PRIVACY POLICY

Except as otherwise specified herein, the following terms have the respective meanings for all purposes of this Privacy Policy:

  • Applicable Laws” refer, with respect to any person, any and all applicable treaties, legislation, laws, bylaws, regulations, codes, rules or rulings, orders or any form of decisions issued by, or requirements of, government administrative, statutory, regulatory or supervisory entities, authorities or bodies (including without limitation, any relevant stock exchange or securities council) or any court or tribunal with competent jurisdiction, whether in Singapore or elsewhere, as amended or modified from time to time, and to which such person is subject.
  • Linked Sites” has the meaning ascribed to it in clause 5.
  • PDPA” refers to the Personal Data Protection Act (No. 26 of 2012) of Singapore as amended from time to time and the relevant version in force at the time of application of this Privacy Policy, including subsidiary legislation and the Personal Data Protection Commission’s Advisory Guidelines.
  • Personal Data” refers to data (whether true or not) about an individual who can be identified from that data, or from that data and other information to which Haulio and/or the Group is likely to have access.
  • Privacy Policy” refers to this privacy policy including any subsequent amendments made.
  • we”, “us” or “our” refers to the company (within the Group) which collecting your Personal Data, or which is operating the digital services which you are accessing or using.
  • digital services” refers to the website or software applications operated by Haulio, i.e. haulio.io, Android & iOS mobile software applications

By providing us with your Personal Data or by accessing, using or viewing the digital services or any of its services, functions or contents (including transmitting, caching or storing of any such Personal Data), you shall be deemed to have agreed to each and all the terms, conditions and notices in this Privacy Policy. If you do not agree, please cease use of the relevant digital services and do not provide any Personal Data to us.

By submitting any Personal Data to us, you represent and warrant that you are at least 18 years of age or have attained the age of majority in your jurisdiction. If you are under 18 years of age, please do not send any Personal Data about yourself to us.

1. Information collection

Data collected directly from you

    • When you use our digital services, any service we provide or in your interaction with us, we may collect following information about you, including but not limited to:
      1. your contact information, including your (first and last) name, billing and/or delivery address, birthdate, email address, contact number;
      2. geographical location;
      3. if you have created an online account on our digital services, the account password to access an application on our digital services, preferences and interests stored in such online account, payment card information and other billing information associated with your online account (where relevant), including card image, card number, cardholder name, card expiration date and card verification code; and
      4. if you have contacted our customer service, the details of this contact and the contract history.

Data collected by automated means

    • We also collect certain technical information when you access, browse and use our digital services, including information that we automatically receive and record from your browser or mobile platform on our server logs. This technical information helps us to operate, and includes standard information about visits, systems capabilities, such as:
      1. information about the device(s) you use to access our digital services, including MAC address, IP address, browser type and version, your location, time zone, browser plug-in types, operating system and platform, device type, device and application identifiers, mobile carrier and cookies;
      2. information about your visits to the digital services, including full URL clickstream to, through and from the website, including dates and times;
      3. information that we need and use to facilitate your use of the digital services, including URL requests, destination IP addresses, or device configuration details;
      4. pages you view, searches you run, length of time browsing search results, specific search results you select to view, page interaction information (e.g. scrolling, clicks and mouse-overs), your engagement with certain variable/ dynamic elements of a page; and
      5. page response times and download errors.
    • We only retain Personal Data for so long as it is necessary. Your Personal Data may be archived as long as the purpose for which the Personal Data was collected still exists.

 

2. Purposes for the collection, use and disclosure of your information

    • The purposes for which information may be used by us in and outside Singapore include:
      1. Ensuring that content from our digital services is presented in the most effective manner for you and for your computer or other smart devices you are using;
      2. Providing you with alerts, newsletter, education materials or information that you requested or signed up to;
      3. Carrying out our obligations arising from any contracts entered into between you and us;
      4. Allowing you to participate in interactive features of our service, when you choose to do so;
      5. Designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
      6. Complying with laws and regulations applicable to us or any of our affiliates in or outside Singapore;
      7. Legal proceedings, including collecting overdue amounts and seeking professional advice;
      8. Researching, designing and launching services or products including seminars/events/forums; and/or
      9. Purposes directly related or incidental to the above.

 

3. Cookies 

    • Our digital services uses cookies to support the functionality of our digital services and also allows us to improve our digital services.
    • A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
    • We use the following cookies:
      1. Strictly necessary cookies. These are cookies that are required for the operation of our digital services. They include, for example, cookies that enable you to log into secure areas of our digital services, use a shopping cart or make use of e-billing services.
      2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our digital services when they are using it. This helps us to improve the way our digital services work, for example, by ensuring that users are finding what they are looking for easily.
      3. Functionality cookies. These are used to recognise you when you return to our digital services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
      4. Targeting cookies. These cookies record your visit to our digital services, the pages you have visited and the links you have followed. We will use this information to make our digital services and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
    • Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
    • Our digital services uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google“). Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our digital services and how to control the information sent to Google. Google Analytics may use cookies to help the web operators to analysis how the digital services is used by you.
    • You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our digital services.
    • You can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).

4. Security 

    • The security of your information is important to Haulio. We have established administrative, technical and physical safeguards to protect your Personal Data against unauthorised alteration, access, loss, theft, use and disclosure.
    • All information you provide to us is stored on our secured servers.
    • Unfortunately, no system can guarantee complete security of your information. We cannot guarantee or warrant that your information, including your Personal Data, is secure from unauthorised third parties. Your use of our digital services and communication with us is at your own risk.
    • Where we have given you (or where you have chosen) a password which enables you to access certain parts of our digital services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We will never ask for your password by phone or e-mail, so if you receive such an inquiry, please report the incident to support@haulio.io. If you access our digital services from a shared computer or a computer in an internet cafe, a PC room or a library, certain information about you, such as your user ID, activity or reminders from the digital services, may also be visible to other individuals who use the computer after you. To protect your personal information or communication from being disclosed to others, you should log out and close the web browser after using our digital services.

 

5. Third parties

This Privacy Policy only applies to our digital services and information that we collect from you. Our digital services may contain links to other digital services (the “Linked Sites“). We are not responsible for the privacy policies or practices of such Linked Sites. When visiting such Linked Sites and/or disclosing your Personal Data to third parties, you should read their privacy policies, or ask relevant questions before you disclose your Personal Data. We are not responsible for the collection, use or disclosure of your Personal Data to such third parties.

 

6. Changes to the Privacy Policy

Any amendments we may make to this Privacy Policy in the future will be publicised on our digital services.

 

7. How your Personal Data may be shared

    • We will not sell or share your Personal Data to third parties. We will only disclose your Personal Data to third parties where you have provided consent, and in situations as set out in this Privacy Policy. We may disclose or share your Personal Data with third parties who provide necessary services to us, such as:
      1. service providers and data processors working on our behalf and providing services to enable us to provide our service to you, as described in this Privacy Policy; and
      2. our consultants and professional advisers (e.g. accountants, lawyers, auditors).
    • We may also disclose your Personal Data to comply with any Applicable Laws.
    • You fully understand and consent that we may transfer your Personal Data to any location outside of Singapore in the manner and for the purposes described in this Privacy Policy. When transferring your Personal Data outside of Singapore, we will protect your Personal Data to a standard comparable to the protection accorded under the PDPA by ensuring that the recipient is either in a jurisdiction that has comparable data protection laws, or is contractually bound to protect your Personal Data.

 

8. Contact us

    • By using our service or visiting our digital services, you consent to the collection and use of your information and other activities as outlined in this Privacy Policy.
    • If you have any questions about the collection, use and/or processing of your Personal Data or this Privacy Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your Personal Data, you may contact us at the following address:
      • Name: Haulio Data Protection Officer
      • Address: 115A Commonwealth Drive, #05-01, Singapore 149596
      • Email: support@haulio.io
    • All requests for correction or for access to your Personal Data must be in writing. We will endeavour to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
    • We may charge a fee for processing any data access request. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
    • If you wish to submit a feedback or compliant regarding our handling of your Personal Data, you may write to the Haulio Data Protection Officer at the address and/or email address provided in clause 8.2 above. Kindly also include the following details when writing to the Haulio Data Protection Officer:
      1. Name, contact number and address of the person submitting the feedback or complaint; and
      2. Relevant details such as the time period of the incident, employees of Haulio who were involved in the incident (if relevant), and copies of documents where required.

 

9. Governing law and jurisdiction 

Nothing in this Privacy Policy shall limit the rights of the data subject under the PDPA. This Privacy Policy shall be governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts.

 

Last updated: 30th September 2020

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