Last Updated: November 2021
(a) the kinds of information we collect and why we collect it;
(b) how we use that information;
(c) how we protect that information; and
(d) how you can update that information or limit or control how it is used.
1.3 Authority. For the purposes of this Policy, "you" and "your" mean you as the user of our Services and/or Platforms, whether as a client or an expert. If you use our Services and/or access our Platforms on behalf of a company, organisation or other entity, then:
(a) "you" includes you and that entity;
(b) you represent and warrant that you are an authorised representative of the entity with the authority to bind the entity to this Policy and that you agree to this Policy on the entity's behalf, and
(c) your entity is legally and financially responsible for your use of our Services as well as for the use of your account by others affiliated with your entity, including any employees, agents or contractors.
1.4 Acknowledgement and Consent. By interacting with us, visiting our Platforms, or accessing our Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Policy (as updated from time to time), and you hereby consent to us collecting, using, disclosing, and/or processing your Personal Data as described herein.
Questions, comments, and queries regarding this Policy are welcome and should be addressed to our data protection officer (the "Data Protection Officer"), addressed to our data protection officer, at firstname.lastname@example.org
1.5 Policy Updates. Our Policy may be revised from time to time to reflect changes in the law or technology or changes in our practices regarding information collection and use. If we make material revisions to the way we collect or use your Personal Data so that we are using it for purposes or sharing data with third parties that you have not consented to, we will provide you with notice of those changes and may do so by publishing the change through on the respective DENARE Platforms. You agree that we may notify you about material changes in the way we treat Personal Data by publishing an updated Policy on the DENARE Platforms.
2. INFORMATION THAT DENARE COLLECTS
2.1 Purpose. We collect information to provide better Products and Services to all users of our Platforms, including determining what types of content, Products, and Services offered on our Platforms are of the most interest and relevance to you. We use the order information that we collect generally to fulfil any orders placed through our Platforms (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
2.2 Personal Data. For the purposes of this Policy, "Personal Data", otherwise known as "Personal Information", shall be deemed to include data, whether true or not, about an individual who can be identified (a) from such data; or (b) from that data and other information to which the organisation has or is likely to have access. Personal Data generally includes your full name, identification number or passport number, photograph or video image, mobile telephone number, personal email address and residential address.
2.3 Information We Collect. We collect information directly from users of the Platform, automatically when you use or interact with our Platforms and/or when you use our Services and/or access our Platforms whether as an expert or as a client. We may collect, store and process your Personal Data, including:
(a) Personal Data Given by You. Personal Data provided by you such as Personal Information provided by you when you create an account, purchase any Services or Products, and/or interact with our Platforms.
(b) Personal Data Collected from Your Use of our Platforms. Personal Data is generated from information that we collect from your interaction with the Platforms, such as the services you use and your activity on our Platforms. This information includes, but is not limited to:
(I) Device Information. We collect information about the devices you use to access our Platforms, such as hardware settings, browser type, browser language, the date and time of your request, and referral URL.
(ii) Log Information. When you use our Platforms, we automatically collect and store certain information in server logs, which automatically record certain information when you use our Platforms, including the following:
(A) details about how you have used our Platforms, such as your search queries;
(B) your IP address, which is the number assigned to an Internet-connected device such as a tablet or smartphone and used to identify the geographic location of that device; and
(C) cookies that may uniquely identify your browser and collect information about how our visitors interact with our Platforms, as well as help us identify problems such as error messages from certain pages.
(iii) Payment Information. We may collect and generate payment information and transaction information (such as records of services purchased on our websites). We use this information to respond to and fulfil requests, improve our Product and Service offerings, communicate with you, tailor our marketing efforts, and for internal reporting purposes.
(iv) Audio and Visual Information. We receive any digital photos you share with us through our Services. We may also record customer service telephone calls for quality purposes and to meet our legal obligations.
(v) Privacy Choices. We receive and retain any opt-outs or other choices related to how we collect and disclose Personal Data.
(vi) Device Information. We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information, including phone number).
(vii) Location Information. We may collect and use real-time geolocation information when you interact with our Platforms.
2.4 Personal Data of Minors and Children. Except where otherwise indicated, we do not knowingly collect or store any Personal Data from children under the age of eighteen (18). If a parent or guardian becomes aware that his or her child under the age of eighteen (18) has provided us with information without his or her consent, he or she should contact our Data Protection Officer. Subject to the applicable laws, we will delete such information from our files within a reasonable period of time. We may, using our discretion, also delete Personal Data from our websites, as well as posts and other information, from users we believe are under the age of eighteen (18).
3. HOW WE USE PERSONAL DATA THAT WE COLLECT
3.1 Purpose. We use the information and Personal Data that we collect from users of our Platforms in order to improve your overall experience as a user as well as the quality of our Products and Services. We will use your Personal Data for legitimate purposes in connection with our business, including but not limited to:
(a) ensuring that your identity is verified, including distinguishing you from another person with the same or similar details as yourself;
(b) handling, processing and responding to any queries, requests, applications, complaints, or feedback from you;
(c) executing our system administration and reporting aggregate information to third-party service providers and potential business partners. This relates to statistical data about our user's browsing actions and patterns, and does not specify any individual;
(d) carrying out our Services and any reasonable business activities such as audits, risk management, or business reporting;
(e) complying with any internal policies, applicable laws, regulations, or to assist with any law enforcement or investigations conducted by any governmental and/or regulatory authority;
(f) improving our Products and Services and/or our Platforms;
(g) ensuring that content from our Platforms is presented in the most effective manner for you and for your device;
(h) providing you with information, Products, or Services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
(i) carrying out our obligations arising from any contracts entered into between you and us;
(j) administering any dispute resolution processes or to enforce or defend our rights, contractual or otherwise, including investigations and participating in potential or actual litigation, arbitration, or other legal processes;
(k) notifying you about changes to our Products and Services and/or our Platforms;
(l) processing any payment or credit transactions and/or performing our Services;
(m) promoting and marketing DENARE, our Products, Services, and our websites;
(n) drawing inferences about your preferences to help us provide you with personalised content and to help us improve our Services; and
(o) such other legitimate purposes as may be associated with our business from time to time.
By providing such information, you hereby acknowledge and consent that your Personal Data can be used by DENARE, its partners, and other service providers.
3.2 Non-Exhaustive List. You acknowledge, agree, and consent to the processing of your Personal Data and understand that the list provided above is not exhaustive.
3.3 Third-Party Use. We may also use your Personal Data or permit selected third parties to use your Personal Data, to provide you with information about goods and services which may be of interest to you and we or they may contact you about these by email, post, or telephone.
3.4 Aggregate Data. We may provide our business associates, partners, or advertisers with aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the Personal Data we have collected from you to enable us to comply with our business associates', partners', or advertisers' wishes by displaying their advertisement to that target audience.
3.5 Continuation. We may continue to use your Personal Data even in a situation where the use of our Products, Services and/or Platforms, or any contractual obligations you may have with us, may have ceased, been terminated, or altered in any way, for a reasonable period thereafter. This may include, where applicable, a period to enable us to enforce our rights under any contract with you.
4. WHERE WE STORE THE INFORMATION
4.1 Singapore or Elsewhere. Your Personal Data may be processed by staff operating in Singapore or in a jurisdiction outside of Singapore. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely with an adequate level of data protection.
4.2 Third-Party Providers. Some of the Personal Data you provide to us may also be stored or processed on our behalf by third party suppliers and data processors which may be located in Singapore or jurisdictions outside of Singapore.
4.3 Transfers of Personal Data. The Personal Data we collect from you may also be transferred to, and stored at, a destination in Singapore or a country outside of Singapore. Whether to third parties or internally, we will take all steps reasonably necessary to ensure that all your Personal Data is treated securely in accordance with the Policy through contractual clauses and/or ensure that such jurisdictions have equivalent data transfer regulations to protect the security and confidentiality of your Personal Data.
4.4 Consent to Transfer of Personal Data. By interacting with our Platforms and/or using our Products and/or Services, you agree to the transfer, storage, or processing of Personal Data described above. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.
4.5 Duration of Retention. 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.
5. YOUR RIGHTS AND LIMITATIONS
5.1 Request for Access. In accordance with the applicable laws, you have the right to request access to, request for a copy of, request to update or correct, your Personal Data held by us. Please note that a reasonable fee may be charged for an access request and if so, we will inform you of the fee before processing your request. You may contact our Data Protection Officer. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you. However, access to your Personal Information may be denied on certain grounds, for example: it is unlawful; it may have an unreasonable impact upon the privacy of other individuals; or your request is frivolous or vexatious. If we deny you access, we will provide our reason for doing so at the time of your request.
5.2 Amendments to Your Personal Data. You may review, update, correct or delete your Personal Data by editing your profile or writing to us via email. If you would like your account to be deactivated, please contact us and we will attempt to accommodate your request if we do not have any obligation or legitimate reason to retain the information contained in your account. When making amendments to your Personal Data, we will verify your identity before proceeding to act on your request.
5.3 Responding to your Personal Data Requests. We will respond to your request as soon as reasonably possible. Should we be unable to respond to your request within a reasonable time period after receiving your request, we will inform you in writing in respect of the same, and propose when we believe we will able to attend to your request by. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will 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).
5.4 Accuracy of Personal Data. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by updating the particulars and records filed with us.
5.5 Withdrawal of Consent. You have the right, by notice in writing to our Data Protection Officer to inform us of your withdrawal (in full or in part) of your consent previously given to use your Personal Data, subject to any applicable legal restrictions, contractual conditions, and a reasonable duration of time for the withdrawal of consent to be effected. However, depending on the extent of your withdrawal of consent for us to process your Personal Data, you may not be able to access our Products and Services and/or use our Platforms.
5.6 Processing your Withdrawal. Upon the 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.
5.7 Effect of Withdrawal. 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.
5.8 Scope of our Policy. Our Platforms may, from time to time, contain links to and from the platforms of our partner networks, advertisers, and affiliates. If you follow a link to any of these platforms, please note that these platforms have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these platforms. Please be reminded that we do not control the privacy practices of these third-party services and we encourage you to read the privacy policies of all third-party organisations. Browsing and interacting on any other website, including websites that have a link to our Platforms, is subject to that website's own terms and policies.
6. DISCLOSURE OF INFORMATION
6.1 Information We Share. We may share your Personal Data with partners, companies, organisations, and individuals outside of DENARE, including but not limited to:
(a) Service Providers. We may share Personal Data with service providers (including but not limited to payment processors, fraud detection vendors, service-related technology providers, and survey administrators) that provide services to you and us, including to help us maintain our databases and websites, administer emails, display content, and analyse website user activity.
(b) Our Partners. We may share your Personal Data and payment information with other business partners, suppliers or delivery personnel to perform a Service, to delivery the Products to you and/or to execute a contract.
(c) Within Our Organisation. We may share any of your Personal Data with parents, subsidiaries, joint venture partners, and other entities under common control subject to this Policy.
(d) Social Networking Platforms. You may interact with certain features of our Services that cause certain categories of your Personal Data to be published on social networks.
(e) Advertising Partners. We may share Personal Data that you provide and payment information with advertising partners that use various technologies to send or serve relevant advertisements to you as you browse the internet.
(f) Transactions. In the event of a fundraising exercise, merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets (whether by private sale, through operation of law, as part of a divestiture plan, or otherwise) or such other similar transactions, your Personal Data and any other information that we have collected, may be disclosed to the persons and/or entities assuming control of the relevant business unit or as otherwise necessary to complete the transaction as permitted by law or contract.
(g) Legal and Similar Disclosures. We may disclose Personal Data about you with law enforcement, the courts, our advisors, attorneys, and others who participate in the legal process, if necessary to do so by law or based on our good-faith belief that it is necessary to enforce or apply our contracts, conform or comply with the law, or is necessary to protect us, the users of the websites, or others.
(h) To Perform our Obligations. We may disclose Personal Data about you where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you.
(i) Additional Disclosures. In addition to the sharing described in this Policy, we may share information about you with third parties for legitimate purposes in connection with the running of our business.
6.2 Continuation. The purposes listed above may continue to apply and we may continue to share your Personal Data even in a situation where the use of our Services, our Platforms or any contractual obligations you may have with us may have ceased, been terminated or altered in any way, for a reasonable period thereafter.
7. DEEMED CONSENT BY NOTIFICATION
7.1 User Information. We may collect or use your Personal Data, or disclose existing Personal Data for secondary purposes that differ from the primary purpose which it had originally collected for. If DENARE intends to rely on deemed consent by notification for such secondary purposes, DENARE will notify you of the proposed collection, use or disclosure of his Personal Data through appropriate mode(s) of communication.
7.2 Adverse Effect. Before relying on deemed consent by notification, DENARE will assess and determine that the collection, use and disclosure of the Personal Data will not likely have an adverse effect on you.
7.3 Opt-out. You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your Personal Data for such purposes.
7.4 Withdrawing your Consent. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your Personal Data in relation to those purposes.
8. RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
8.1 User Information. We may collect, use or disclose your Personal Data without your consent for the legitimate interests of DENARE or another person. In relying on the legitimate interests exception of the PDPA, DENARE will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
8.2 Purpose. In line with the legitimate interests' exception, we will collect, use or disclose your Personal Data for the following purposes:
(a) fraud detection and prevention; and
(b) detection and prevention of misuse of services.
The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
9. PROTECTING YOUR PERSONAL DATA
9.1 Data Security. We work hard to protect the information provided by, or collected about, the users of our Platforms, from unauthorised access, alteration, disclosure or destruction. We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorised access, alteration, disclosure, or destruction of your Personal Information, username, password, transaction information, and data stored on our Platforms.
9.2 Data Breach. In the event of a data breach, DENARE will, as soon as reasonably practical, notify all affected parties of such breach.
9.3 Internet Transmission of Information. Please note that the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our Platforms and any transmission is made at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access to your Personal Data.
10. HANDLING COMPLAINTS FROM OUR USERS AND REGULATORY AUTHORITIES
10.1 We regularly review our compliance with this Policy and with any and all industry-recommended best practices, as well as applicable laws and regulations. When we receive a formal written complaint, we will contact the person who made the complaint to follow up. This is without prejudice to your right to launch a claim with your local data protection supervisory authority. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Data that we cannot resolve with the users of our Service directly.
11. 1 Implementation of Cookies. We may from time to time implement "Cookies" or other features to allow us or third parties to collect or share information that will help us improve our Platforms and the Services we offer or help us offer new services and features.
11.2 What are Cookies. Cookies are small files that are placed on your computer when a website is accessed by you. Cookies help the website user to navigate efficiently between pages and the website operator to track usage of the site. We may link Cookie information to Personal Data.
11.3 Use for Cookies. Cookies allow us to recognise your computer or device and tell us how and when the Services or Platforms are used or visited, by how many people and to track activity within our Platforms. Cookies are also used to deliver content specific to your interest and to monitor the usage of the Platforms and Services.
12. PRIVACY AND CHOICE
12.1 Privacy and Choice. People have different concerns about privacy. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how that information is used. You may set your browser, in its "options" or "preferences" feature, to warn you before accepting Cookies or to disable Cookies entirely. However, it is important to understand that many of the services we provide on our Platforms and to our users may not function properly if your Cookies are disabled.