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Adzaps Privacy Policy

KEY POINTS

INTRODUCTION

Adzaps (we, us, our) complies with the Singapore Personal Data Protection Act 2012 (Act) and the General Data Protection Regulation of the European Union (GDPR), when dealing with personal information. 

Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws. 

This policy does not limit or exclude any of your rights under the Act or the GDPR. For further information on the Act, see https://www.pdpc.gov.sg/Legislation-and-Guidelines/Personal-Data-Protection-Act-Overview. For further information on the GDPR, see https://ec.europa.eu/info/law/law-topic/data-protection_en

This policy was drafted with brevity and clarity in mind. It does not provide exhaustive details of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to hello@adzaps.com

CHANGES TO THIS POLICY

We may change this policy by uploading a revised policy on our website. The change will apply from the date that we upload the revised policy. 

This policy was last updated on 3rd January 2024

WHEN DOES THIS PRIVACY POLICY APPLY

This privacy policy applies to personal information we collect from visitors to our website, or mobile apps our customers and other persons with whom we deal directly. In addition, users of our SaaS service may collect personal information from individuals (e.g. their employees and customers) and upload, store or process that information to or in that service (User Data). 

We require our customers to obtain the necessary consents from individuals to provide User Data to us and permit us to use it as set out in this privacy policy. If you have any concern about our collection and use of personal information about you contained in User Data, please contact us at hello@adzaps.com

For the purposes of the GDPR, our customers are the data controller when storing or otherwise processing User Data that we hold solely for the purpose of providing our SaaS service and we are the data processor. We are the data controller when storing or otherwise processing User Data that we use for our own purposes. 

We only process User Data as authorised by Twitter. Unless required otherwise under applicable law, if we receive any request or enquiry relating to User Data that we hold solely for the purpose of providing our SaaS service, we will forward this request to our relevant customer. If we receive any requests or enquiries relating to User Data that we use for our own purposes, we will deal with these requests or enquiries as set out in this privacy policy. 

CHILDREN

We do not intend to collect personal information from or about children aged under 16. If you have reason to believe that we have collected personal information from or about a child under the age of 16, please contact us at hello@adzaps.com

WHAT PERSONAL INFORMATION DO WE COLLECT

Directly from you

We collect the following information directly from you.

When you fill in a contact or enquiry form on our website, call us, meet us in person or otherwise contact us, we collect your name and email address and any other information you choose to provide to us. 

Some of the personal information that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some of the information that we may request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our products or services to you. If you require further information about the consequences of not providing us with any information, please contact us at hello@adzaps.com

Automatically when you use our website 

When you access and use our website or related services we may automatically collect information about your device and usage of our website, products and services, including your IP address/operating system/browser type/time spent on certain pages of the website/pages visited/links clicked/language preferences. 

Some of this data is collected through third party tools and/or the use of cookies, web beacons and similar storage technologies. Please refer to our cookie policy below for further information, including information on how you can disable these technologies. 

From third party sources 

Where possible, we collect personal information from you directly. However, sometimes we may collect: 

  • personal information from third parties where you have authorised this. This may include accessing certain personal information from third party social media or other authentication services (e.g. Facebook, Google or LinkedIn) if you login to your account with us using these services or otherwise provide us access to information from these sources. The third party provider that we use will be displayed and you can visit its privacy policy for further details on how it deals with personal information 
  • personal information about you from our trusted advertising partners which may include demographic information, browsing history, location and online behavioural or profile information 
  • personal information that is publicly available e.g. through LinkedIn profiles or public directories 
  • personal information included in User Data. 

We may combine the personal information about you that we receive from third parties with the personal information we collect from you directly or with device and usage data we collect automatically when you visit our website. 

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information to: 

  • verify your identity 
  • provide our website, products and services to you 
  • market our products and services to you, including contacting you electronically (e.g. by text or email for this purpose) 
  • improve our website, products and services 
  • publish things on our website (e.g. comments on message boards or chat rooms) 
  • run promotions (e.g. referral and loyalty programmes, surveys and contests) 
  • undertake credit checks of you (if necessary) 
  • bill you and collect money that you owe us, including authorising and processing credit card transactions 
  • respond to communications from you, including enquiries and complaints 
  • conduct research and statistical analysis (on an anonymised basis) 
  • tailor content or advertisements on our website to you 
  • protect and/or enforce our legal rights and interests, including defending any claim 
  • respond to lawful requests by public authorities, including to comply with law enforcement requirements, or 
  • for any other purpose authorised by you or applicable law. 

We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition. 

You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails. 

DISCLOSING YOUR PERSONAL INFORMATION

We may disclose your personal information to: 

  • another company within our group 
  • any business that supports our website, products and services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our website, products or services or that we use to process payments 
  • third parties (for anonymised statistical information) 
  • professional advisers e.g. accountants, lawyers or auditors 
  • a person who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority) 
  • any other person with your consent 
  • any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition 
  • any other person authorised by applicable law. 

Also, we may share information about your use of our website with our trusted advertising and analytics partners through the use of cookies, web beacons, and similar storage technologies. Please refer to our cookie policy below for further information. 

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

A business that supports our website, products and services may be located outside of Singapore (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of Singapore and the country where you are located. 

If you are located in the European Economic Area (EEA), your personal information may be transferred outside of the EEA. Under the GDPR, the transfer of personal information to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal information if other appropriate safeguards are in place. 

Where we transfer personal information outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where approved transfer mechanisms are in place to protect your personal information (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses. For further information, please contact at hello@adzaps.com

PROTECTING YOUR PERSONAL INFORMATION

As required by applicable law, we will take steps to keep your personal information safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information. 

You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security. 

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

Subject to certain grounds for refusal under applicable law, you have the right to access your personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates. 

Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal information, we will make the correction. In all other cases, we will take reasonable steps to make a note of the personal information that was the subject of your correction request. 

If you want to exercise either of the above rights, email us at [insert email address]. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting). 

Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information. 

OTHER RIGHTS

In addition to the rights to access and correct your personal information, if you are based in the European Union, you have the additional rights set out in the GDPR Additional Terms section of this privacy policy below. 

INTERNET USE

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk. 

If you post your personal information on our website’s message board or chat room, you acknowledge and agree that the information you post is publicly available. 

If you follow a link on our website to another website, the owner of that website will have its own privacy policy relating to your personal information. We suggest you review that website’s privacy policy before you provide personal information to that owner or website. 

DATA RETENTION POLICY

The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer. 

CONTACTING US

If you have any question about this privacy policy, or our privacy practices, or if you would like to request access to, or correction of, your personal information, you can contact us at hello@adzaps.com

The name and contact details of our Data Protection Officer for the purposes of the GDPR are: 

Name  Srinivas 
Email Address  hello@adzaps.com
Phone Number  +60 11 6156 5626

GDPR ADDITIONAL TERMS 

LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION 

Our lawful basis for processing (as that term is defined in the GDPR) personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it. 

Generally, we collect personal information from you where we have your consent, where the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms). 

Where we process personal information based on your consent, you may withdraw your consent at any time. 

Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws. 

If you have any question about the legal basis on which we process personal information or need further information, please contact us at hello@adzaps.com. 

YOUR RIGHTS UNDER THE GDPR

If you are located in the European Union, your rights in relation to your personal information include: 

  • right of access – if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information
  • right to rectification – if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure that inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible
  • right to erasure â€“ when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information
  • right to withdraw consent – if the basis of our processing of your personal information is consent, you can withdraw that consent at any time
  • right to restrict processing – you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible
  • right to object to processing – you may request that we stop processing your personal information at any time and we will do so to the extent required by the GDPR
  • rights related to automated decision-making, including profiling – you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making.
  • right to data portability – you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller
  • the right to complain to a supervisory authority – you can report any concern you have about our privacy practices to your local data protection authority.

Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing. 

If you would like to exercise any of your above rights, please contact us at hello@adzaps.com. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.