1.1 Welcome to the Poplab platform run by Poplab Space Pte. Ltd. and its affiliates (individually and collectively, "Poplab", "we", "us" or "our"). Poplab takes its responsibilities under applicable privacy laws and regulations which includes, but is not limited to, the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore, as may be amended from time to time (the “PDPA”) ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our Poplab mobile application and Poplab Website (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). Users refers to a user who registers for an account with us for use of the Services or otherwise access the Platform without registration, and include both buyers and sellers (individually and collectively, “Users”, “you
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, in accordance with the PDPA. Personal data include data which is gathered in the background while Users interact via their virtual lives on the Platform. Personal data can also include data which is gathered from the avatar of Users, as well as the virtual choices that the avatar makes, on the Platform. Section 4 below sets out a non-exhaustive list of common examples of personal data.
1.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we expressly state otherwise.
1.5 This Policy applies to both buyers and sellers who use the Services except where expressly stated otherwise.
2. WHEN WILL POPLAB COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
- when you access, register and/or use our Services or Platform, or open an account with us;
- 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;
- 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;
- when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents;
- when you use our electronic services, or interact with us via our application or use services on the Platform. This includes, without limitation, through cookies which we may deploy when you interact with the Platform or Poplab website;
- when you grant permissions on your device to share information with the Platform;
- when you link your Poplab account with your social media or other external account or use other social media features, in accordance with the external account provider’s policies;
- when you carry out transactions through our Services;
- when you provide us with feedback or complaints;
- when you register for a contest; or
- when you submit your personal data to us for any reason.
2.2 The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
3. HOW WILL POPLAB COLLECT YOUR PERSONAL DATA?
3.1 We collect your Personal Data:
(a) Directly from you. You may give us your personal data when you do any of the following (whether on your own behalf or on behalf of your organisation):
(i) use our Services;
(ii) create an account on our Platform;
(iii) enter into a contract with us or purchase products on our Platform;
(iv) apply for or enquire about our Services or products on our Platform;
(v) participate in a promotion, survey, event or other marketing campaign organised by us;
(vi) subscribe to our newsletters or alerts;
(vii) request marketing materials to be sent to you; or
(viii) contact us – for example, if you get in touch to give us some feedback.
(b) From your authorised representatives. We may also collect your personal data from your authorised representatives. These include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures.
(c) When you interact with our Platform. As you interact with our Platform, we may automatically collect your personal data. We may collect such personal data by using website cookies.
(d) Third parties or publicly available sources. We may receive your personal data from third parties which are located in various countries. These include:
(i) personal data from analytics providers [such as Google], advertising networks and social media platforms such as [LinkedIn, Twitter and Facebook]; and
(ii) personal data from providers of technical, payment and delivery services.
4. WHAT PERSONAL DATA WILL POPLAB COLLECT?
4.1 The personal data that Poplab may collect includes but is not limited to:
- country of residence;
- email address;
- date of birth;
- billing and/or delivery address;
- mailing address of any third party. Such as mailing address of the intended recipient of your order;
- payments and orders to and from you;
- bank account and payment information;
- credit card details;
- telephone number;
- marital status;
- information sent by or associated with the device(s) used to access our Services or Platform;
- information about your network and the people and accounts you interact with;
- photographs or audio or video recordings;
- government issued identification or other information required for our due diligence, know your customer, identity verification, or fraud prevention purposes;
- marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties;
- usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the Platform, and other products and services related to you;
- technical data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Services;
- location data;
- any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform; and
- aggregate data on content the User engages with.
4.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you. Poplab will not be liable for any damages arising out of any inaccurate or misleading information and/or data associated with you or your avatar. This includes inaccurate or misleading information and/or data gathered from the use of any web proxy service, virtual private network or other privacy software that encrypts, hides or anonymizes your online identity.
4.3 For the avoidance of doubt, Poplab will not be liable for losses arising out of any fraudulent misrepresentation or mistaken identity of Users or their avatar, both in the real world and in the virtual world.
4.4 If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your Poplab account to your Social Media Account or use any Poplab social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times.
4.5 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Personal Data Protection Officer in writing at firstname.lastname@example.org. Further information on opting out can be found in section 14 below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services and the Platform. For example, opting out of the collection of location information will cause its location-based features to be disabled.
5. COLLECTION OF OTHER DATA
5.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Platform or use our Services. This typically includes without limitation your device’s 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 site (if any), the pages you visit on our website and Platform and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Services.
5.2 Our Platform may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. 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 Platform. 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.
5.3 As when you view pages on our website or Platform, when you watch content and advertising and access other software on our Platform or through the Services, most of the same information is sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time.
6.1 We or our authorized service providers and advertising partners may from time to time use "cookies" or other features to allow us or third parties to collect or share information in connection with your use of our Services or Platform. These features help us improve our Platform and the Services we offer, help us offer new services and features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that record data about computer or device, how and when the Services or Platform are used or visited, by how many people and other activity within our Platform. We may link cookie information to personal data. Cookies also link to information regarding what items you have selected for purchase and web pages you have viewed. This information is used to keep track of your shopping cart, to deliver content specific to your interests, to enable our third party advertising partners to serve advertisements on sites across the internet, and to conduct data analysis and to monitor usage of the Services.
7. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
7.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
- to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
- to verify your identity;
- to process and deliver your order(s);
- to manage your account, including managing payments, fees and charges and collecting and recovering money owed to us;
- to manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preference), as well as your relationship and user account with us;
- 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;
- to enforce our Terms of Service or any applicable end user license agreements;
- to protect personal safety and the rights, property or safety of others;
- for identification, verification, due diligence, or know your customer purposes;
- to evaluate and make decisions relating to your credit and risk profile and eligibility for credit products;
- 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;
- 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;
- 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. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- to allow other users to interact, connect with you or see some of your activities on the Platform, including to inform you when another User has sent you a private message, posted a comment for you on the Platform or connected with you using the social features on the Platform;
- 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 recommend products and/or services relevant to your interests, to improve our Services or products and/or to enhance your customer experience;
- to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with Poplab’s Services;
- for marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom Poplab may collaborate or tie up with) that Poplab (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. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters or marketing materials from us and from our related companies;
- to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on Poplab or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and company details);
- to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
- 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;
- to audit our Services or Poplab's business;
- to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- to respond to any threatened or actual claims asserted against Poplab or other claim that any content violates the rights of third parties;
- to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
- to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves Poplab as a participant or involves only a related corporation or affiliate of Poplab as a participant or involves Poplab and/or any one or more of Poplab '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;
- any other purposes for which you have provided the information;
- any other incidental business purposes related to or in connection with the above;
- to contact you in relation to all of the above; and/or
- any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
7.2 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 (including, where applicable, a period to enable to enforce our rights under any contract with you).
7.4 Please note that the list of Purposes above is not exhaustive. 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.
8. HOW DOES POPLAB PROTECT AND RETAIN CUSTOMER INFORMATION?
8.1 We implement a variety of security measures and strive 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. However, there can inevitably be no guarantee of absolute security.
9. DOES POPLAB DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?
9.1 In conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, which may be located 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. We endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed for the above-mentioned Purposes. Such third parties include, without limitation:
- our subsidiaries, affiliates and related corporations;
- buyers or sellers you have transacted with or interacted with on the Platform or in connection with your use of the Services for the above-stated Purposes;
- other users of our Platform for one or more of the above-stated Purposes;
- contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those parties which provide administrative or other services to us such as mailing houses, logistics service providers, financial services providers, advertising and marketing partners, telecommunication companies, information technology companies, and data centres;
- governmental or regulatory authorities having jurisdiction over Poplab or as otherwise permitted under Section 7.3;
- 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 Poplab’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Poplab about our Users is among the assets transferred; or to a counterparty in a business asset transaction that Poplab or any of its affiliates or related corporations is involved in; and
- 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.
9.2 We may share your personal data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our Platform or the public.
9.3 We may share user information, including statistical and demographic information, about our Users and information about their use of the Services with advertising partners and third party suppliers of advertisements, remarketing, and/or other programming.
9.4 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. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.
9.5 Third parties may unlawfully intercept, or access personal data transmitted to or contained on the Platform, 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.
9.7 As set forth in Poplab’s Terms of Service, Users (including any employees, agents, representatives, or any other person acting for such User or on such User's behalf) in possession of another User’s personal data through the use of the Services (the “Receiving Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to any such data, including any collection, processing, storage or transfer or transfer of such data; (ii) allow Poplab or the User whose personal data the Receiving Party has collected (the “Disclosing Party”) to remove his or her data so collected from the Receiving Party’s database; and (iii) allow Poplab or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws.
9.8 Notwithstanding anything set forth herein, sellers (including any employees, agents, representatives, or any other person acting for such User or on such User's behalf) shall comply with all applicable Privacy Laws and, in respect of any buyer’s personal data received from Poplab, (i) are not permitted to use such buyer’s personal data except as reasonably necessary to respond to buyers’ enquiries and to carry out respond to, process, deal with or complete a transaction without the buyers’ and Poplab’s prior written consent; (ii) should refrain from contacting buyers using such information outside of the Platform; (iii) are not permitted to disclose such buyer’s personal data to any unauthorized third parties without the buyer’s and Poplab’s prior written consent; (iv) shall employ sufficient security measures to protect each Poplab user’s personal data in their possession, retain such data only for as long as necessary for the Purposes above and in accordance with the Privacy Laws, and to delete or return such data to Poplab upon any request from Poplab or as soon as reasonably possible upon completion of the transaction; and (v) to inform Poplab’s Personal Data Protection Officer at email@example.com in the event of any potential data breach or other loss of such user’s data.
10. INFORMATION ON CHILDREN
10.1The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally identifiable information from anyone under the age of 13 nor is any part of our Platform or other Services directed to children under the age of 13. Parents and/or legal guardians are responsible for ensuring that such children under your care must not submit personal data to Poplab. In the event that personal data of a child under the age of 13 in your care is disclosed to Poplab, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.
10.2 If a child under the age of 13 provides us with personal data, a parent or guardian of that child may have this information deleted from our records by contacting us through our Personal Data Protection Officer at firstname.lastname@example.org.
11. INFORMATION COLLECTED BY THIRD PARTIES
11.2 We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third-party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by Poplab. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.
12. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES
12.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server.
12.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience, and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
13. WILL POPLAB TRANSFER YOUR INFORMATION OVERSEAS?
13.1 Your personal data and/or information may be transferred to stored or processed outside of your country for one or more of the Purposes. In most cases, your personal data will be processed by us in Singapore, where our servers are located. Poplab will only transfer your information overseas in accordance with Privacy Laws.
14. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US?
14.1 Withdrawing Consent
14.1.2 Where you share YouTube Content, in addition to withdrawing your consent by emailing us pursuant to Section 14.1.1, you may also revoke Poplab 's access to your personal data via the Google security settings page at https://security.google.com/settings/security/permissions
14.2 Requesting Access to or Correction of Personal Data
14.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Platform. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at email@example.com.
14.2.2 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
14.2.3 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.
15. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
15.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at firstname.lastname@example.org.