PRIVACY AND DATA PROTECTION POLICY
Last Updated: 1 April 2019
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.
1. Types of Data Collected
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 cplect 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:-
- NRIC number;
- Contact details;
- Income level;
- Body features (eg. height, weight, hair and eye colour);
- Education background;
- Marital Status;
- Personal interests;
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. Collection of Anonymised Data
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:-
- 2.4.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain circumstances, your IP Address remains the same from browser session to browser session. However, in the event that a consumer Internet access provider is utilised, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyse the flow of webpages on our Website.
- 2.4.2 “Cookies” refer to small pieces of data that a website sends to your computer’s hard drive or mobile device’s internal storage while you are viewing the said website. Our Website utilises both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain in your computer until you actively take steps to delete them) so as to provide you with a more personalised and interactive experience on our Website. By changing the options on your Internet browser and adjusting the settings in your mobile device (subject to your version of operation system and your device’s features), you can control whether to accept or decline cookies.
- 2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Website and your pattern of browsing our webpages as well as your access of our Website, for the purpose of allowing us to assess the attractiveness of the content on our Website, and the flow of webpages and layouts that appeal to you. Clear GIFs are also commonly known as “web beacons” and may be included on our Website, and generally works in conjunction with cookies to identify users and user behaviour. Some of our HTML based emails also utilise Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage, feature or service on our Website is accessed, and a description of the webpage, feature or service on our Website in which the clear GIF resides. Such collected Anonymised Data helps us to determine the effectiveness of the way our webpages, features and services are arranged on our Website, our modes of communications and promotional campaigns.
- 2.4.4 “Third-party web analytics” refer to services provided by third party service providers for the assessment, analysis, measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website. One of the most well-known third-party analytics service is “Google Analytics”.
- 2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences offline which will then be updated and synchronized when you go online.
- 2.4.6 “Dynamic device identifiers” refer to “identifier for advertisers” or “IFA”, which is a random, anonymous number assigned to an end-user of the iPhone or iPad and is temporary, allowing it to be blocked like a cookie. When an end-user views an application or browses the internet, the end-user’s presence generates a call for an advertisement as the publisher’s site that the end-user is viewing will pass the IFA to the ad server and the advertiser is then able to serve the end-user with an advertisement relevant to the topic being viewed. IFA can also be used to identify whether the advertisements resulted in end-users downloading applications or purchasing products that were advertised. The IFA does not identify the end-user personally, it provides an aggregated audience data that advertisers can target with advertisements. IFA can be opted out of via the settings in the end-user’s device (by default, the IFA is enabled), subject to the availability of such options in the version of your operating system and the features of your device.
3. Your Consent to our Collection, Retention and Use of Personal Data
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:-
- (i) When you sign up for our Updates, access our Website for information, or you email or call us with any queries, you will be required to provide us with your Personal Data in order for us to add you to our mailing list, to enrol you in the course/workshop/ seminar you requested for, or to revert to your queries.
- (ii) When you register for a seminar, enrol for Events or other services, sign up for any Updates, enrol for any Events, or loyalty programme, utilise any of our Services, enter into a subscription plan, or participate in promotions (offline and online) that we (or our other business partners) provide, we will require your Personal Data in order to keep a record of and provide you with the benefits that accompany your course registration, usage of our Website, our Services, any Events enrolled for, service engagement, participation in loyalty programme and/or promotional campaigns (whether online or offline). Unless you withdraw your registration for any Events, terminate any engagement of our services, cancel your access to our Website, withdraw from our loyalty programme or promotional campaigns, or our relevant promotional campaign ends, we will keep your Personal Data for as long as you are still access our Website or any of our Content, you are still a user of any of our Services, a participant of any of our Events, a subscriber to our Updates, our loyalty programme and/or promotional campaigns (whichever ceases the latest) so that we can provide you with the relevant benefits. Accordingly, we will retain your Personal Data for as long as we are of the reasonable opinion that you may still be interested in any of our Services, Content, Events, our new trainers and consultants, profiles, dates, products and/or services so that our Company can be expeditious in the provision of our services or products whenever you should seek a engage any of our services, a delivery of any of our products or our assistance. In the event that you notify us that you wish to terminate all access to our Website, Updates and Events as well as ceasing all communications to and from our Company and terminating all engagement of our services, for legal and audit purposes, we will keep your Personal Data for seven (7) years thereafter the last participation, expiration date of your membership, or other transaction that you have performed via our Website.
- (iii)Without limiting the scope of Clause 3.1(ii) above, when you engage GaiGai to assist in procuring matches, scheduling dates and/or other social activities for you, GaiGai will use your Personal Data for the aforesaid purpose which will include internal processing and analyzing of profiles to identify potential compatible matches, sharing of brief profiles between members, customers or users to solicit interests in being matched-up, and storing of your Personal Data for future matching activities. For the avoidance of doubt, only minimal Personal Data and primarily Anonymised Data is shared with your potential matches before the actual meet-up/date.
- (iv)When you click on any of our Company’s Google ads or other internet based advertisements for more information regarding our Website or our Services, available Content, Updates, services or products, we collect the Personal Data that you provide in order to follow up with you pertaining to your interest in the aforegoing.
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. Disclosure of Personal Data
4.1 We may need to disclose your Personal Data to:-
- third party service providers in order for us to facilitate your access to and use of our Website, our Services, download Content, register for our Events, participate in our promotions, for us to contact you as you may have requested via our Website, email or telephone, for us to maintain and update your records to ensure that you receive our replies to your queries, for us to follow up on any delivery of products or services that you may have requested for, and to provide you with any other updates and perks accompanying your registration to use or attend our Events, engagement for our Services, participation in any loyalty programme and/or promotional campaigns. The aforesaid third party service providers have a contract with us to perform the services necessary for you to use our Website, our Services, receive Updates and/or our services or products that you might have ordered, and such third party service providers therefore include but are not limited to webhost companies, website maintenance companies, database storage companies, loyalty programme service providers, app stores, platform maintenance providers, credit bureaus, payment solutions companies, credit card associations, financial institutions, companies that assist to perform mass mailing on our behalf, courier and logistics companies, etc.;
- our organizers, hosts, trainers and consultants who may need your information in order to conduct the Events that you have registered for appropriately, including but not limited to taking attendance of participants and being aware of any particular sensitivities, preferences or medical conditions that you may have notified us of during your enrolment;
- our other customers in order for them to socialize, communicate or meet up with you (or to decide if they wish to) as per your indicated requests and/or preferences;
- our book-keepers, accounting firms, audit firms, corporate secretarial firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;
- governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data;
- (vi) where disclosure is necessary to respond to an emergency that threatens the life, health or safety of the individual or another individual;
- (vii) subject to the conditions in sub-clause (vi) above, there are reasonable grounds to believe that the health or safety of the individual or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way;
- (viii) when defending against any allegations, claims or legal actions directed against GaiGai or a related company of GaiGai where such related company has been providing services to, or Activities for, you;
- (ix) credit bureaus, credit rating agencies and fraud preventing companies for the purpose of minimizing fraudulent activities via your Personal Data; and
- our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, trade sale, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding;
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. Transferring Personal Data out of Singapore
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. Accurate and Complete Personal Data
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. Do-Not-Call (“DNC”) Provisions and Registries
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 email@example.com.
8. Withdrawal of 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. Access and Correction of Personal Data
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 firstname.lastname@example.org.
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.
9.4 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 email@example.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.
12. Third Party Sites, and Social Network 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. Governing Law and Jurisdiction
14. Citizens of and Residents in Members of the European Union
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.
14.5 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.
14.7 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:-
- You have the right to request access to, correction of, updating or deleting of your Personal Data held with us;
- You have the right to object to processing of your Personal Data based on our legitimate interests, and also the separate right to object to direct marketing activities and communications from us;
- You have the right to request that in certain situations, to restrict processing of your Personal Data;
- You have the right to request for your Personal Data in electronic format for portability;
- You are entitled at any time to opt-out of marketing communications. Please opt out by clicking on the “opt-out” or “unsubscribe” hyperlink in the marketing e-mails that you may receive. To opt-out of other forms of marketing (such as letters via post, SMSes, Whatsapp, or telemarketing), please notify us using the contact details as set out in Clause 14.8.
- You are entitled to withdraw your consent to our collection and processing of your Personal Data at any time. However, there may be consequences (such as your inability to communicate with your selected dating prospects or to receive our services that you have paid for) arising from such withdrawal which we will inform you at the appropriate juncture. For the avoidance of doubt, your withdrawal of consent will not render our prior processing of your Personal Data unlawful, nor will your consent withdrawal impede the processing of your Personal Data performed based on lawful processing grounds other than consent.
- You may at any time submit a complain to a data protection regulatory authority about our collection and use of your Personal Data. Please check with your local data protection regulatory authority for more details in submitting such complaints.
- We will respond to all requests we receive pertaining to the exercise of an individual’s data protection rights in accordance with applicable data protection laws.
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.