1. OVERVIEW


    1. Pinheads Interactive is committed to protecting and respecting your privacy.


    2. This Privacy Policy applies to all persons and entities that access the Platform. By accessing and / or using the services available on or through the Platform, you hereby acknowledge that you have read and agree to the terms of this Privacy Policy.


    3. The Privacy Policy is designed to assist you to understand how we collect, use, disclose and/or process the Personal Data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your Personal Data.  Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.


  2. DEFINITIONS


    1. “Personal Data” means information or data which can be used to directly or indirectly identify an individual who is a natural person including:-
       
      1. full name;


      2. identification number (for example, identification card, passport or social security number);


      3. date of birth; 


      4. correspondence address; 


      5. the type of Service and/or Product utilised;


      6. banking and financial record; and


      7. your personal details from Third Party Sites for e.g. Facebook.


    2. “Selected Third Parties” refers to the third parties set out at section 4.5 below.


  3. INFORMATION COLLECTION


    1. From time to time, Pinheads Interactive may collect information and data about you, including information and data:


      1. that you provide or is provided to by any person authorised by you;
      2. in relation to each of your visit to our Platform; and
      3. from such other third parties authorised by you and publicly available sources.


    2. Through you, Pinheads Interactive may also collect information and data about your family members, friends and other individuals (collectively all of the foregoing who are natural persons, (“Relevant Individuals”).


    3. In this regard, Pinheads Interactive may collect the following information and data stated at section 3.1 and 3.2 as follows:


      1. Any information or data about you and/or such Relevant Individual(s) that can identify you or such Relevant Individual(s), including but not limited to name, date of birth, passport, national identity card number or other identification number or particulars, address, email address, phone number, contact details, financial and credit card information, personal description and photograph, products and services portfolio information, transaction patterns and behaviour, financial background, educational background and demographic data;


      2. Any information and data about you and/or such Relevant Individual(s) generated and/or provided to us in the course of accessing our Platform and undertaking any activity on our Platform. For example, your registered username for the Platform, search results and history for Service and Product within our Platform, Service and Product Submissions history, records of transactions for Service and Product provided via our Platform, records of participation in any Interactive Service on our Platform, and your answers to questions intended for security verification;


      3. Any information and data about you and such Relevant Individual(s) generated and/or provided to us in the course of maintaining the relationship between us and you including account review reports and records of correspondence with you over the phone or via email;


      4. Any information and data about you collected in relation to each of your visit to our Platform including:


        1. technical information, including the Internet protocol (IP) address used to connect your computer or Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;


        2. site visit information, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and


        3. information and data from Cookies or other technologies deployed on our Platform. For detailed information on such Cookies and technologies and the purposes for which we use them see our Cookie Policy.


      5. Any information and data about you collected by us when you participate in events organised by us, such as functions, seminars, contests or reward programs, which may include photographs, videos and voice recording of you;


      6. Any information and data about you which we receive if you use any of the other websites operated by us, our Affiliates or the other services provided by us, our Affiliates. In such a case, we will have informed you and obtained your consent for the collection of such information or data about you by the relevant Privacy Policy contained from such other websites operated by us.


      7. Any information and data about you which we receive from Selected Third Parties (set out at section 4.5 below);


    4. Information and data about you and such Relevant Individual(s) which are referenced above at section 3.3 shall collectively form part of Personal Data.
  1. Use and Disclosure of Personal Information and Data


    1. Where deemed necessary and appropriate by Pinheads Interactive and in accordance with applicable laws, rules, regulations, Personal Data may be used and disclosed by Pinheads Interactive for the following purposes to:


      1. grant you access and facilitate the use of our Platform and to ensure that the Site Content, Service, Product, Interactive Services, User Content, Third Party Content and Third Party Sites are presented in the most effective manner for you and for your Device;


      2. provide you with information, Site Content, Service, Product, Interactive Services and User Content that you request from us and access to Third Party Sites and Third Party Content;


      3. carry out our obligations arising from any contracts entered into between you and us;


      4. provide you with information about other Service and Product we offer that are similar to those that you have already purchased or enquired about;


      5. provide you, or permit Selected Third Parties to provide you, with information about Service and Product that we feel may interest you. If you are an existing User, we will only contact you by email, SMS or phone with information about Service and Product similar to those that you had previously considered, booked, registered, subscribed, scheduled or purchased. If you are a new customer, and where you consented to the disclosure of your Personal Data to Selected Third Parties, we (or such Selected Third Parties) may contact you by email or SMS with information about Service and Product;


      6. notify you about changes to our Site Content, Service, Product, Interactive Services, User Content, Third Party Content and Third Party Sites;


      7. administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;


      8. improve our Platform to ensure that the Site Content, Service, Product, Interactive Services, User Content, Third Party Content and Third Party Sites are presented in the most effective manner for you and for your Device;


      9. allow you to participate in Interactive Services and any other interactive features of our Platform, Service and Product, should you choose to do so;


      10. implement and review safety and security measures on our Platform so as to keep our Platform safe and secure;


      11. measure or understand the effectiveness of our advertising and third party advertising on our Platform and on other third party websites, and to deliver relevant advertising to you;


      12. make suggestions and recommendations to you and other Users of our Platform about Service, Products or third party products and services that may interest you or them;


      13. make decisions relating to the opening or continuation of User Account and the establishment, provision or continuation of Service and Product otherwise maintaining accurate “know your customer” information and conducting anti-money laundering, credit and background checks;


      14. provide, operate, process and administer User Account, Service and Product or to process applications for User Account, Service and Product, any transactions (including remittance transactions), and to maintain service quality and train staff;


      15. undertake activities related to the provision of User Account, Service and Product, including the provision of articles, education materials, research reports or similar materials;


      16. provide Product-related services and support, including without limitation, provision of processing or administrative support or acting as an intermediary / nominee / agent in connection with your participation in Product;


      17. provide or grant access to Product-related materials;


      18. fulfil foreign and domestic legal, regulatory and compliance requirements applicable to Pinheads Interactive under any Applicable Laws (including anti-money laundering and tax obligations applicable to Pinheads Interactive, and disclosure to any court, governmental authority, supervisory authority or any other authority or regulator pursuant to relevant guidelines, regulations, orders, guidance or requests from such organisations);


      19. verify the identity and/or authority of your representatives who contact Pinheads Interactive or may be contacted by Pinheads Interactive and to carry out or respond to requests, questions or instructions from verified representatives or other parties pursuant to our prevailing security procedures;


      20. to carry out data processing and perform statistical, trend analysis and planning, for present and future reference;


      21. monitor and record calls and electronic communications with you for record keeping, quality, training, investigation and fraud prevention purposes;


      22. detect, prevent, investigate and prosecute crime and fraud including to aid in any criminal investigation by the relevant authorities of you, such Relevant Individuals or any other person;


      23. enforce (including, without limitation, collection of such outstanding amount(s) owed to Pinheads Interactive) or defend the rights of Pinheads Interactive, contractual or otherwise;


      24. perform internal management to operate control and management information systems and to carry out internal audits or enable the conduct of external audits;


      25. comply with contractual arrangements by or between industry self-regulatory, industry bodies, associations of industry providers or other institutions similar to Pinheads Interactive;


      26. to manage Pinheads Interactive’s relationship with you, which may include providing information to you or a Relevant Individual, about Pinheads Interactive’s products and services, including without limitation, Service and Product, where specifically consented to or where permissible under applicable laws and regulations;


      27. for marketing products or services by various modes of communication including mail, telephone call, SMS, fax, electronic mail, internet, market research, and designing or refining any similar products or services including by conducting market research, data analysis, and surveys; and


      28. to comply with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information within Pinheads Interactive and any other use of data and information in accordance with any Pinheads Interactive programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities.


    2. We may combine any information and data, regardless of how such information and data were provided to us or collected by us, and use the combined information or data for the purposes set out at section 4.1 above.


    3. We may also use and disclose Personal Data for any other purposes relating to any of the above set out at sections 4.1 and 4.2, which a reasonable person would consider appropriate in the circumstances.

    4. As the purposes for which we may collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose(s) may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent for the collection of such Personal Data, unless processing of your Personal Data without your consent is permitted by law.


    5. We may also share Personal Data with Selected Third Parties including:


      1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;


      2. advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our Users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We may make use of information or data collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;


      3. analytics and search engine providers that assist us in the improvement and optimisation of our Platform;


      4. prospective seller or buyer of business or assets in the event that we sell or buy any business or assets, in which case we may transfer your Personal Data to such buyer or seller as part of the transaction;


      5. any such organisations or persons, if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply any agreements, or to protect the rights, property, or safety of Pinheads Interactive, our customers, Users or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;


      6. agent, contractor or third party service provider who provides administrative, mailing, telemarketing, direct sales telecommunications, call centre, business process, travel, visa, knowledge management, human resource, data processing, information technology, computer, payment or other background checks or other services (including backup services) to Pinheads Interactive in connection with the operation of the business of Pinheads Interactive;


      7. person or entity which is part of the Pinheads Interactive although only to the extent necessary to fulfil the relevant Permitted Purpose;


      8. drawee or drawer bank in connection with any cheque or equivalent processed by Pinheads Interactive;


      9. financial institution with whom you have or propose to have dealings in relation to any Service and/or Product;


      10. person or entity to whom Pinheads Interactive is under an obligation or otherwise required to make disclosure pursuant to legal process or under the requirements of any foreign or domestic law, regulation, court order or agreement entered into, binding on or applying to Pinheads Interactive, or agreement entered into by Pinheads Interactive and any government authority, domestic or foreign, or between or among any two or more domestic or foreign governmental authorities, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations with which Pinheads Interactive is required or expected to comply, or any disclosure pursuant to any contractual, best practices or other commitment of Pinheads Interactive with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside whichever country you access the Platform from including disclosure to courts, tribunals,  legal, regulatory, tax and government authorities or self-regulatory or industry bodies or associations, whether such legal process, obligation, request, requirement, agreement or guidance may be existing currently or created in the future;


      11. financial institution, processing agent, Payment Gateway or any other person who will be involved in remittance transactions or any banking/financial activities; and


      12. actual or proposed assignee of Pinheads Interactive, or participant or sub-participant or transferee of Pinheads Interactive’s rights in respect of you or any other Relevant Individual, all or any part of the assets or business of Pinheads Interactive.


    6. In this regard, the purposes for the use and disclosure of information and data about you which is referenced under this section 4 shall collectively be referred to as “Permitted Purposes”.
  1. ADMINISTRATION AND MANAGEMENT OF YOUR PERSONAL DATA


    1. We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by Pinheads Interactive to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from your not updating us of any changes in your Personal Data that you had initially provided us with.


    2. We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.


    3. We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.


    4. Where your Personal Data is to be transferred out of whichever country you access this Site from, we will comply with the Applicable Laws in doing so.


  2. RIGHT TO REFUSE USE OF PERSONAL DATA FOR MARKETING PURPOSES


    1. You have the right to ask us not to process your Personal Data for marketing purposes. Even after you have given us your consent for your Personal Data to be used for marketing purposes, you may, at any time thereafter, withdraw your consent. You can exercise your right to opt out of such processing by contacting us at email address specified at Section 12 below or by marking on the relevant online forms we use to collect your data.


  3. LINKS TO OTHER SITES


  1. Our Platform may, from time to time, contain links to Third Party Sites and from the websites of our partner networks, advertisers or Affiliates.  If you follow a link to any of these Third Party Sites, please note that these Third Party Sites may or may not have their own privacy policies and that we do not accept any responsibility or liability for these policies or lack thereof.  Please check these policies before you submit any information including your Personal Data to these Third Party Sites.


  2. If you access a page on our Platform that includes a social plugin, your browser may set up a direct connection to the servers of third parties and transfer the social plugin’s content directly to your browser which will then integrate the content with the Third Party Sites and/or our Platform. We have no influence on the extent of the data that third parties collect via its social plugins. If you do interact with the social plugins, e.g. by using the “Like”, “Share”, “Follow” buttons or by posting a commentary, your browser will transfer such information directly to the Third Party Sites where it is being stored and/or published.


  3. If you are an user of a Third Party Site and do not wish the Third Party Site to collect data on you via our Platform and to combine such data with your user data, you may need to log off from the Third Party Site before accessing our Platform. You may also wish to block social plugins by downloading and installing the relevant add-ons for your browser.
  1. ACCESS TO INFORMATION


    1. You have the right to request from us Personal Data about you held by Pinheads Interactive. If you wish to access, update or otherwise change or remove any information that you provide to us, please contact us at email address specified at Section 12 below for assistance. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.


    2. In exceptional circumstances, Pinheads Interactive may deny you access to your Personal Data but we will provide you with an explanation of the reason(s) which prevent us from doing so under the applicable laws. Such exceptional circumstances include but are not limited to where:


      1. An investigating authority or government institution objects to Pinheads Interactive complying with a customer’s request;


      2. The information may, in the exercise of Pinheads Interactive’s reasonable discretion and/or assessment, affect the life or security of an individual; and


      3. Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of law.


  2. CHANGES TO OUR PRIVACY POLICY


    1. We may from time to time vary or amend this Privacy Policy by posting the amended Privacy Policy on this Site. Any use of the Platform, Services and/or Product after the amendment of this Privacy Policy will be deemed to be an acceptance of the amended Privacy Policy by you. If you do not agree to the amended Privacy Policy, you have the right to close your account and/or cease using the Platform, Service and Product. Please check this page from time to time as the changes, variations and corrections to the Privacy Policy are binding on you.


  3. MINORS


    1. Pinheads Interactive cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided Pinheads Interactive with Personal Data without parental or guardian consent, the parent or guardian should contact Pinheads Interactive to remove the relevant Personal Data and unsubscribe the minor.
  1. ACKNOWLEDGEMENT


    1. You acknowledge that where you fail to supply relevant information or data or withdraw consent in respect of the collection, use and/or disclosure of relevant information or data as described in this Privacy Policy, Pinheads Interactive may be unable to open or continue User Account(s), or establish or provide or continue any Service and Product, or continue to allow you to use or access our Platform, Site Content, User Content, Service, Product, or Interactive Service. Pinheads Interactive will inform you of the likely consequences for such withdrawal of consent should you inform us of your intention to withdraw your consent.


    2. You warrant to Pinheads Interactive that where you or your representatives are responsible for the provision of any information or data relating to any person(s) to Pinheads Interactive, or has provided any such information or data to Pinheads Interactive, you have informed and obtained the consent of the person(s) concerned to allow Pinheads Interactive to collect, use and/or disclose information relating to the person(s) concerned as described in this Privacy Policy.

    3. You agree that you have obtained the consent of all such Relevant Individual(s) so that any information or data of a Relevant Individual may be processed, kept, transferred or disclosed in and to any country as Pinheads Interactive considers appropriate or necessary, in accordance with applicable law for the Permitted Purposes. Such data may also be processed, kept, transferred or disclosed in accordance with the local practices and laws, rules and regulations (including any regulatory requests, governmental acts and orders) in such country/jurisdiction.


  2. CONTACT
    Questions, comments and requests regarding this Privacy Policy are welcomed and may be directed to Pinheads Interactive’s Data Protection Officer at the following address:-

    ask@pinheadsinteractive.com

DATA PROTECTION NOTICE

This Data Protection Notice (“Notice”) sets out the basis which Pinheads Interactive (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Notice:

customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

5. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the

goods and/or services requested by you;

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(h) any other purposes for which you have provided the information;

(i) transmitting 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; and

(j) any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.

7. The purposes listed in the above clauses 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 us to enforce our rights under any contract with you).

WITHDRAWING YOUR CONSENT

8. 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 in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

9. 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.

10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. 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, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

14. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

15. To safeguard your personal data from unauthorised 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 authorised third party service providers and agents only on a need-to-know basis.

16. You should be aware, however, 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.

ACCURACY OF PERSONAL DATA

17. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

19. We 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.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

20. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

21. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request at:

ask@pinheadsinteractive.com

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

23. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Effective date : 1/1/2019

Last updated : 23/8/2019