Business Operation - Privacy Policy

1.  INTRODUCTION 

1.1  Welcome to the MyKuya platform run by MyKuya Technologies Pte Ltd and its respective subsidiaries, associate companies and jointly controlled entities (“MyKuya”) use your Personal Data.

MyKuya Technologies Pte. Ltd. and its affiliates and affiliates (individually and collectively, "MyKuya", "we", "us" or "our"). MyKuya takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our MyKuya Application (the "Application") (we refer to the Application, including but not limted to the web and mobile applications, and the services we provide as described in our Application collectively as the "Services"). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Please read this Privacy Policy carefully. If you have any questions regarding this information or our privacy practices, please see the contact information section at the end of this Privacy Policy. 

1.2  "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information. 

1.3 By using the Services, registering for an account with us, visiting our application, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR WEB OR MOBILE APPLICATION and/or Application. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our Application. We reserve the right to amend this Privacy Policy at any time. 

2. WHEN WILL MYKUYA COLLECT PERSONAL DATA? 

2.1 We will/may collect personal data about you: 

(a) when you register and/or use our Services or Application, or open an account with us; 

(b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;

(c) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services; 

(d) when you interact with us, such as via telephone calls (which may be recorded), text messages or SMS, letters, fax, face-to-face meetings, social media platforms and emails; 

(e) when you use our electronic services, or interact with us via our application or use services on our Application. This includes, without limitation, through cookies which we may deploy when you interact with our application or Application; 

(f) when you carry out transactions through our Services; 

(g) when you provide us with feedback or complaints; 

(h) when you register for a contest; or 

(i) when you submit your personal data to us for any reason. 

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected. 

2.2 When you visit, use or interact with our mobile application or the Application, we may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. The information we collect may include, without limitation, your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web Application (if any), and the pages you visit on our Application and mobile applications and the times of visit. We may collect, use disclose and/or process this information only for the Purposes (defined below). 

2.3 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, and other such technologies. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer. 

3. WHAT PERSONAL DATA WILL MYKUYA COLLECT? 

3.1 The personal data that MyKuya may collect includes but is not limited to: 

• name; 

• email address; 

• date of birth; 

• billing address; 

• Credit card information, bank account information and other payment information; 

• telephone number; 

• gender; 

• any other information about the User when the User signs up to use our Services or Application, and when the User uses the Services or Application, as well as information related to how the User uses our Services or Application; and 

• aggregate data on content the User engages with. 

3.2 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing about it. Further information on opting out can be found in the section below entitled "How can you opt-out, remove, request access to or modify information you have provided to us?" . Note, however, that opting out of us collecting your personal data or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services. For example, opting out of the collection of location information will cause its location-based features to be disabled. 

 

4. SETTING UP AN ACCOUNT 

In order to use certain functionalities of the Services, you will have to create a user account which requires you to submit certain personal data. When you register and create an account, we require you to provide us with your name and email address as well as a user name that you select. We also ask for certain information about yourself such as your telephone number, email address, photo identification, bank account and credit card details, age, date of birth, gender and interests. Upon activating an account, you will select a user name and password. Your user name and password will be used so you can securely access and maintain your account. 

5. COOKIES 

5.1 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 Application and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when the Services or Application are used or, by how many people and to track movements within our Application. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and pages you have viewed. This information is used to keep track of your shopping cart, for example. Cookies are also used to deliver content specific to your interest and to monitor Application usage. 

5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this you may not be able to use the full functionality of our Application or the Services. 

6. Why and How do We Process Your Data?

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes: 

(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services; 

(b) to manage, operate, provide and/or administer your use of and/or access to our Services and our website/application, as well as your relationship and user account with us; 

(c) to manage, operate, administer and provide you with as well as to facilitate the provision of our Services, including, without limitation, remembering your preferences; 

(d) to tailor your experience through the Services by displaying content according to your interests and preferences, providing a faster method for you to access your account and submit information to us and allowing us to contact you, if necessary; 

(e) to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions; 

(f) to enforce our Terms of Service or any applicable end user license agreements; 

(g) to protect personal safety and the rights, property or safety of others; 

(h) for identification and/or verification; 

(i) to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services; 

(j) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf; 

(k) to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. (l) to inform you when another User has sent you a private message or posted a comment for you on the Site; 

(m) to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience; 

(n) to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with MyKuya’s Services; 

(o) where you give us your prior consent, for marketing and in this regard, to send you by various modes of communication such as postal mail, email, location-based services or otherwise, marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom MyKuya may collaborate or tie up with) that MyKuya (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future.; 

(p) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on MyKuya or on its related corporations or affiliates; 

(q) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements; 

(r) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us; 

(s) to audit our Services or MyKuya's business; 

(t) to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned; 

(u) to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction; 

(v) to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves MyKuya as a participant or involves only a related corporation or affiliate of MyKuya as a participant or involves MyKuya and/or any one or more of MyKuya's related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or 

(w) any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”). 

6.2 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws. 

7. Purpose of Processing your Data

MyKuya may use and process your Personal Data for business and activities of MyKuya which shall include, without limitation the following (“Purpose”):

Where you are a customer of the services provided by MyKuya:

  1. to perform the MyKuya’s obligations in respect of any contract entered into with you;

  2. to provide you with any service you have requested;

  3. to process your subscriptions and to deliver the services to you;

  4. where you have requested to download and use the MyKuya App (“App”), to process your request, to deliver the App to you and to provide you a license for the use of the App;

  5. to process your participation in any events, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions;

  6. to process, manage or verify your application for subscription with the MyKuya and to provide you the benefits offered to subscribers;

  7. to validate your bookings and process payments relating to any products or services you have requested;

  8. to understand and analyses our sales as well as your needs and preferences;

  9. to develop, enhance and provide products and services to meet your needs; to process exchanges or product returns;

  10. Where you are an agent, vendor, supplier, partner, contractor or service provider:

  11. for the purposes of engaging you to provide services or products;

  12. to facilitate or enable any checks as may be required by MyKuya in order to engage you;

  13. to process payments relating to any products or services you have provided;

  14. to contact you or your MyKuya;

GENERAL

  1. to respond to questions, comments and feedback from you;

  2. to communicate with you for any of the purposes listed in this Notice;

  3. for internal administrative purposes, such as auditing, data analysis, database records;

  4. for purposes of detection, prevention and prosecution of crime;

  5. for MyKuya to comply with its obligations under law;

  6. and you agree and consent to MyKuya using and processing your Personal Data for the Purposes and in the manner as identified in this Notice.

Marketing and promotional purposes

  1. MyKuya may also use and process your data for other purposes such as (“Additional Purposes”):

  2. To send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings from MyKuya, its partners, sponsors or advertisers;

  3. To notify and invite you to events or activities organized by MyKuya, its partners, sponsors or advertisers;

  4. To process your registration to participate in or attend an event or activity and to communicate with you regarding your attendance at the event or activity;

  5. To share your Personal Data amongst its subsidiaries, associate companies and jointly controlled entities as well as with its agent, vendor, supplier, partner, contractor or service provider who may communicate with you to market their products, services, events or promotions.

  6. by way of post, telephone call, short message service (SMS), by hand and/or by email.

8. SHARING OF INFORMATION FROM THE SERVICES

Our Services enable Users to share personal information with each other, in almost all occasions without MyKuya’s involvement, to complete transactions. In a typical transaction, Users may have access to each other’s name, user ID, email address and other contact and postage information. Our Terms of Service require that Users in possession of another User’s personal data (the “Receiving Party”) must (i) comply with all applicable Privacy Laws; (ii) allow the other User (the “Disclosing Party”) to remove him/herself from the Receiving Party’s database; and (iii) allow the Disclosing Party to review what information have been collected about them by the Receiving Party.

9. HOW DOES MYKUYA PROTECT CUSTOMER INFORMATION? 

We implement a variety of security measures to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any legal or business purposes. If you cease using the Site, or your permission to use the Site and/or the Services is terminated, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you. 

10. DOES MYKUYA DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES? 

10.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation: 

(a) our subsidiaries, affiliates and related corporations; 

(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; 

(c) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of MyKuya’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by MyKuya about our Service Users is among the assets transferred; or to a counterparty in a business asset transaction that MyKuya or any of its affiliates or related corporations is involved in; and 

(d) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes 6.1-7. This may require, among other things, share statistical and demographic information about our Users and their use of the Services with suppliers of advertisements and programming. This would not include anything that could be used to identify you specifically or to discover individual information about you. 

10.2  For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. 

10.3 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours. 

11. Unsubscribe and Revocation of Consent

If you wish to unsubscribe to the processing of your Personal Data for Additional Purposes by MyKuya, please click on the link “Unsubscribe” which is embedded in the relevant email in order not to receive any email in the future.

If you wish to revoke the consent that MyKuya has obtained from you for the Purposes stipulated herein, please notify MyKuya using the contact details stated below.

12. Transfer of Personal Data

Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any services provided by MyKuya (“Alternate Country”), to companies under MyKuya which are located outside of your home nation or Alternate Country and/or where MyKuya’s servers are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.

13. Disclosure to Third Parties

Your personal data may be transferred, accessed or disclosed to third parties for the Purposes and Additional Purposes. Further, MyKuya may engage other companies, service providers or individuals to perform functions on its behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties include, without limitation:

  1. MyKuya partners, which include parties with whom MyKuya collaborates with for certain events, programs and activities;

  2. Event management companies and event sponsors;

  3. Marketing research companies;

  4. Service providers, including, information technology (IT) service providers for infrastructure, software and development work;

  5. Professional advisors and external auditors, including legal advisors, financial advisors and consultants;

  6. Other entities within MyKuya; and

  7. Governmental authorities to comply with statutory, regulatory and governmental requirements.

  8. Your Personal Data may also be shared in connection with a corporate transaction, such as a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.

  9. Access & Correction Requests and Inquiries, Limiting the Processing of Personal Data

Subject to any exceptions under applicable laws of your home nation or Alternate Country, you may request for access to and/or request correction of your Personal Data, request to limit the processing of your Personal Data for the Additional Purposes and/or make any inquiries regarding your Personal Data by contacting:

MyKuya Technologies Pte Ltd

6 Eu Tong Sen Street, #05-07

Clarke Quay Central

Singapore, 059817

Email: hello@mykuya.com

Subject to any laws of your home nation or Alternate Country, MyKuya reserves the right to impose a fee for access of your Personal Data in the amounts as permitted therein.

In respect of your right to access and/or correct your Personal Data, MyKuya has the right to refuse the your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.

If you do not wish for your Personal Data to be collected via cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.

14. Links to Third-Party Websites

The Websites may contain links to third parties’ websites. Please note that MyKuya is not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information directly to such sites, the privacy policy and terms of service on those sites are applicable and MyKuya is not responsible for the information processing practices or privacy policies of such sites.

15. Personal Information from Minors and Other Individuals

As a parent or legal guardian, please do not allow the minor (individuals under 18 (eighteen) years of age) under your care to submit Personal Data to MyKuya. In the event that such Personal Data is provided to MyKuya, you hereby consent to the processing of the minor’s Personal Data and personally accept and agree to be bound by this Notice and take responsibility for his or her actions.

In some circumstances you may have provided personal data relating to other individuals (such as your spouse, family members or friends) and in such circumstances you represent and warrant that you are authorized to provide their personal data to MyKuya and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Notice.

16. Acknowledgement and Consent

By communicating with MyKuya, using MyKuya’s services, purchasing products from MyKuya or by virtue of your engagement with MyKuya, you acknowledge that you have read and understood this Notice and agree and consent to the use, processing and transfer of your Personal Data by MyKuya as described in this Notice.

MyKuya shall have the right to modify, update or amend the terms of this Notice at any time by placing the updated Notice on the Websites. By continuing to communicate with MyKuya, by continuing to use MyKuya’s services, purchasing products from MyKuya or by your continued engagement with MyKuya following the modifications, updates or amendments to this Notice, such actions shall signify your acceptance of such modifications, updates or amendments.

In the event of any conflict between the English and other language versions, the English version shall prevail.

 

For any questions or concerns, please visit http://help.mykuya.com or email hello@mykuya.com.

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MyKuya Technologies Pte. Ltd. 

6 Eu Tong Sen Street
#05-07
The Central
Singapore 059817

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