VIRTUALISTS PTE LTD takes its responsibilities in relation to protecting your Personal Data and compliance with Applicable Laws very seriously. We are committed to properly managing, protecting and processing your Personal Data in accordance with this Policy, which shall apply to all Personal Data we collect from you through our Platforms.
PLEASE READ AND REVIEW THIS POLICY, WHICH WILL INFORM YOU HOW WE COLLECT, USE, PROCESS AND DISCLOSE YOUR PERSONAL DATA. WE MAY ALSO COLLECT AND PROCESS YOUR PERSONAL DATA UNDER ANY EXCEPTIONS TO APPLICABLE LAWS, WHICH ARE NOT SET OUT IN THIS POLICY. WE TRUST THAT IT WILL ASSIST YOU IN MAKING AN INFORMED DECISION WHETHER TO PROVIDE US WITH ANY OF YOUR PERSONAL DATA.
For the purposes of understanding VIRTUALISTS’s Personal Data Protection Policy (“Policy”), capitalised terms used in this Policy shall have the following meanings:
Applicable Laws” means Personal Data Protection Act 2012 (“Act” or “PDPA”) and applicable privacy law, including but not limited the GDPR (General Data Protection Regulation) and related national enforcement laws and its subsidiary legislations and regulations as amended from time to time;
Apps” means our VIRTUALISTS mobile app on iOS and Android;
Personal Data” means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” or “personal information” under any applicable Data Protection Laws;
Platforms” means collectively VIRTUALISTS’s Apps, social media and Website, and any other websites or applications which we may own or operate from time to time;
Social Media” means VIRTUALISTS’s pages and accounts on third party social media platforms such as Instagram, Facebook, Twitter, Pinterest and Google+;
Website” means the VIRTUALISTS’s website accessed at the following address at 3six9.space and app.3six9.space; and
VIRTUALISTS, we, us, or our” means VIRTUALISTS PTE LTD and its affiliates.
During our relationship with you, we may collect Personal Data from you. Examples of the types of Personal Data we may collect include your name, contact details, mailing and delivery addresses, email address, birthday, network and device data, your shopping or browsing behaviours, facial image, voice recording (for customer service calls) and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us.
If you provide us with Personal Data relating to a third party by submitting such Personal Data to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
By (1) clicking “Yes” on our Policy pop-up or any web form referring to this Policy on any of our online platforms, (2) submitting your Personal Data to us when signing up for an account on the Website, (3) browsing our website, or (4) ordering any of our products and services, you are agreeing to the terms of this Policy.
We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.
HOW DO WE COLLECT YOUR PERSONAL DATA?
We collect Personal Data from you when:
Please also take note of our Cookies Policy below in respect of the data collected and used by third-party cookies and trackers on our Website and Apps.
We may also collect your Personal Data in circumstances where such collection does not require consent under Applicable Laws.
Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the products and services you have requested.
HOW WILL YOUR PERSONAL DATA BE USED?
We may use and disclose your Personal Data for purposes necessary to provide you with our products as services, including to:
(Collectively, the “Purposes”)In addition, we may use and disclose your Personal Data for the following purposes, to:
(Collectively, the “Additional Purposes”)
We may also use your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such use does not require consent under Applicable Laws.
Note: If you withdraw your consent for us to use and process your Personal Data the Purposes or the Additional Purposes, we may no longer be able to provide you with the related products, services or benefits associated with our promotion.
WHO WILL YOUR PERSONAL DATA BE SHARED WITH?
In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:
We may also disclose your Personal Data (a) for other purposes which are reasonably related to the Purposes and where we have obtained and maintain related consent, the Additional Purposes; or (b) in circumstances where such disclosure does not require consent under the Applicable Laws.
We do our best to minimize the disclosure of your Personal Data to the information necessary to perform the related Purpose or Additional Purpose.
HOW CAN I ACCESS OR CORRECT MY PERSONAL DATA?
You may access or correct your name, e-mail address, birthday, shipping and billing addresses and contact numbers by logging in to your user account on the Website or Apps under “Account Information” and clicking the “Edit” button under each relevant field.
For Personal Data that cannot be corrected by you by logging in to your user account on the Website or Apps, you may request to access and correct such Personal Data by submitting a written request to us via our customer service feedback form (available on firstname.lastname@example.org) or by emailing our Data Protection Officer at here. We may need to request additional information from you to confirm your identity before providing the access or making the correction.
We will do our best to respond to Personal Data access and correction requests within 21 days from the date of receipt of the requests. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Applicable Laws.
Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.
We will send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by VIRTUALISTS within the year OR twelve (12) months before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose or unless we reasonably believe that the other person or entity has ceased using such Personal Data for the purpose for which such disclosure was made.
REQUEST TO WITHDRAW PROCESSING
If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please inform us as follows:
Note that, depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of our products or services.
Once we receive notification that you wish to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials or communications during this period.
If you withdraw your consent to receive marketing or promotional materials through a specific communication mode (e.g. SMS), we may still contact you for other purposes in relation to the products and services via other communication modes you have subscribed to (e.g. email).
You may (a) withdraw your consent for the collection, use and/or disclosure of any of your Personal Data or (b) make a request to delete your Personal Data in our possession or under our control by submitting a written request via email to our Data Protection Officer via email@example.com. We will process such a request within a reasonable time and it may take up to thirty (30) days for this to be reflected in our systems. Once this is complete, we will no longer collect, use and/or disclose your Personal Data, except for compliance, regulatory or other legal purposes.
ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.
We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data. However, we will not be responsible for any unauthorized use of Personal Data by third parties which is attributable to factors beyond our control.
When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is destroyed, permanently deleted or anonymised.
If Personal Data is transferred out of Singapore, we will comply with Applicable Laws in doing so. This includes: (i) obtaining your consent, unless an exception exists under Applicable Laws or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Applicable Laws.
THIRD PARTY COOKIES
VIRTUALISTS uses the services of third-party vendors, who may implement cookies on the Website. Advertisements on the Website may be provided by third party agencies. These advertisements may also generate cookies, for example, to track how many people have viewed the advertisement. The collection, use, and disclosure of information, including Personal Data, collected by such third-party cookies are subject to the privacy and data protections policies of the third-party vendors and are not under our control.
You may reject third party cookies through the settings on your browser. Note that this may result in the loss of Website functionality, restrict your use of the Website, or delay or affect the way in which the Website operates.
VIRTUALISTS uses certain Google Analytics functions. Please see this link for how your data is collected and this link for instructions on how to opt-out of any Google Analytics data tracking.
VIRTUALISTS may use Google Analytics features based on Display Advertising, including but not restricted to the following: Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads.
VIRTUALISTS also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show VIRTUALISTS ads on sites across the Internet. VIRTUALISTS and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on visitors’ past visits to VIRTUALISTS, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to VIRTUALISTS.
When you log on to the VIRTUALISTS website, VIRTUALISTS with the help of Google Analytics may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this Policy.
For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Applicable Laws, you may contact our Data Protection Officer via email mode:
Email address: firstname.lastname@example.orgAttention it to the ‘Data Protection Officer’.
Emails and letters should clearly state that you are making a data protection query, request or complaint in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.
This Policy and your use of this Website shall be governed in all respects by the laws of Singapore.
UPDATES ON DATA PROTECTION POLICY
As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time. In this regard, VIRTUALISTS may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion.
Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our website. Any amended Policy will be posted on our website and can be viewed at:
By continuing to use our Platforms and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.
You are encouraged to visit the above website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.
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