Please refer to the Terms and Conditions accessible at https://legalexpat.sg/terms-and-conditions/ (“Terms”) when reading this Privacy Policy.

1. INTERPRETATION

1.1. “Terms” refers to the terms and conditions of use of the Website.

1.2. “Services” refers to the services we provide including the Website.

1.3. The headings used in this Privacy Policy are for convenience only and shall not affect the interpretation of these provisions.

2. APPLICATION

2.1. This Privacy Policy applies to users when browsing, visiting, accessing and/or using any part of the Website and/or any of our Services.

2.2. This Privacy Policy sets out our commitments and explains the rights that you have with respect to your personal data. If you do not agree to the terms of this Privacy Policy, please do not use the Website or Services or any part thereof.

2.3. You shall not be permitted to use the Services where you do not confirm your acceptance of this Privacy Policy.

3. GROUNDS FOR DATA COLLECTION

3.1. By browsing, visiting, accessing and/or using our Services and/or when you provide personal data to us, you consent to the collection, storage, use, disclosure and other uses and processing of your personal data by us in accordance with this Privacy Policy, and such consent shall remain effective unless you otherwise notify us in writing of the withdrawal of your consent and the reason thereto. You shall not use our Services if you do not consent to this Privacy Policy, and you shall immediately cease using our Services if you withdraw your consent for us to process your personal data.

3.2. “Personal data” and other terms defined under the PDPA where used in this Privacy Policy shall have the same meaning defined under the PDPA.

3.3. Processing of your personal data is necessary for the performance of our contractual obligations towards you under the Terms and providing you with the Services, to protect our legitimate interests, and to ensure compliance with legal and financial regulatory obligations. If you choose not to provide us with the information requested, you may not benefit from certain features of the Services or participate in a particular activity and your use of the Services may be limited.

4. HOW DO WE RECEIVE INFORMATION ABOUT YOU?

4.1. You may, during the course of registration, disclose your personal data.

4.2. It is your voluntary decision whether to provide us with any personal data. However, if you do not provide the information we require or requested, we may not be able to contact you and you may not benefit from the use of the Services.

4.3. To enable us to provide our Services to you effectively, the information you provide to us shall be accurate, complete, not misleading and without material omission, and that such information is kept up to date. If you discover that the information is inaccurate, incomplete, misleading, contains material omission or is outdated, please update us with the true, accurate, complete and updated information.

4.4. If you provide us personal data about another person, you confirm that such other person has appointed you to act for him/her, to consent to the processing of his/her personal data by us in accordance with this Privacy Policy and to receive on his/her behalf any data protection notices.

4.5. We collect information in several ways, such as:

(a) From our website: you may have an opportunity to send us information about yourself (e.g. when you create an account/when you fill out a registration form/survey). You may choose to personalize your user-experience on the Services in which case we may collect information about your visits to our website, including the URL clickstream, products you viewed or searched for, length of visits to certain pages and page interaction which may be collected automatically through the use of cookies.

(b) We may collect information when you contact us for information on our applications and Services, provide feedback or complaints or otherwise in the course of providing technical assistance or responding to product or service queries.

5. WHAT TYPES OF INFORMATION WE COLLECT?

5.1. We collect the following personal data about you:

(a) Identification Information

(b) Voluntary Information – when you communicate with us (for example when you send us an email or contact us) we collect the personal data you provided us with; and

(c) Technical Information – we collect certain technical information that is automatically recorded when you use our Services, such as your IP address and device approximate location.

(d) Credit card information and banking account details

(e) Content, file uploads, information, feedback, questions or enquiries input on the platform for content generation

(f) Digital and calibration data including electronic network activity information such as the data we receive when you use the Services, preferred settings and credentials, products purchased and preferences when using the Services, and other related information for data analytics.

5.2. We will only collect information that is reasonably necessary for us to provide you with the Services. We collect such information only when we ask you for it and you provide it, and through technology that collects information automatically, such as cookies or other similar technologies. We will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was provided to us.

6. TRACKING TECHNOLOGIES – COOKIES

6.1. A cookie is a small piece of text that is sent to your browser when you access this Website. The Website provides this piece of text to your device when you return. We use cookies to help personalize your experience with this Website.

6.2. The Website automatically accepts cookies however you may to modify security settings so you can approve or reject cookies on a case-by-case basis or reject all cookies.

6.3. You are free to delete any existing cookies at any time.

6.4. We also use “Google Analytics” to collect information about the use of the Services. Google Analytics collects information such as how often users visit the Services, what pages they visit, when they do so, and what other sites they used prior to coming to the Services. Google Analytics collects only the IP address assigned to you on the date you use the Services, as well as information regarding your operating system, language and information regarding your use of the Services, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personal data. We use the information we get from Google Analytics only to improve our Services. Google’s ability to use and share information collected by Google Analytics about your use of the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

6.5. We may also collect certain information automatically through the use of cookie-less tracking technology when you use the Services, and the information may be collected in the following ways:

(a) Through your browser – This may include your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version.

(b) IP address – Your IP address, along with the time of the visit and pages visited, is identified and logged automatically in our server log files whenever you visit the Services. Collection of IP addresses is standard practice and is done automatically by many online services. The IP address collected may be use for diagnosing server problems and administering the Services.

(c) Mobile device – If you access the Service through a mobile device, we may collect information on it such as smartphone device brand and type to understand how you use the Service.

7. HOW DO WE USE THE INFORMATION WE COLLECT?

7.1. We use your information collected only for purposes permitted by applicable laws and for the purpose for which it is collected, which generally includes the following:

(a) Provision of Services – we will use your information for the provision and improvement of our Services to you, and for the processing of your requests and queries

(b) General Communication – we also use your personal data to send you texts, emails or other communications regarding general adherence information, Services, updates, or changes to this Privacy Policy or any other relevant agreements.

(c) Analytics, Surveys and Research – we are always trying to improve our services and think of new and exciting features for our users. From time to time, we may conduct surveys or test features, and analyze the information we have to develop, evaluate and improve these features.

(d) Protecting our Interests – we may use your personal data when we believe it is necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of the Website, and protect the rights and property of the Company, its users and/or partners.

(e) Enforcement of Policies – we may use your personal data in order to enforce our policies, including the Terms.

(f) Compliance with Legal and Regulatory Requirements – we may also use your personal data as required by or for the purpose of compliance with law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

(g) Record-keeping – we will collect and retain your personal data in the ordinary course of our business and for so long as necessary for the fulfilment of the purposes set out in this Privacy Policy or as is required by any legal, regulatory and/or accounting requirements.

(h) Ancillary purpose – we may use your personal data for any purposes in connection with, relating or ancillary to any of the above, provided that they are necessary for the delivery of the Services.

(i) To assist you in setting up an account to use the Services.

(j) To conduct trials (with your consent) to enhance, improve and optimise your experience when you use the Services.

By using the Services or allowing your child to use the Services, you expressly authorize and consent to us gathering, reviewing, retaining and where reasonably required, transmitting your or your child’s personal information to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the PDPA. When you provide personal information on or through the Services, the information may be sent to servers located outside of Singapore. In such an event, we will take appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the PDPA.

8. WITH WHOM YOUR PERSONAL DATA MAY BE SHARED?

8.1. We may share your personal data with the following persons:

(a) Law Authorities – we may share your personal data with law enforcement authorities, courts and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Services users.

(b) Merger, Acquisition or Sale – we may transfer your personal data to another organisation in the event of a merger, acquisition or sale of all or a portion of our assets.

(c) Auditor, Legal and Professional Advisor – we may share your personal data with our auditor if requested for the purpose of audit on our business. We may also share your personal data with our legal and other professional advisors for the purpose of enforcing our rights or defending any claims against us, or for any other purpose in connection with the Services.

(d) Data Intermediary – we may store personal data on a public and/or private cloud. The cloud provider is subject to the obligations and responsibilities of a data intermediary as set out in the PDPA.

(e) Service providers – we may share information, including personal information, with third parties that perform certain services on our behalf. These services may include, without limitation, storage of personal information on a cloud service, server hosting, marketing and supporting our notification service functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to disclose or use such information for any other purposes.

(f) We may allow third party service providers, advertising companies, advertisement networks, merchandising companies and other third parties to display advertisements and brands on the Services. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements.

(g) We do not provide any non-anonymized personal information to third parties. We will adhere strictly to the provisions in the PDPA in relation to any disclosure and dissemination of information to any third parties.

We may disclose your information, including personal information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law.

9. ACCESS AND CORRECTION

9.1. You may request access to and correction of, your personal data and limit the processing of your personal data or make any enquiries or complaints in respect of the processing of your personal data, by contacting us at the contact details set out in “How to Contact Us” section below. You are responsible for informing us when your personal data or preferences have changed and require updating. We shall, within a reasonable time frame, attend to your request for access to and correction of your personal data or updating of your preferences.

10. INTERNATIONAL TRANSFERS

10.1. We store information and data on a public and/or private cloud, where your data can be stored and/or backed up in any of the jurisdictions where the cloud service providers provide their cloud service. You hereby consent that we may store your personal data on our cloud server, which may be located outside Singapore or the jurisdiction in which the Services was obtained or is used.

10.2. Your personal information may be transferred, stored or processed in any country where we have facilities or service providers. By using our Service or by providing consent to use (where required by law), your information may be transferred outside Singapore including Switzerland, which may provide for different data protection rules than in Singapore. We will ensure that the use and disclosure of personal information transferred offshore is dealt with in accordance with this Privacy Policy, and we will not transfer your personal data to a country or territory outside Singapore that does not provide protection of personal data that is comparable to the protection under the PDPA.

11. RETENTION

11.1. We will retain your personal data for as long as necessary to provide our services or as required by any legal, regulatory and/or accounting requirements. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

12. LINKS TO OTHER WEBSITES OR APPS

12.1. Our Services may link to or refer to websites or mobile device services that we do not control. Any personal data you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or mobile device services, and we are not responsible for the privacy practices or content of any website or mobile device service not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or mobile device services for more information about their applicable policies. The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us or by our affiliates.

13. HOW WE PROTECT YOUR INFORMATION

13.1. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal data. Your information is stored on secure servers and is not publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.

13.2. While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your personal data, we cannot ensure or warrant the security and privacy of your personal data or other content you transmit using the Services, and you do so at your own risk.

13.3. We shall, in the event of a compromise of personal data:

(a) Assess the extent to which personal data collected by us has been compromised and put in place appropriate measures to contain the breach of personal data and minimize any harm to you arising from the breach of personal data;

(b) Analyze and determine the cause of the data breach;

(c) Ascertain if the data breach are notifiable data breaches under any data protection and privacy laws applicable to the Company;

(d) Report the data breach to any relevant governmental data protection body or agency, including the Singapore Personal Data Protection Commission if the data breach is a notifiable data breach;

(e) Ascertain if you are required to be informed of the data breach having regard to relevant rules, regulations, advisories, orders wheresoever applicable, including but not limited to the Personal Data Protection (Notification of Data Breaches) Regulations 2021 and the Advisory Guidelines on Key Concepts in the PDPA;

(f) Inform you if you are required to be notified of the data breach; and

(g) Take continuing action to prevent further harm to you arising from the breach of personal data, including but not limited to reviewing measures taken to contain breaches of personal data and protect personal data.

13.4. We shall, in managing data breaches, have regard to the Guide on Managing and Notifying Data Breaches under the PDPA (“Guide”). Subject to our compliance with the Guide in the event of a breach of personal data, by continuing to use the Website following such an event of breach, you confirm that you accept the adequacy of measures taken by us following an event of breach of personal data.

13.5. No system can be completely secure. You acknowledge that notwithstanding the Company’s security measures, malicious actors, scripts, viruses, codes, software and other damaging factors including the evolution of hacking technologies, may result in the compromise of the personal data which you have provided to the Company.

13.6. To the fullest extent permitted, you waive any claim against the Company for any, loss, liability, damage and/or cost incurred (“Damage”), howsoever such Damages arise and whether such losses are direct or indirect losses, where such data breaches do not arise out of the negligence, fraud or wilful default of the Company.

13.7. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately contact us below.

13.8. We do not keep personal information for longer than required and we destroy or permanently anonymize personal information that we no longer need, where permitted.

14. CHILDREN

14.1. Our Services are intended for use by persons 18 years of age or older. Individuals below 18 years of age or individuals who are not the minimum legal age in their country of residence to provide consent may not use the Services, subject to their parent or guardian who may open an account to use the Services and help them access appropriate content. Under no circumstances should the Services be used by children under 18 years of age or without consent, and we will not knowingly collect personal data from any person we know to be under 18 years of age, or who does not have consent. If any person discovers that his/her child has been using the Services without parental consent, or that someone has been using the Services for or on behalf of his/her child without his/her consent, please contact us using the information below under “How to Contact Us” and we will take reasonable steps to delete the child’s information from our active databases. We reserve the right to check our user base from time to time and remove users whom we have grounds to believe they are in fact minors, including without limitation, restricting those user accounts, or deleting them, as we may deem appropriate.

15. MODIFICATIONS OF THIS PRIVACY POLICY

15.1. We reserve the right to update or modify this Privacy Policy at any time and from time to time at our sole and absolute discretion. By continuing to use the Services after any such changes, you agree to follow and be bound by this Privacy Policy as changed. We will notify you of any changes to this Privacy Policy by way of email or by a pop-up notification when you access the Website, app or Services to help ensure that you are always aware of the information that we collect, how we use it, and in what circumstances, if any, that we share it with other parties.

15.2. You are encouraged to visit the Services from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. Your use of the Service following any changes means that you accept the revised Privacy Policy. This Privacy Policy was last updated on 17 September 2024.

16. NO THIRD-PARTY RIGHTS

16.1. This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Services.

17. HOW TO CONTACT US

17.1. If at any time you would like to access, review, correct, update, restrict, or delete your personal data, or if you would like to enquire about our privacy practices, please contact us by:

Email to our Data Protection Officer: Kenneth G Pereire (Kenneth@kgplegal.com.sg)

17.2. We will endeavour to respond to your request as soon as reasonably practicable and no later than one (1) month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response. Your withdrawal of consent to our collection, use and disclosure of personal information may mean that we will not be able to continue with the existing relationship with you and the contract that you have with us may be terminated.

17.3. Please note that while you may have a right to access your personal data, there are some circumstances where we are not permitted to give you access to it under the PDPA (for example, we will not accommodate a request to access, change or delete personal data if we believe that doing so would violate any law or legal requirement).

18. UPDATES TO THIS PRIVACY POLICY

18.1. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will review our policies, procedures and processes from time to time. We reserve the right to amend the terms under this Privacy Policy at our absolute discretion. We will notify you of any changes to this Privacy Policy by way of email or by a pop-up notification when you access the Website, app or Services to help ensure that you are always aware of the information that we collect, how we use it, and in what circumstances, if any, that we share it with other parties.

18.2. You are encouraged to visit the Services from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. Your use of the Service following any changes means that you accept the revised Privacy Policy. This Privacy Policy was last updated on 17 September 2024.