LAST UPDATED: 24 July 2023
We take your privacy very seriously and have in place policies and practices dealing with data protection. We ask that you read this Policy carefully as it contains important information about our collection, use, processing and disclosure of personal data in our possession or under our control, including information on:
i) our policies and practices for meeting our obligations under laws, regulations and guidelines which concern data protection;
ii) how you may access, correct or make other requests in relation to your personal data in our possession or control as permitted by applicable laws; and
iii) details of our data protection complaints procedure.
1. COLLECTION OF PERSONAL DATA
1.1 Personal data that SquareX collects include name, email address/social media handles, information regarding use of the Application and other relevant information in order for us to provide products and/or services and to share information that may be of interest.
1.2 Personal data may be collected by us, directly or indirectly, for instance:
1.2.1 when you register for an account access and/or use the Application;
1.2.2 when you respond to our promotions, or subscribe to our mailing lists;
1.2.3 when you use our services or enter into transactions with us, or express any interest in doing so;
1.2.4 when you communicate with us by telephone, email, via our website or through other communication channels including social media platforms;
1.2.5 when we seek information about you and receive your personal data in connection with your relationship with us; and/or
1.2.6 when you submit your personal data to us for any reason.
1.3 We also collect personal data from third party sources, for example:
1.3.1 from our business partners and third party service providers;
1.3.2 from third parties who have been duly authorised by you to disclose your personal data to us; and/or
1.3.3 from public agencies or other public sources.
1.4 In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes, including all purposes as set out in this Policy.
2. PURPOSES OF COLLECTION, USE OR DISCLOSURE
2.1 We may collect, use, process, store and/or disclose your personal data for one or more of the following purposes:
2.1.1 to verify your identity;
2.1.2 to conduct and complete transactions, performing our obligations or exercising our rights as set out in binding contractual terms, and otherwise to manage your relationship with us;
2.1.3 to provide, operate, maintain, improve, market or promote our products, services or materials, including the Application and related services and materials;
2.1.4 to process, handle and respond to your enquiries, feedback, requests, applications complaints or incident reports;
2.1.5 to inform you of promotions and updates;
2.1.6 to send you marketing materials;
2.1.7 to generate internal reports such as annual, operational or management reports and to conduct statistical, trade or other forms of analysis;
2.1.8 to improve our products and services;
2.1.9 to resolve any disputes which may arise between SquareX and you;
2.1.10 to respond to legal processes, to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority or to comply generally with any applicable laws, governmental or regulatory requirements, codes of practice, guidelines or rules, of any relevant jurisdiction (and any applicable rules, codes of practice or guidelines), and requests of any governmental or other regulatory authority with jurisdiction over us, including, without limitation, meeting requirements to disclose under the requirements of any applicable law, assisting in law enforcement and investigations by relevant authorities, conducting audit checks or surveillance and investigation, whether in Singapore or elsewhere;
2.1.11 such purposes that may be informed to you when your personal data is collected;
2.1.12 any other reasonable purposes related to the aforesaid or for which you have provided any information to us;
2.1.13 any other incidental business purposes related to or in connection with the above; and/or
2.1.14 to transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
2.2 We may also collect, use, process, store and/or disclose personal data for purposes related to for which you have provided the personal data, in circumstances other than set out in this Policy where required, or permitted, by laws applicable to us or in any relevant jurisdiction, or where we have obtained your consent through other means (for example, pursuant to notices at our premises).
2.3 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way (for example, where we use personal data to enforce our rights under a contract with you).
3. THIRD PARTIES WHO MAY BE PROVIDED WITH PERSONAL DATA
3.1 We may disclose your personal data to the following, whether located within or outside Singapore, for the purposes set out or otherwise referred to in this Policy:
3.1.1 third parties to whom you authorise our disclosure of your personal data (through this Policy or otherwise);
3.1.2 our auditors, professional consultants, lawyers and other advisors;
3.1.3 our business partners;
3.1.4 our service providers or agents; and
3.1.5 insurers, credit providers, courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as agreed or authorised by law.
4.1 We generally rely on the accuracy of personal data provided by you or your authorised representatives. In order to ensure that our records of your personal data is current, complete and accurate, please update us if there are changes to your personal data by writing to our Data Protection Officer at the contact details at the end of this Policy.
5. LINKS TO OTHER WEBSITES
5.1 Our products, services and/or materials may contain links to other websites or applications. However, this Policy only applies to this website, and if you visit other websites or other applications, including through such links, different privacy policies will apply.
6. SECURITY AND RETENTION
6.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and loss of any storage medium or device on which your personal data is stored, we have introduced appropriate administrative, physical and technical measures, including to protect personal data from unintended access.
6.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot and do not guarantee that our systems or applications are invulnerable to security breaches. SquareX makes no warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.
6.3 We keep your personal data only for so long as we need the personal data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements. In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.
7. ACCESS REQUEST/CORRECTION REQUEST
7.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, (b) a correction request to correct or update any of your personal data which we hold about you, or (c) other request in relation to your personal data, as permitted by applicable data protection laws, you may submit your request by contacting the Data Protection Officer.
7.2 If you wish to exercise your rights, please contact the Data Protection Officer. You may be required to submit certain forms or provide certain information in order for your request to be processed. Where permitted by law, SquareX may charge you a reasonable fee to process your request, and will inform you of the fee before processing your request.
7.3 We will respond to your request as soon as reasonably possible, and in accordance with applicable law.
8. CONSENT WITHDRAWALS
8.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you. You may withdraw consent and request us to stop using and/or disclosing your personal data by submitting a request in writing to our Data Protection Officer at the contact details provided below.
8.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
8.3 If you withdraw your consent to any or all use of your personal data or do not consent to the collection of your personal data by us, we may not be able to provide or continue providing you with products, services and/or materials which you have requested, including the Application or part thereof. SquareX requires your personal data to fulfil a contractual obligation to you and you withdraw your consent to collect, use or disclose the relevant personal data for those purposes, SquareX cannot be held liable for breach of that agreement. SquareX’s legal rights and remedies in such event are expressly reserved.
8.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, usage and disclosure without consent is permitted or required under applicable laws in any jurisdiction.
9. TRANSFERS OF PERSONAL DATA
You agree that we may transfer personal data to locations other than where you are located, including jurisdictions which protect personal data to a greater or lesser degree than the protection under Singapore law.
10. CHANGES TO THIS POLICY
10.1 We keep this Policy under regular review. If we change this Policy we will post the changes on www.sqrx.com, or such other means as we deem appropriate.
10.2 Where you continue to provide personal data to us as described in this Policy, or continue to use our products, services or materials, including the Application and/or related services and/or materials, this will constitute your acknowledgement and acceptance of a revised Policy.
11. HOW TO CONTACT US / DATA PROTECTION OFFICER DETAILS
11.1 If you have any queries or comments on this Policy or the use of your personal data, or if you wish to lodge a privacy-related complaint, please contact SquareX’s Data Protection Officer at:
Email address: email@example.com
SquareX will investigate your queries, comments or complaint, and will use reasonable endeavours to respond, in accordance with applicable laws.
12. GOVERNING LAW
12.1 This Policy shall be governed by and construed in accordance with Singapore law.