the other legal bases is applicable.
We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way we use your personal information or any changes to the laws and regulations applicable to us. We will make available the updated policy on our web sites. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.