PRIVACY POLICY
(Last updated on 31-07-2022)
We, at, QIEN TECHNOLOGIES PTE. LTD., the owners and operators of the Mobile Application REDEMPO (collectively, “we”, “our” or “the Company”), are committed to protect the privacy of our business Partners, Clients, end users (“you”, “user”, “visitor” or “client”) who have access to any of the data resources monitored by our software (“the “Software”). We encourage you to read this Software Privacy Policy (“Privacy Policy”) carefully and use it to make informed decisions. By using our Software, you agree to the terms of this Privacy Policy, and your continued use of the Software constitutes your ongoing agreement to it. This Privacy Policy applies to Mobile Application REDEMPO.
WHAT IS REDEMPO APP?
REDEMPO. and its corporate affiliates (“Company” or “we” or “our” or “us”) provide consumer and retail information and insights for a wide range of industries. The REDEMPO App (the “App”) is a mobile app that the Company uses to enhance its consumer receipt panel. In exchange for your participation, you can earn points for rewards as well as have your receipt information automatically collected to allow for easy submission and participation. Points are awarded based on the amount spent on the receipt, then points can be converted back to cash to the user’s mobile wallet called PayNow in Singapore.
QUICK REFERENCE
By visiting the site and interacting with or using the site, you are accepting and consenting to the practices described in this Privacy Notice.
1. WHAT DOES THIS PRIVACY POLICY COVER
2. LEGAL BASIS OF THIS PRIVACY POLICY
3. PERSONAL DATA PROTECTION ACT, 2012 COMPLIANCE STATEMENT
4. ACCESS TO THE APPLICATION
5. ELIGIBILITY
6. WHAT DATA IS BEING COLLECTED
7. PERMISSIONS WE ASK TO THE END USER
8. HOW DO WE USE YOUR PERSONAL INFORMATION
9. HOW IS YOUR PERSONAL DATA COLLECTED
10. THIRD PARTY COLLECTING DATA AND LINK
11. SHARING OF DATA TO THIRD PARTY
12. HOW IS THE DATA USED BY THE ORGANIZATION
13. IS THERE ANY USAGE OF COOKIES OR WEB BEACONS AND COLLECTION OF ANONYMISED DATA
14. IS THERE ANY USAGE OF THIRD PARTY PLUGINS AND COLLECTION OF DATA BY THIRD PARTIES
15. STORAGE AND TRANSFER OF YOUR PERSONAL DATA
16. YOUR CONSENT
17. RETENTION OF DATA
18. PUBLICATION POLICIES
19. DATA OF CHILDREN
20. LEGAL DISCLOSURES
21. RIGHTS YOU HAVE
22. SAFEGUARDING YOUR PERSONAL DATA AND SECURITY
23. OPT-OUT
24. UPDATES TO THE PRIVACY POLICY
25. COMMITMENT TO GDPR COMPLIANCE OF THE EUROPEAN UNION (EU)
26. WHOM CAN YOU APPROACH IN CASE OF GRIEVANCES
1. WHAT DOES THIS PRIVACY POLICY COVER?
This privacy policy covers our treatment of personally identifiable information (‘personal information’) that we gather when you are accessing or using our application, service and products. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
2. LEGAL BASIS OF THISPRIVACY POLICY:
This Privacy Policy is an electronic record in the form of an Electronic Contract formed under the Personal Data Protection Act, 2012 and the Rules made there under and the provisions pertaining to Electronic Documents/records in various statutes as amended from time to time. This Privacy Policy does not require any physical, electronic or digital signature. This privacy policy is a legally binding document between ‘You’ and the REDEMPO. The terms of this Privacy Policy will be effective upon your acceptance of the same (directly or indirectly in electronic form, by clicking on or by the use of the Application or by any other means), and will govern the relationship between You and REDEMPO for your use of the application.
3. PERSONAL DATA PROTECTION ACT, 2012 COMPLIANCE STATEMENT:
This Privacy Policy (“Policy”) is prepared in compliance with the Personal Data Protection Act, 2012, and the Rules made there under as applicable and the amended provisions pertaining to electronic records in various statutes as amended by the Personal Data Protection Act, 2012.This document is published in accordance with Section 12(a) of the Personal Data Protection Act, 2012 that requires publishing the rules and regulations, privacy policy and user agreement for access or usage of the intermediary’s computer resource by any person for access or usage of the application. Further, this document is also in compliance with Section 24 of the Data Protection Act, 2012 (reasonable security arrangements) which requires the intermediary to take all reasonable measures to secure its computer resource and information contained therein following the reasonable security practices and procedures.
4. ACCESS TO THE WEBSITE:
Your access to, and browsing, review, and use of the application is subject to these terms and conditions and all applicable laws. By accessing and using the application, you accept the Privacy Policy, Terms and Conditions and Community Guidelines without limitation or qualification. If you do not agree to the terms and conditions, do not use the site. If, at any time, any part of the Privacy Policy/Terms and Conditions/Community Guidelines is no longer acceptable to you, immediately terminate the use of the site.
5. ELIGIBILITY:
The services of the Application are available only to persons who are competent to enter into a legally binding contract that is 21 years, under the Civil Law Act 1909. Persons who are incompetent to enter into a contract under this act, including undischarged solvents, minors etc. are not eligible for the services provided for this application and hence shall not register as a user or transact on this Application.
6. WHAT DATA IS BEING COLLECTED?
i. We collect and process the Personal Data that you directly and voluntarily provide through our Application.
ii. We may collect the information such as your name, username, email address, age, gender, phone number, location as our services and products are further developed.
iii. We also collect your picture by getting access of your camera application or by you providing us with the picture of the user yourself for promotion of Redempo which is mandatory in cases Redempo chooses it to be.
iv. If you use our Application, we may collect information about the browser you are using, and your browsing behavior. We may also collect information posted on third party websites or social media platforms about our products and services, when necessary.
v. Your personal information is collected either directly from you (e.g., if you create an account on our Application or make a purchase or otherwise interact with our client advisors over call), or from you passively (e.g., when using tracking tools like browser cookies), or from third parties (e.g. through social media platforms).
vi. You can choose not to provide us with certain information, but then you may not be able to take advantage of some of our services/ features/ products and will not be able to receive the product or service you ordered or otherwise register on our, app or other media.
vii. We use certain third party services to assist us in analysis, auditing, research, and reporting regarding the Services. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. We use Amazon Web Services to help collect and analyze certain information for the purposes discussed in this Policy. You may opt out of the use of cookies by Amazon Web Services at: https://aws.amazon.com/privacy/?nc1=f_pr
viii. When you visit or leave our Services (including our pluggin or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your mobile carrier. When you use our Services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.
ix. We work with third party vendors and service providers to gather deidentified or aggregated information about how users interact with our app or software. This may include information such as demographic information, preference information, what you watch or buy, or your exposure to advertising. These sources include, for example: census data, the manufacturers or sellers of the products you purchase or use, organizations that collect online data, data suppliers, companies that combine purchase information, and other entities that have a legal right to provide such information to us.
7. PERMISSIONS WE ASK TO AN END USER
Our Website/Application will ask the following permissions to an end user:
• Location Permission: Which helps us to know where a user’s location is, which help us to serve users’ localized contents and to power some features like Invite friends etc.
• Contacts Permission: Which help us to sync users contacts from their device to our app to power some feature like User recommendations, Invite friends etc.
• Camera Permission: Which help us to collect your picture if you win the Redempo points.
8. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the information described for the purposes specified at the time of collection or hereafter in this Policy:
• To operate, improve, understand and personalize our services based on our legitimate business interest in operating our services in a way that benefits us and our users
• Create and manage user profiles
• Communicate with you about the services
• Contact you about service announcements, updates or offers
• We may use your information to customize your experience with us and to tailor our marketing activities to fit your needs and interests to better serve you and respond to your needs
• Provide support and assistance for the services
• To process your order and transaction.
• Personalize and improve your experience on our digital platforms
• Personalize application content and communications based on your preferences Commented
• We use information to maintain transaction and other business record for legal, administrative and audit purpose
• We use information to meet legal, insurance and processing requirement
• Respond to user inquiries or questions
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, misuse, illegal or harmful actions
• Enforce our Terms of Service
• To communicate with you about your account or our relationship: we may contact you about changes to the site or about service updates
• We may also use your information to contact about feedback, promotion of Redempo Application.
When you interact with our digital platforms, we may also automatically collect the following information about your visit. This is primarily to help us better understand how you use our digital platforms to enable us create better content and more relevant communications:
• How you have reached our digital platform and the internet protocol (IP) address you have used
• Your browser type, versions and plug-ins, and your operating system
• Your journey through our digital platform, including which links you click on and any searches you made, how long you stayed on a page, and other page interaction information
• What content you like or share
• Which adverts you saw and responded to
• Which pop up or push messages you might have seen and responded to
• Your subscription status
• Information collected in any forms you complete
We may also infer your country of location from the IP address you have used to access our digital platforms and we may analyze which marketing activity led to your taking specific action on our digital platforms.
9. HOW IS YOUR PERSONAL DATA COLLECTED?
Through this Application, we only collect Personally Identifiable Information (PII) that is specifically and voluntarily provided by visitors having regard to the purpose for its disclosure. We receive limited personal information, such as name, title, company address, email address, and telephone numbers from application visitors. Demographic information, including gender is collected. It is our policy to limit the information collected to only the minimum information required to complete a visitor’s request. If you choose to register or login to our Application using a third party single sign-on service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with our application, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable services. In some cases where you have registered for certain services we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request and OTP). The platforms we use to send emails are Google Firebase (https://firebase.google.com/support/privacy) and AWS (AMAZON WEB SERVICE) (https://aws.amazon.com/privacy/)
10. THIRD PARTY COLLECTING DATA AND LINK
If you interact with a third party service when using our services, such as if you share content from our Website/Application through such third party service such as Facebook (https://www.facebook.com/), Youtube (https://www.youtube.com/), Twitter (https://twitter.com/home), we may send these third party service certain Personal Data (specifically your first name, ID, token and URL) only if the third party service and your account settings allow such sharing. Specifically, this Personal Data permits third party to create and manage your profiles and sync your progress when you connect to through our services. The Personal Data of yours to third party will depend on the policies and your account settings with the applicable third party service.
(Please note: our site and the advertisements we serve on behalf of users may contain links to other sites whose information practices may be different from ours. In addition, there may be links to other sites provided within the body of advertisements on other websites. We do not have control over the information that is submitted to, or collected by, these third parties. You should consult the privacy policy of these other sites to learn how your privacy is protected.)
11. SHARING OF DATA TO THIRD PARTY
We share your data with the third-party, who works on our behalf or provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:
• Staff augmentation and contract personnel
• Affiliated companies and business partners
• Service provider or agent who perform services on our behalf
• Any third party as part of business restructuring or reorganization
• We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested to us.
In addition to those set forth above, parties also include:
• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the services)
• Social media (if you interact with them through your use of the services)
• Third party business partners who you access through the services
• Other parties authorized by you
We also share Personal Data when we believe it is necessary to:
• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigates or protect against fraudulent activity.
We also share Personal Data with third parties when you give us consent to do so. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets based on our legitimate business interest of being able to provide you with continued services. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy
12. HOW IS THE DATA USED BY THE ORGANIZATION?
We generally collect only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.
Use of Personal Information
The main purposes of collecting personal information about individuals are as follows:
• Providing Services;
• Respond to an individual’s request;
• Maintaining contact with clients;
• Keeping clients and other contacts informed of the services we offer and industry developments that may be of interest to them, and to notify them of service offerings, seminars and other events we organize;
• Send you marketing/promotional communications;
• For promotion of Redempo Application;
• Send newsletter(s) to you, subject to your subscription;
• General Management and reporting purposes, such as invoicing and account management;
• Provide customer support and the services you request;
• Resolve disputes, if any and troubleshooting;
• All other lawful purposes related to our business and in furtherance to fulfillment of lawful contact.
(information collected by us through this site is used only for the intended purpose stated at the time that the information is collected or for the purposes specified above.)
13. IS THERE ANY USAGE OF COOKIES OR WEB BEACONS AND COLLECTION OF ANONYMISED DATA?
In some instances, we and our service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that
we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of our online presence, and to measure the effectiveness of our marketing activities. In common with many other website operators, we use standard technology called ‘cookies’ on our Application. Cookies are small pieces of information that are stored by your browser on your computer’s hard drive and they are used to record how you navigate this Application on each visit.
We automatically collect and temporarily store the following information about your visit:
• The name of the domain you use to access the Internet;
• The date and time of your visit;
• The pages you visited; and
• The address of the web site you came from when you came to visit
We use this information for statistical purposes and to help us make our site more useful to visitors. Unless it is specifically stated otherwise, no additional information will be collected about you.
Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
BY NAVIGATING ON OUR WEBSITE/APPLICATION OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
14. IS THERE ANY USAGE OF THIRD PARTY PLUGINS AND COLLECTION OF DATA BY THIRD PARTIES?
• Social Media Widgets and Applications
We may host blogs, forums, crowd-souring and other applications or services (collectively “social media features”). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any website social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.
15. STORAGE & TRANSFER OF YOUR PERSONAL DATA
The personal information we possess through our Application may be transferred to, and processed in, to a jurisdiction outside Singapore in which we, our group companies, or our service providers or partners operate, and this may include countries other than the country in which you are not a resident. These countries may have data protection laws that are different from the applicable law in Singapore. However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice
• Data Storage: We store all our user data in Singapore only. For storage purposes we use services like, Amazon Web Services (https://aws.amazon.com/privacy/?nc1=f_pr). Google Firebase is a part of Google cloud services and we use it for storing data and all other information related to a user.
• Data Transfer: The information can be made or transfer solely if we believe it is necessary for the performance of a lawful contract between the body corporate or any person acting on our
behalf or to the service providers involved for the processing of our clients or prospects information. When we transfer your information, we will provide adequate protection for the transfer of your personal information to recipients in those countries by entering into data transfer agreements based on those countries and according to current applicable laws in Singapore. Please note that such transfer has been also consented to by the provider of information. By using our site or otherwise providing us with personal data, you agree to us doing so in accordance with the terms of this Privacy Policy and current applicable laws in Singapore. We will ensure to a reasonable extent that anyone processing your personal data outside Singapore is required to implement measures to protect it and is only entitled to process it in accordance with our instructions.
16. YOUR CONSENT
By using our Application and/ or by providing your information, you consent to the collection and use of the information you disclose on the Application in accordance with this Privacy Policy, including but not limited to your consent for sharing your information as per this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it
17. RETENTION OF DATA
We retain your personal information for as long as you have an open account with us or as otherwise necessary to provide the services to you and improve the services for all users generally. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
18. PUBLICATION POLICIES
(a) The user of Redempo shall not host, display, upload, modify, publish, transmit update or share certain prohibited categories of information (Prohibited Information) listed below:
I. belongs to another person and to which the user does not have any right to;
II. is grossly harmful, harassing, blasphemous defamatory, obscene, pornographic, pedophilic, libelous, invasive of another’s privacy, hateful, or racially, ethnically objectionable, disparaging, relating or encouraging money laundering or gambling, or otherwise unlawful in any manner whatever;
III. harm minors in any way;
IV. infringes any patent, trademark, copyright or other proprietary rights;
V. violates any law for the time being in force;
VI. deceives or misleads the addressee about the origin of such messages or communicates any information which is grossly offensive or menacing in nature;
VII. impersonate another person;
VIII. contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer resource;
IX. threatens the unity, integrity, defense, security or sovereignty of Singapore, friendly relations with foreign states, or public order or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting any other nation
(b) Termination of Access to users: The Redempo has the right to terminate access or usage rights to our computer resources if the user doesn’t comply without rules, user agreement and privacy policy, and to remove any information which is not in compliance with the intermediary policies
19. DATA OF CHILDREN
We do not knowingly collect or solicit any data from anyone who is under the age of 21 years. If you are under the age of 21 years, please do not attempt to register for the services or send any personal data or sensitive data about yourself to us. If we learn that we have collected any type of Data from a child under age 21, we will delete that information as quickly as possible. If you believe that a user under 21 may have provided us any personal information, please contact us at (Teo, please add the correspondence email for Privacy Policy here)
20. LEGAL DISCLOSURES
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably to
(1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
(2) enforce our agreements with you
(3) investigate and defend ourselves against any third-party claims or allegations
(4) protect the security or integrity of our service (such as by sharing with companies facing similar threats);
(5) exercise or protect the rights and safety of our company, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, butwe do not promise to challenge every demand
21. RIGHTS YOU HAVE
(1) Right to information: You have the right to get informed about how your personal data is being processed, when your personal data is being collected and information about the processing of your personal data.
(2) Right to access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. If you request such access, we will provide you with all the information as required by law on the purposes of the processing, categories of data processed, categories of recipients, data retention with us, etc.
(3) Right to be forgotten/deletion/Erase: You have right to restrict or prevent us to continuing disclosure of data processed about you till date; If would like to delete your personal data in our records you have right to do so.
(4) Right to correction: You have right to correct or update your personal data
(5) Withdrawal of consent: If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Data, if such use or disclosure is necessary to enable you to utilize some or all of our services
If you want to exercise any of the above rights, please feel free to write us at (Teo, please add the correspondence email for Privacy Policy here). We will reach you out within 48 hours and guide you how you can exercise any of these right timely and accurately.
22. SAFEGUARDING YOUR PERSONAL DATA AND SECURITY
We take all reasonable precautions to keep your personal data secure and require any third parties that handle or process your personal data for us to do the same. Access to your personal data is restricted to prevent unauthorized access, modification or misuse and is only permitted among our business partners, employees and agents on a need-to-know basis. We value the security of your Information, including but not limited to the Information collected via the site or service. We have taken appropriate technical and organizational measures to protect the Information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, destruction, and any other form of unauthorized processing. However, to the extent that the Internet is not completely secure, we cannot guarantee that any of your personal information stored or sent to us will be completely safe. We encourage you to use caution when using internet to access our Application or any services.
23. OPT-OUT
We provide all users with the opportunity to opt out of our data collection for ad serving and for interest based advertising, receiving any promotional, marketing-related communications from us on behalf of our partners and from us in general, after setting up an account. These settings must be performed on each device for which you want to opt out.
Whenever you uninstall our Application, we will stop collecting data from you. Once a user has deleted the account with us, all data of the user will be deleted from our side.
24. UPDATES TO THE PRIVACY POLICY
If we decide to change our privacy policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.
25. COMMITMENT TO PDPA COMPLIANCE OF SINGAPORE
We are committed to the principles inherent in the Private Data Protection Act and particularly to the concepts of Privacy by design & Privacy by default, the right to be forgotten, consent and risk based approach. In addition we aim to ensure:
A. Transparency with regard to the use of data
B. That any processing is lawful, fair, transparent and necessary for a specific purpose
C. That data is accurate, kept up to date, and removed when no longer necessary
D. That data is kept safely and securely
26. WHOM CAN YOU APPROACH IN CASE OF GRIEVANCES
If you wish to contact us for any reason regarding our Privacy Policy, kindly email it to us at the following address:
• Name: Privacy Policy Officer
• Address: 22 Sin Ming Lane, Midview City #06-76 Singapore 573969
• Email ID: [email protected]