1.1. “Data Intermediary” means an organisation which Processes personal data on behalf of another organisation but does not include an employee of that other organisation.
1.2. “End-User” means any person or entity with whom the Subscriber interacts using the Service(s).
1.3. “Personal Data” means data, whether true or not, about an individual who can be identified — a) from that data; or b) from that data and other information to which the organisation has or is likely to have access.
1.4. “Process” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
1.5. “Service(s)” shall have the meaning ascribed to it in the Terms.
1.6. “Subscriber” means the natural or legal person that has subscribed to the Service(s) by agreeing to the Terms.
1.7. “Terms” means the binding contract between Svested and You which governs the access and use of the Service(s) by You.
1.8. “Website(s)” means the websites that Svested operates.
1.9. “You” and “Your” means an identified or identifiable natural person whose Personal Data Svested Processes.
2. HOW YOUR DATA IS COLLECTED
2.1. You directly provide Us with most of the data We collect. We collect Personal Data from You when You:
a) Subscribe for any of Svested’s Service(s) by agreeing to the Terms;
b) Use or view Svested’s Website(s) via Your browser’s Cookies;
c) When You submit web forms on Our Website(s) or as You use interactive features of the Website(s), including: participation in surveys, downloading of templates, etc; or
d) When You download and use the Service(s), Svested automatically collects information on the type of device You use, and the operating system version, to perform Our agreement with You.
2.2. We may also receive Your Personal Data indirectly as follows: a) from third party sources like databases and social media but only where We have checked that these third parties either have Your consent or are otherwise legally permitted or required to disclose your personal information to us; b) We may also obtain Personal Data if You authorize Svested to connect with a third-party service. We will access and store Your name, email address(es), current city, profile picture URL, and other Personal Data that the third-party service makes available to Svested, and use and disclose it in accordance with this Policy.
2.3. The Website(s) includes social media features and widgets that are either hosted by a third-party or hosted directly on the Website(s) and Your interaction with these social media features and widgets is governed by the privacy statement of the companies that provide them. You should check Your privacy settings on these third-party services to understand and change the information sent to Svested through these services.
3. PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED
3.1. We Process Your Personal Data to:
a) facilitate Your access to the Website(s) and Service(s);
b) process and complete payment transactions;
c) provide customer service and support;
d) send You communication on Your use of the Service(s), updates on Our Terms or other policies;
e) send You communication on new features in the Service(s) or new service offerings;
f) conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve Our Service(s) and facilities in order to enhance Your relationship with Us or for Your benefit, or to improve any of Our Service(s) for Your benefit;
g) organise seminars, events or other marketing/ promotional activities;
h) investigate and prevent fraudulent transactions, unauthorized access to the Websites and Service(s), and other illegal activities;
i) personalize the Websites and Service(s); and
j) for other purposes for which Svested obtains Your consent.
4. SHARING OF PERSONAL DATA
4.1. You acknowledge that We will share Your Personal Data with its group companies and third-party service providers so that they may offer You Svested’s Service(s) and/or to send information or updates on the Service(s) if You are a Subscriber.
4.2. When We Process Your order where You are a Subscriber, it may send Your Personal Data to and also use the resulting information from credit reference agencies to prevent fraudulent purchases.
4.3. We share Personal Data with Our third-party service providers that host and maintain the Svested Website(s), applications, backup, storage, payment processing, analytics and other services. These third-party service providers may have access to or Process Your Personal Data for the purpose of providing these services for us.
4.4. We may share Your Personal Data with third-party providers who assist us in marketing and promotions.
4.5. We may be required to disclose Your Personal Data in response to: a) lawful requests by public authorities, including to meet national security or law enforcement requirements and/or b) subpoenas, court orders, or legal process, or to establish or exercise Svested’s legal rights or defend against legal claims.
4.6. We may also share Personal Data to assist investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Svested’s Terms, or as otherwise required by law.
5. INTERNATIONAL TRANSFER
5.1. We mainly Process Personal Data in Singapore. However, We may transfer Personal Data outside Singapore for the purposes referred to in Section 4. We will ensure that the recipient of Your Personal Data offers an adequate level of protection that is at least comparable to that which is provided under applicable data protection laws.
6. RETENTION OF PERSONAL DATA
6.1. Svested retains the Personal Data collected where an ongoing legitimate business requires retention of such Personal Data.
6.2. In the absence of a need to retain Personal Data under Section 6.1. above, Svested will either delete or aggregate it or, if this is not possible then Svested will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.
7. SECURITY OF PERSONAL DATA
7.1. 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 authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, web security measures against risks, and security review and testing performed regularly.
7.2. 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.
8. YOUR RIGHTS
You are entitled to the following rights:
8.1. You can request Svested for access, correction, update or request deletion of Your Personal Data. 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.
a) 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; and
b) We will respond to Your request as soon as reasonably possible. In general, Our response will be within ten (10) business days. 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 applicable law).
8.2. You have the right to opt-out of marketing communications Svested sends You at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails Svested sends You. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please submit Your request in writing or via email to Our Data Protection Officer at the contact details provided below.
8.3. You can withdraw Your consent at any time. 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.
9.1. Cookies are text files that are placed on Your computer to collect standard internet log information and visitor behaviour information by Svested. When You visit the Website(s), Svested may collect Personal Data automatically from You through cookies or similar technology.
9.2. Essential Cookies: Svested sets essential cookies that enable core functionality such as security, network management, and accessibility. You may not opt-out of these cookies. However, You may disable these by changing your browser settings, but this may affect how the Website(s) functions.
9.3. Analytics, Customisation and Advertising Cookies: Svested sets Google Analytics cookies to help it improve its Website(s) by collecting and reporting information on how You use it. The cookies collect information in a way that does not directly identify anyone.
9.4. Svested also sets cookies to collect information that is used either in aggregate form to help Svested understand how its Website(s) are being used or how effective marketing campaigns are, to help customise the Website(s) for You or to make advertising messages more relevant to You.
10. NOTICE TO END-USER AND OTHER EXCLUSIONS
10.1. Svested’s Service(s) are intended for use by enterprises. Svested is not responsible for Subscribers’ privacy or security practices which may be different from this Policy. Subscribers to Our Service(s) are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of Our Service(s) by End Users. We Process Personal Data of End Users in connection with Our Subscriber’s use of Our Service(s) as a Data Intermediary. If You are an individual who interacts with a Subscriber using Our Service(s), then You will be directed to contact Our Subscriber for assistance with any requests or questions relating to Your Personal Data.
10.3. This Policy does not apply to aggregated information which summarises statistical information about groups of members, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.
11. CONTACT INFORMATION
11.1. 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, in the following manner:
Name of DPO: Marcus Wong
Contact No: +65 8668 4614
Email Address: email@example.com
12. CHANGES TO THE POLICY
12.1. 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: 16/07/2021
Last updated: 22/07/2021