PRIVACY POLICY
This Privacy Policy applies to all sites,
domains and applications provided, is maintained or operated by Sustainable
Living Lab Pte. Ltd. (UEN No. 201211858M), a private limited company
incorporated under the laws of Singapore, with address at 68 Ceylon Road,
Singapore 429650 (the “Company” or “SL2”) and/or its affiliates, carrying on business under the
registered mark “SPRYX” (“SPRYX”),
including http://spryx.co/ and all related sub-domains (hereinafter the “Platform”).
SL2 has in place measures to protect your privacy and Personal Data. This
policy describes how we may collect, use, disclose and process Personal Data
which is provided to us and applies to any individual’s Personal Data which is
in our possession and over which we have control. By accessing, subscribing for
an account and/or using the Platform or the services therein or accepting the
Terms and Conditions of the Platform, you hereby agree to this Privacy Policy.
1.
General
1.1From time to time, SL2 may collect data
which enables an individual to be identified (“Personal Data”) in connection with the use of the Platform. This
includes information such as names, contact details, addresses, email
addresses, and other identification details of individuals who access or use
the Platform.
1.2SL2 may also collect information from or
about the devices which are used to access the Platform. Such information
includes, but is not limited to:
(a)attributes such as the operating system
of the device, hardware version, settings, file and software names and types
and device identifiers;
(b)device
locations; and
(c)connection information such as the name
of the ISP or mobile operator through the Platform is accessed, browser type
and IP address.
2.
Provision and Withdrawal of Personal
Data
2.1Where Personal Data is provided as
required by, pursuant to, or in connection with the use of the Platform, you
represent and warrant to SL2 that (i) the relevant
individual(s) (such as your spouse, children, parents, students, customers
and/or employees) has/have been notified of the purposes for which data will be
collected, processed, used or disclosed; and (ii) such individual’s consent for
the collection, processing, use and disclosure of such Personal Data by SL2 has
been obtained and authorized by such individual.
2.2SL2 must be promptly informed upon
becoming aware of the withdrawal by the relevant individual of his/her consent
to the collection, processing, use and/or disclosure by SL2 of any Personal
Data provided to SL2. The withdrawal of such consent may affect the services
which SL2 is able to provide to you. To make a request to withdraw consent
previously given, please contact SL2 at [email protected]. All requests to
have Personal Data removed from SL2’s databases or physical storage facilities
will be entertained and performed within its reasonable abilities.
2.3Any consent given in relation to Personal
Data shall, unless withdrawn by the relevant individual in accordance with
section 2.2 above and/or subject to all applicable laws and regulations,
survive death, incapacity, bankruptcy or insolvency of any such individual and
the termination or expiration of any account in connection with the use of the Platform.
2.4If you withdraw your consent to any or
all use of your Personal Data, depending on the nature of your request, we may
not be in a position to continue to provide our products and services to you,
or administer any contractual relationship in place, which in turn may also
result in the termination of any agreements with SL2. Please note that
withdrawing consent does not affect our right to continue to collect, use and
disclose Personal Data where such collection, use and disclosure without
consent is permitted or required under applicable laws.
2.5 The Platform uses tracking technologies
to provide services therein. These enable SL2 to understand how you use the Platform
and its services therein which, in turn, helps SL2 to provide and improve them.
However, the tracking technologies do not access, receive or collect
information which can be used to identify you. Below are some examples of the
tracking technologies used on the Platform:
(a)Cookies. A cookie is a small data file
sent from a website to your browser that is stored on your device. Cookies are
used for a number of purposes, including to display the most appropriate content
based on your interests and activity on the Platform, estimate and report the
total audience size and traffic on the Platform, and conduct research to
improve the services on the Platform. You can configure your device's settings
to reflect your preference to accept or reject cookies. If you reject all
cookies, you will not be able to take full advantage of the full services on
the Platform.
(b)Flash cookies. The Platform may use
Flash cookies (a.k.a local shared objects or LSOs) to
store some of your viewing preferences. These are used to collect and store
information, but differ from browser cookies in the amount, type and manner in
which data is stored.
3.
Use of Personal Data
3.1. SL2 may collect, store, process, disclose,
access, review and/or use Personal Data in accordance with the Personal Data
Protection Act 2012 or any other written law.
3.2.Without prejudice to the foregoing, SL2
may use Personal Data for any of its business purposes, which include, and is
not limited to, the following purposes:
(a)to operate, administer any account
and/or offer the products and services available on, the Platform;
(b)to verify the identity or authority of
representatives of registered clients or Users of the Platform;
(c)to carry out or respond to requests,
questions or instructions from verified or authorized representatives or other
individuals pursuant to the current security procedures;
(d)to
facilitate transactions on the Platform;
(e)to
carry out, monitor and analyze SL2’s business;
(f)for
the marketing of products and services ancillary or related to the use of the Platform;
(g)in
connection with any sale, merger, or similar change of SL2’s business;
(h)to verify to comply with any applicable laws, rules, or regulations in any country; and
(i)to detect, prevent and investigate fraud.
3.3.SL2 may also retain Personal Data for so
long as it may deem necessary for the purposes of record retention and for its
own business purposes in connection with the operation of the Platform.
3.4By using the Platform, you authorize SL2
to use your information in Singapore and other countries where we operate for
the purposes mentioned above. We will ensure that your information is
transferred in accordance with this Privacy Policy and protected in accordance
with applicable laws on Personal Data protection (including, but not limited
to, the Personal Data Protection Act 2012 of Singapore).
4.
Storage of Data
The Platform uses third-party
service providers such as Amazon AWS Cloud services, Microsoft etc., therefore
your information may be transferred to and stored on servers in various
locations both in and outside of Singapore. We maintain control of your
information and protect your information using technical and administrative
security measures to reduce the risks of loss, misuse, unauthorized access,
disclosure and alteration.
5. Disclosure
of Data
5.1.SL2 may from time to time also disclose
Personal Data to the following (whether inside or outside of Singapore) for the
purposes listed above:
(a)any agent, contractor, or third-party service providers which provides operation,
administrative or other services to SL2 in connection with SL2’s business
operations and/or the Platform;
(b)any person or entity employed by or on
behalf of SL2 or is a part of or related to any group of companies of which SL2
forms part; or
(c)any actual or proposed assignee of SL2
or transferee of SL2’s rights in respect of all or any part of the assets or
business of SL2.
5.3. Without prejudice to the foregoing, SL2
may disclose Personal Data to any person or entity to whom SL2 is under an
obligation or otherwise required to make disclosure pursuant to any applicable
laws, including disclosure to courts, tribunals, and/or legal, regulatory, tax
and government authorities.
6.
Access, Correction & Update of Data
6.1.You can update your Personal Data through
your account profile settings. If you believe that Personal Data
we hold about you is incorrect, incomplete or inaccurate, you may request us to
amend, correct or update it by contacting us at [email protected].
6.2.Additionally, you may request access to
any Personal Data that we hold about you at any time by contacting us at [email protected].
Where we hold Personal Data that you are entitled to access, we will try to
provide you with suitable means of accessing it (for example, by mailing or
emailing it to you). We may charge you a fee to cover our administrative and
other reasonable costs in providing the information to you. We will not charge
for simply making the request and will not charge for making any corrections to
your Personal Data.
6.3.There may be instances where we cannot grant
you access to the Personal Data that we hold. For example, we may need to
refuse access if granting access would interfere with the privacy of others or
if it would result in a breach of confidentiality. If that happens, we will
give you written reasons for any refusal.
7. Protection
of Data
7.1SL2
will take reasonable steps to protect your Personal Data against unauthorized
disclosure. To safeguard your Personal Data from unauthorized access,
collection, use, disclosure, copying, modification, disposal or similar risks,
we have introduced appropriate administrative, physical and technical measures
such as up-to-date antivirus protection, encryption and the use of privacy
filters to secure all storage and transmission of Personal Data by us, and
disclosing Personal Data both internally and to our authorized third party
service providers and agents only on a need-to-know basis.
7.2Despite the foregoing, please note that
no method of transmission over the Internet or method of electronic storage is
completely secure. While security cannot be guaranteed, we strive to protect
the security of your information and are constantly reviewing and enhancing our
information security measures.
8. Retention
of Data
8.1We retain such Personal Data as may be
required for business or legal purposes, and such purposes may vary according
to the circumstances.
8.2We 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.
9. Links
to Third Party Websites
We may provide links to websites
and resources operated or provided by third parties, including for example our
business partners, with different privacy practices ("Third-Party
Websites"). When you use a link online to visit a Third-Party Website,
you will be subject to that Website’s privacy and security practices, which may
differ from ours. You should familiarize yourself with the privacy policy,
terms of use and security practices of the linked Third-Party Website before
providing any information on that Website.
10.Visiting
Our Platform from Outside Singapore
If you are visiting our Platform
from outside Singapore, please be aware that your information may be
transferred to, stored and processed in Singapore where our servers are located
and our central database is operated. The data protection and other laws of
Singapore and other countries might not be as comprehensive as those in your
country. Please be assured that we seek to take reasonable steps to ensure that
your privacy is protected. By using our services or by accessing the Platform,
you understand that your information may be transferred to our facilities and
those third parties with whom we share it as described in this Privacy Policy.
11. European
Union Privacy Rights
11.1Under the General Data Protection
Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an
individual protected by the GDPR you may have certain rights in relation to the
Personal Data we hold about you, which we set out below.
These rights include:
(a)
The
right of access.
(b)
The
right of data portability.
(c)
The
right of rectification.
(d)
The
right of erasure.
(e)
The
right to restrict processing.
(f)
The
right to object.
11.2To request information about or avail
yourself of the above rights, please send an email to [email protected] with
"GDPR Request" in the subject line. In the email please describe,
with specificity, the GDPR right you are requesting assistance with. Please
note additional information may be requested prior to initiation of a request
and that we reserve the right to charge a fee with respect to certain requests.
Upon completion of our review, you will be notified if your request has been
granted, denied, or exemptions apply.
The Right of Access
11.3You have the right to know whether we
process Personal Data about you, and if we do, to access Personal Data we hold
about you, how we use it and who we share it with. If you require more than one
copy of the Personal Data we hold about you, we may charge an administration fee.
11.4We may not provide you with certain
Personal Data if providing it would interfere with another’s rights (eg. where providing the Personal Data we hold about you
would reveal information about another person) or where another exemption
applies.
The Right of Data Portability
11.5You have the right to receive a subset of
the Personal Data we collect from you in a structured, commonly used and
machine-readable format and a right to request that we transfer such Personal
Data to another party. The relevant subset of Personal Data is data that you
provide us with your consent.
11.6If you require us to transfer the Personal
Data to a third party, please provide us with relevant details of that third
party and note that we can only do so where it is technically feasible. We are
not responsible for the security of the Personal Data or its
processing once received by the third party. You understand that we may not
provide you with certain Personal Data if doing so would interfere with
another’s rights (e.g. where providing the Personal
Data we hold about you would reveal information about another person).
The Right of Rectification
11.7You have the right to correct any Personal
Data held about you that is inaccurate by logging into your account or
contacting us at [email protected].
The Right to Restrict Processing;
The Right of Erasure
11.8You may request that we stop processing
the Personal Data we hold about you (other than for storage purposes) and/or
erase the Personal Data we hold about you in the following circumstances:
(a)you believe that it is no longer
necessary for us to hold the Personal Data we hold about you;
(b)we are processing the Personal Data we
hold about you on the basis of your consent, and you wish to withdraw your
consent and there is no other ground under which we can process the Personal
Data;
(c)we are processing the Personal Data we
hold about you on the basis of our legitimate interest and you object to such
processing. Please provide us with detail as to your reasoning so that we can
assess whether there is an overriding interest for us to retain such Personal
Data;
(d)you no longer wish us to use the
Personal Data we hold about you in order to send you any marketing and/or
promotional materials; or
(e)you
believe the Personal Data we hold about you is being unlawfully processed by
us.
11.9Please provide as much detail as possible
on your reasons for the request to assist us in determining whether you have a
valid basis for erasure. However, we may retain the Personal Data if there are
valid grounds under law for us to do so (e.g., for the defence
of legal claims or freedom of expression) and we will inform you in writing if
that is the case. Please note that after acceding to your request and/or
deleting the Personal Data, we may not be able to provide the same level of
services to you due to a lack of information.
11.10To exercise any of your rights under this
section, please log into your account or contact us at [email protected].
The Right to Object
11.11At any time you have the right to object to
our processing of Personal Data about you by contacting us at [email protected].
Please provide us with detail as to your reasoning so that we can assess
whether there is a compelling overriding interest in us continuing to process
such data or we need to process it in relation to legal claims.
12.Changes
to Privacy Policy
We will occasionally update this
Privacy Policy to reflect changes in our practices and services. If we make any
material changes in the way we collect, use, and/or share personal data that
may impact you, we will notify you by sending an e-mail to the e-mail address
you most recently provided us in your account, profile or registration (unless
we do not have such an e-mail address), and/or by prominently posting notice of
the changes on the Platform. We recommend that you check our Platform from time
to time to inform yourself of any changes in this Privacy Policy or any of our
other policies. All communications, transactions and dealings with SL2 will be
subject to the latest version of this Privacy Policy in force at the relevant
time.
This Privacy Policy was last updated on 20 March 2023.