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Last Updated: 15 Jan 2022
This Privacy and Data Protection Policy (“Privacy Policy“) sets out the terms and conditions under whichGAIGAI PTE. LTD. (“our Company“, ‘ we‘, ‘our‘, or ‘us‘) collects information via our website www.letsgaigai.com (” Website“), our services, our events, our training courses, our workshops, our seminars, our membership programmes, our packages, our other activities (individually and collectively, our ” Events“), registration of interest for any of our Events, and any other services and products provided by our Company whether by itself or in conjunction with other third parties (individually and collectively, our “Services” which shall include our Events). As such, this Privacy Policy applies to any person (hereinafter referred to as “you” or “user“) who accesses, reads, participates in, or uses our Website (including any variations, updates, support patches or successors), any of our Services, and/or any information, write-ups, photographs, pictures, profiles, charts, articles, testimonials, tips, our Events schedules, advertisements, media files and other content on our Website and in your account as maintained with us (collectively, “Site Content“), or our newsletters, EDMs, marketing materials, promotional updates, support patches, messages (via any channels), or other emails (collectively, ” Updates“). “Site Content” and “Updates” collectively shall be referred to as “Content“.
In order to serve you better and provide you with the appropriate customer service or product requested for, we require information from you, some of which may be considered as Personal Data (defined in Clause 1.2 below). We understand the importance of the privacy and security of your information, and we have therefore set out in detail below how we collect and use your information. Kindly review the terms and conditions of our Privacy Policy as follows so that you may be reassured that we take data protection seriously:-
A. Please note that your access and use of our Site is subject to our GaiGai Website Terms of Use (“Terms of Use“), the terms and conditions as set out herein this Privacy Policy, our Terms of Service Agreement, and any other terms of service (including rules and guidelines) that may be applicable to your usage of any of our specific Services or participating in our any of our Events, products, features, services or specific aspects of our Website and/or particular activity transacted on our via our Website (collectively, the “Agreement”). Accordingly, by accessing our Website or any of our Content, using any of our Services, or otherwise howsoever providing us with your Personal Data, you are agreeing to our collection of your information pursuant to this Privacy Policy. Should you disagree with any clause in the Agreement, please immediately cease your access to, participation in, and use of our Website, our Content and our Services.
B. In order to maximise your participation in and your utilisation of our Website, our Content, our Services, our products, our other services, and content thereto, request information from us (whether via the telephone, exhibitions, road shows or other events), take-part in our promotions (online or offline), receive our marketing materials, newsletters, updates to our Website, updates on our Events’ schedules, introduction of new workshops, new employees (such as relationship managers), new trainers/consultants, and other persons relevant to our Company or the Services, or updates regarding other information and/or promotions regarding our Website, our Services, our products, and other related matters (our newsletters, forum posts, blogs, updates, direct mailers/emails/EDMS, and/or promotions shall be individually and collectively referred to as our “Updates“), your Personal Data (as defined in clause 1.2 below) has to be provided to us, and we will need to keep and use your Personal Data in order to fulfil the purpose for which you have contacted us, subscribed to our Updates and/or other services.
For expediency and for compliance with any changes in the law, we reserve the right to amend this Privacy Policy in our sole discretion at any time without prior notice to you, and you agree that your continued access to and/or use of our Website, our Services, and/or other associated platforms, your continued desire to view our Content, receive our Updates, check for Events’ schedules online or offline, participate in any of our Events, go on a date co-ordinated by GaiGai, keep in contact with us via email, and/or take-part in our promotions (whether notified to you or made available online or offline, via the telephone, road shows or other events) constitutes your unconditional acceptance of our amended Privacy Policy. You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy at our Website regularly.
1.0 When you visit, access or use our Website, our Services, and/or associated platforms, sign-up for any of our Updates, email us, call us, or take part in our promotions (offline or online), we collect Personal Data and Anonymised Data.
1.2 “Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively with other information to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, gender, income range, dating preferences, priorities/values, residency status, bank account details, and credit card details.
1.3 “Anonymised Data” refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.
1.4 GaiGai, in the process of profiling each customer or member, will be collecting Personal Data under the following main categories:-
which are relevant for us to provide our Services in selecting potential match and dates for you. For the avoidance of doubt, no online tracking technology is deployed to capture Persona Data beyond the information submitted via our online profiling form.
2.1 When you access our Website or any of our Services, and/or email us, we collect Anonymised Data about you via the application of generally acceptable web technologies including but not limited to “web beacons”, “cookies”, “clear GIFs”, “widgets”, “online evaluations”, “surveys”, “HTML5”, “dynamic device identifiers”, and third-party web analytics such as “Google analytics” (collectively, ” Acceptable Technologies“). This automatic collection of non-personal information includes (without limitation) collection of your IP Address, the web browser software that you used, the type of smart phone or tablet that you may be using, the operating software/platform of your device, your sign-up(s) for any Updates or information via our Website and/or Services, the specific pages of our Website viewed by you, the specific categories or features in our Website accessed by you, the sharing of any information by you via our Website, any third party application used in conjunction with our Website or Services, your downloading of related applications, and third party websites that you may have visited prior to our Website. Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Website and our Services.
2.2 As part of the Anonymised Data that we collect, when you access our Website via your mobile device or tablet, we will also collect information regarding the type of mobile device or tablet that you are utilising so that our Website and our Services can provide you with the version of our Website best suited for access on your mobile device or tablet.
2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or disable our use of the Acceptable Technologies. In the event that you choose to access our Website or our Services without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.
2.4 To better assist you in understanding the generally Accepted Technologies used in our collection of Anonymised Data include:-
3.1 In order for our Company to provide you with our Services and products, including but not limited to our making available for your review online information regarding our Services, our past and upcoming Events, profiles, and allowing you to contact us via our Website, email or telephone, you agree and consent to our Company collecting, using and retaining your Personal Data as follows:-
2. In addition, we will retain your Personal Data where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, repayment of loans, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.
4.1 We may need to disclose your Personal Data to:-
Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Data to third parties, and only authorised personnel of GaiGai who have signed written obligations of confidentiality are permitted to access your securely kept Personal Data in order to provide the Services that you have requested for from GaiGai. We are careful in our selection of third party service providers, and all such third party service providers are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations herein this Privacy Policy. In general, the third party service providers engaged by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
4.2 During your period of membership, package subscription or Event’s enrolment with GaiGai, you may be exposed to personal information of other GaiGai members, customers or users of the Website. You agree not to divulge or disclose any of such information to other third parties without prior consent, now or any time in the future.
5.1 Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012.
6.1 In order for us to provide you with access to our WebSite, our Services, our Content, our Updates, and all their respective associated functions, our services and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you warrant that the Personal Data that you provide to us is accurate, and that all Personal Data as may be relevant for that particular purpose/circumstance has been provided. In the event of any changes or updates to your Personal Data, you undertake to promptly inform us in writing of such changes, failing which we shall not be responsible for any consequences thereto (including but not limited to your non-receipt of communications sent by us, non-completion of any transactions performed via our Website, and/or your inability to access our Website).
7.1 We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at contact@letsgaigai.com.
8.1 You may at any time withdraw your consent to our use, retention, disclosure or transfer of your Personal Data pursuant to this Privacy Policy by emailing our Data Protection Officer at contact@letsgaigai.com . However, please note that any such withdrawal of consent may result in us being unable to continue providing our services or fulfilling our contractual obligations with you, including but not limited to termination of your access to our Website and Services, inability to transaction or complete an ongoing transaction started via our Website, cancellation of any engaged services, purchased Services, enrolled Events, and thereby all deliverables that would have been provided thereunder, termination of loyalty programme benefits that would otherwise have been available to you, inability to access your status and logs that would be otherwise reflected in your registered account with us, cessation of your access to our Website, our Services and all Content as well as other features thereto, inability to provide you with the opportunity to participate in promotions, inability to fulfil any request for information that you may have submitted to our Company, inability to allow your participating in any requested seminar, fulfill any purchase orders, and potentially inability of third parties to provide you with their services or products as you might have contracted with them through our Website or Services, regardless of whether you have made payment for such engagements, enrolments, services or products. Accordingly, your withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company, as well as termination of any contracts with any third parties you may have engaged with through our Website, our Company or Services, for which our Company expressly reserves its rights and remedies thereto. Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact him to withdraw your consent.
8.2 Should you wish to unsubscribe to our email updates, please click the “unsubscribe” option made available in our emails to you. Please note however that this may result in our being unable to make available to you updates on our products and services, Events, our Company, your benefits under our membership programme, and any ongoing promotions.
9.1 Should you wish to access, update or make corrections to your Personal Data held with us, or if you wish to receive further clarifications on your Personal Data held with us, please email our Data Protection Officer at contact@letsgaigai.com.
9.2 There will be no administrative fees or other charges levied for any request to correct or update your Personal Data. However, for all other requests such as accessing your Personal Data held with us, obtaining a record of when you accessed our Site or Services, the date of your requests for information, etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.
9.3 Should you have any queries or complaints pertaining to this Privacy Policy, our Terms of Use, any specific terms of service of the Agreement, your Personal Data as registered with us, or in relation to our Company’s use, retention, disclosure or transfer of your Personal Data, or should you desire to learn more about our data protection policies and security measures, please email our Data Protection Officer at contact@letsgaigai.com.
9.4 In the event that you are a citizen or resident of the European Union, please refer to section 14 ” Citizens of and Residents in Members of the European Union” below for more information.
10.1 Our Website, our Services, our Content, our Updates, our Events, our promotions, our services and products are not meant for persons who may be defined as minors under applicable law. As such, if you are below 21, please terminate all access to our Website and Services immediately. We reserve the right (but not the obligation) to demand at any time evidence for our review to verify that you are above 21 years of age. In the event that you are under 21 years of age, or we reasonably suspect that you are under 21 years of age and you are unable to prove otherwise, all your subscriptions and purchases with us shall be immediately terminated and no refunds of any kind shall be provided to you.
10.2 To clarify, we do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access our Website, use our Services, enrol for any of our Events, download or access our related applications, email us, or provide us with Personal Data without their parental/guardian’s consent. If a parent or guardian becomes aware that his or her minor has accessed our Website or our Services or provided us with Personal Data without his/her consent, he or she should contact our Data Protection Officer at contact@letsgaigai.com promptly.
11. Security Measures for Protection of Personal Data
11.1 We ensure that our Website is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.
11.2 Your Personal Data is kept securely and protected against unauthorized access and disclosure. We utilise security means such as (without limitation) password protection, encryption, locked and restricted access. We have strict policies in place restricting access to Personal Data to only our authorized personnel on a need-to-know basis.
11.3 We will take practical steps to ensure that your Personal Data will not be kept longer than as set out herein this Privacy Policy, or for as long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate business or legal purposes, whichever is the latest.
12.1. Our Website, our Services, our Updates, our Content, emails and other promotional messages may contain hyperlinks to websites operated by third parties. However, such third party websites are not governed by our Privacy Policy or Terms of Use. We are not responsible for the privacy policies or data security of such third party websites, even if they are co-branded with our Company name or logo, or our Website or Services or promotional messages display products or services that originate from such third parties. As such, we urge you to learn about the privacy policies of these third party websites before accessing or using them, and to be careful about providing any Personal Data to such third party websites. We seek your understanding that we are not liable for any acts or omissions or any loss or damage that you may suffer due to your use or access of such third party websites.
12.2 Our Company may utilise reputable social media/network sites such as, but not limited to Facebook, Twitter, Instagram, Pinterest and LinkedIn (collectively the “Social Media Sites“) so as to connect to your social networks. In order to generate interest in our Website and our Services, our products and services amongst the contacts in your social networks and to allow you to share your interest in our Website, our Services, our Updates, our Content, our training course/workshops/seminars, our officers, our trainers or other course participants, and/or our products and services, we may provide access to our Website to the third party Social Media Sites, and there may thus be links on our Website to such Social Media Sites. The aforesaid association with the Social Media Sites does not constitute any endorsement or recommendation of any of the Social Media Sites by our Company nor vice versa. As per clause 12.1 above, kindly review the terms of use and privacy policies of the Social Media Sites before you use or access such Social Media Sites in conjunction with our Website or Services or any of our promotions and our products or services made available via any Social Media Sites.
12.3 The association of our Website and/or Services with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company. Such information which we collect about you shall constitute public information that is available in the general domain because such information was made publicly available by the Social Media Sites. Should you prefer that we do not collect your information from the Social Media Sites, please (i) do not use the features or links that associates our Site and/or Services with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Website and mobile application. Please note that our Company cannot control nor is our Company howsoever responsible for the sharing of your information by the Social Media Sites with third parties.
12.4 One of the features which you may see available on our Website and Services in association with the Social Media Sites, is the “like” feature by Facebook, and other similar functions provided by other Social Media Sites. When you “like” our Website or any of our Services or our products or services, information about our Website or Services, our products and services will be made known to your network within your Social Media Sites’ accounts via a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with our services, products or services that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features. If you are not agreeable to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site. Please note however that we are not obliged to display on our Website or any related webpages (whether on Social Media Sites or otherwise) any of your information, including but not limited to your photo or name, even if you “like” our Website, our Services, our other services or products. In the event that any of your information, product or service endorsements (including your liking of our Website, our Services, any of our Company’s other services or products, or third party services or products featured on our Website or Services) appear on our Website or any related webpages (whether on Social Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our Site or any related webpages.
13.1 The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy and your use of our Website and/or our Services (including but not limited to our matchmaking services, workshops and other activities), you must first contact our Data Protection Officer at contact@letsgaigai.com regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.
If you have any questions regarding this Privacy Policy or your Personal Data, please contact our Data Protection Officer at contact@letsgaigai.com.
14.1 This Section 14 of the Privacy Policy is applicable only if you are a citizen of, or resident in, any members of the European Union. The clauses hereunder this Section 14 supplements the above provisions of this Privacy Policy which will still apply to you.
14.2 Our collection, use, processing and retention of Personal Data is as described above. Our legal basis for processing of Personal Data is dependent on the context in which the Personal Data was collected, which will therefore also determine the type of Personal Data collected. Nonetheless, collection and processing of Personal Data is usually only performed where it is necessary for us to provide our services or products to you, and for us to comply with applicable legal requirements (as further described in Sections 3, 4 and 5 above), where necessary for our legitimate business or legal interests that are not superseded by your rights, and/or where you have consented.
14.3 In the event that your Personal Data has been collected based on our legitimate interests, the said legitimate interest is generally for the operation of GaiGai and the provision of our services, managing our relationship with you such as updating your membership or account status, communicating with you in order to provide you with our services, updates to our Website, activities, events, offers, and other legitimate business interest such as replying to your requests, co-ordinating your selected dates, developing our Website and our services, offering promotions, publicity, or security enhancements, crime prevention and fraud detection. Should we have other legitimate interests, we will where appropriate notify you of them clearly at the relevant time.
14.4 In the event that you are requested to provide your Personal Data in order to enter into a contract with us, or for compliance with a legal obligation, we will make it clear to you at the appropriate juncture and advise you accordingly as to whether the provision of your Personal Data is indispensable, together with the possible consequences that may ensue should you still choose not to provide your Personal Data under the circumstances. To illustrate, as GaiGai is providing you with consultations, events and services to source for and enhance your chances of meeting suitable dating partners, in order for you to fully benefit from and utilize our services, your Personal Data would have to be provided to us and processed as per the above provisions of this Privacy Policy.
14.5 Your Personal Data will be retained and processed securely for as long as there is still ongoing legitimate commercial need for such retention and processing. Examples of legitimate commercial needs would be to allow you to continue accessing our Website, to maintain your account, membership or purchased package, provide consultations, sourcing for suitable dating partners, co-ordinating dates and other services to you, investigating and defending any potential legal action or claim against us, and as may be required or permitted by applicable laws (including laws pertaining to taxation and keeping of accounting records). As soon as there is no more legitimate business or legal needs for us to retain and process your Personal Data, your Personal Data will be deleted or anonymised (where possible), and in the event that it is not possible (such as storage of Personal Data in backup archives), we will ensure the security of your Personal Data that is being stored, segregate it so that no further processing will be carried out using your Personal Data, and will delete your Personal Data once possible.
14.6 As we are a business based in Singapore, your Personal Data will be transferred to countries that are not members of the European Union, including countries such as Singapore and the United States which may not mandate the same obligations of data protection as the European Union. Nonetheless, please be assured that we adopt appropriate measures to ensure that recipients (as described in Section 6 above) of your Personal Data are bound to obligations of protection, security and confidentiality similar to the obligations hereunder this Privacy Policy, including but not limited to the use of contractual clauses in our contracts/terms and conditions with such recipients.
14.7 As a citizen of, or resident in, any members of the European Union, you can exercise your following data protection rights at any time by contacting us via the details provided in Clause 14.8:-
In the event that you become aware of changes or inaccuracies in your Personal Data, please notify us promptly for the updating and correction of our records.
14.8 Should you have any queries, concerns or requests pertaining to the legal basis pursuant to which we collect, use and process your Personal Data, your Personal Data held with us, this Privacy Policy or any other matters related to your privacy associated with our Company and our services, please email our Data Protection Officer at contact@letsgaigai.com