1. GENERAL PRINCIPLES
Protecting your privacy is very important to us. We have accordingly developed
this Privacy Policy to protect your personal information and keep it confidential.
We endeavor to comply with laws of other countries but cannot and do not warrant
that we do. We do everything we reasonably can to protect your rights of privacy
on systems and the Website controlled by us, but we are not liable for any
unauthorized or unlawful disclosures of your personal and confidential information
made by third parties who are not subject to our control, for example advertisers
and websites that have links to our Website. You should take note that the
information and privacy practices of our business partners, advertisers, sponsors
or other sites to which we provide hyperlinks, may be different from ours. Our
privacy policy is subject to change at any time without notice. To make sure you
are aware of any changes, please review this policy periodically.
We categorise information about you (collectively referred to as “Personal
Information”) as follows:
(a) Profiling Information: Information which you provide when you register for a
Service, which may include some or all of the following: – Information about your
personal identity such as gender, marital status, age, preferences, likes and
dislikes etc.; – Your financial information such as your banking details and any
information relating to your income and lifestyle levels; and – Your contact details
such as your physical addresses, postal addresses, telephone and fax numbers
and the like. – In the case of Facebook aligned services (if so opted by you),
publicly available information of your friends, their likes and dislikes, etc. (b)
Payment and Account Information: Your account history with us including (without
limitation) all billing information and communications, payment history etc. We
maintain this in encrypted form on secure servers. (c) Service Usage: Information
about your navigation using our Services, for example the URLs of websites, which
you visit and from which you request downloads. (d) Log information: Information
such as your web request, IP address, browser type, browser language, date and
time of request. (e) Transactional Information: Transactional history (other than
banking details) about your e-commerce activities. (f) Correspondence Information:
Content, information about your correspondents, and the destination/origin of
communications between you and any other person using our Services, which
include email communications, blog, chat room and discussion board
communications, instant message communications, experts forum
communications, faxmail communications, membership of mailing lists etc. (g)
User IDs: Your usernames, passwords, email addresses and other security-related
information used by you in relation to our Services. (h) Stored Information: Data
either created by you or by a third party and which you wish to store on our
servers such as image files, documents etc. We only collect your Personal
Information to conduct our business and to enable us to deliver and improve our
Services. We do not for any reason whatsoever sell your Personal Information to
any third party or otherwise trade on it.
We will only disclose your Personal Information in accordance with this Privacy
Policy. If we want to use it for any other purpose, we will obtain your prior written
consent. If you decline to submit personal information to us, then we will
unfortunately not be in a position to provide the Services to you. Any of your
information which you provide when you use certain Services and are to an open,
public environment or forum including (without limitation) any blog, community or
discussion board, is not confidential, does not constitute Personal Information, and
is not subject to protection under Privacy Policy. Since such public environments
are accessible by third parties, it is possible that third parties may collect and
collate and use such information for their own purposes. You should accordingly
be careful when deciding to share any of your Personal Information in such public
environments. Information, which is disclosed publicly, is also shared with our
affiliates, third party service providers, sponsors of competitions etc. unless
expressly stated otherwise. We are not liable to you or any third party for any
damages that you or any third party may suffer howsoever arising from your
disclosure of Personal Information in any public environment. You accordingly
disclose information in a public environment at your own risk.
2. RIGHT TO COLLECT
By accepting the Terms of Service you agree that we may collect and store your
Personal Information as long as you use our Services subject to the limitations set
out in this Privacy Policy.
2.1 We collect your Profiling and Account Information for the following reasons: (a)
We need your identity details, contact details, banking information and account
history to manage our relationship with you and provide Services to you. We may
use this information for suggesting products that you might like on our website. We
will only disclose this information as provided below. (b) We use certain of your
information in an aggregated form to compile statistical and demographical
profiles for our business and marketing activities. We may disclose such
information about you, provided that the information is in an aggregated form that
is not capable of being used or interpreted in such a manner as to identify you. 2.2
We collect and store your Service Usage and Transactional Information to: (a)
determine and verify the Service Charges payable by you and to administer our
relationship with you. (b) comply with any statutory or regulatory requirement. (c)
compile statistical and demographical profiles about you for our business and
marketing activities and to customise our Services to you. While we are entitled to
use such information about you for our own internal business purposes without
limitation, we will only disclose it in an aggregated form which is not capable of
being used or interpreted in such a manner as to identify you; and (d) monitor your
use of our Services for the purposes of ensuring compliance with our Terms of
Service. 2.3 We collect and store your Correspondence Information and Personal
Identifiers to: (a) comply with our obligations under law; and (b) monitor your use of
our Services in order to ensure your compliance with our Terms of Service. Any
Personal Information which we collect and which we may use in an aggregated
format ensuring you are not individually identified is our property. We may use it, in
our sole discretion and without any compensation to you, for any legitimate
purpose including (without limitation) the commercial sale thereof to third parties.
Sometime we use “cookies” so that we can provide you with more customised
information when you return to our website. “Cookies” are used to store user
preferences and to track user trends, so as to enhance your interactive experience
and generally improve our Services to you. You can set your browser to notify you
when you are sent a “cookie”, giving you the chance to decide whether or not to
accept it. If you do accept a “cookie”, you thereby agree to our use of any
Personal Information collected by us using that Cookie. You may update your
Profiling Information at any time on the website. You acknowledge and agree that
in the interests of improving personalisation and Service efficiency, we may, under
controlled and secure circumstances, share your Personal Information with our
affiliates (an entity which is our subsidiary or holding company or a subsidiary of
our holding company or an entity which controls, is controlled by or is under
common control with us).
3. GENERAL EXCEPTIONS
If we are required to intercept, disclose, monitor and/or store your Personal
Information: (a) by law; (b) to conduct our business; (c) to secure our systems; or
(d) to enforce our own rights, we will do so in the manner as prescribed by law.
Such interception, disclosure, monitoring and storage may take place without your
knowledge. In that case, we will not be liable to you or any third party for any
damages howsoever arising from such interception, disclosure, monitoring and
storage. In order to ensure that all our Users comply with the Terms of Service, we
may monitor your Personal Information to the extent that this may be required to
determine compliance and/or to identify instances of non-compliance. To ensure
that the security and integrity of our Services are safeguarded, we may monitor
your Personal Information. This monitoring may include (without limitation) the
filtering of incoming and outgoing electronic data messages to identify, limit and/or prevent the transmission of spam, viruses and/or unlawful, defamatory, obscene or
otherwise undesirable material or content. We may under certain circumstances
procure an element of the Services from a third party service provider. To the
extent that it may be necessary, and solely for the purposes of providing the
Service to you, you agree that we may disclose to such third party any of your
Personal Information that may be necessary for the procurement of services from
the third party.