DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which DataNoodle (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. Collection And Use of Personal Data
1.1 Types of Data
(a) We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title and date of birth.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes payment card details.a
- Access Data includes username, login and password details for your access to the Service via our web portal or dashboard. Bank Account, Card Processor Account and other third party services (including, but not limited to, Adwords, Facebook, Google Analytics, Shopify, Stripe and such other accounts as may be required from time to time), provided by you to us as part of the Online Application Process.
- Transaction Data includes details about payments to and from you and other Service details you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Feedback Data includes your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and Service which include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect information on how the Service is accessed and used (“Usage Data“). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
(c) The data collected and processed by DataNoodle in the context of the provisioning of DataNoodle’s services for our customers includes (i) customer and customer employee account information to enable access to DataNoodle’s services; (ii) any content customer chooses to upload or store in the DataNoodle platform, (iii) content published or sent by social media users via customer’s social media profiles, as well as inbound and outbound messages and posts on the various social media networks (e.g. Facebook and Twitter, etc.), and (iv) Structured data (aka rich snippets, rich results, schema codes, JSON tags). DataNoodle’s customers authorize DataNoodle to connect to their social media accounts and can unilaterally determine the scope of the data collection and data processing. The data collected and processed by DataNoodle is primarily publicly accessible data.
(d) We do not collect any details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
1.2 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, insufficient Registration Information). In such a case, we might have to cancel the Services but we will notify you if that happens.
1.3 Use of Data
DataNoodle uses the collected data for various purposes:
- To provide and maintain the Service
- To verify your identity
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer care and support
- To provide analysis or valuable information so that we can improve the Service
- To monitor the usage of the Service
- To detect, prevent and address technical issues relating to the website or our Service
- To process payments
- To manage our relationship with you
- To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority
- To transmit to any unaffiliated third parties including our Service Providers (as defined below) and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad
We will also use the personal data we have collected from you for any other purposes for which you have provided the same, as well as for any other incidental business purposes related to or in connection with the purposes stated above.
- Session Cookies. We use session cookies to operate our Service.
- Preference Cookies. We use preference cookies to remember your preferences and various settings.
- Security Cookies. We use security cookies for security purposes.
3. Disclosure Of Data
We may disclose your personal data to others (such as our Service Providers) when required for performing obligations in the course of or in connection with our Services. We may also disclose your personal data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of DataNoodle
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
If our business is sold or integrated with another business, your personal data may be disclosed to our advisers and any prospective purchasers and their advisers will be passed on to the new owners of the business.
4. Our Legitimate Interests
4.1 We may collect, use or disclose your personal data without your consent for the legitimate interests of DataNoodle or another person. This is the case when we collect, use or disclose your personal data for the detection and prevention of any misuse of our Service.
4.2 In relying on such legitimate interests, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
5. Security of Data
The security of your data is important to us, and we strive to use commercially acceptable means to protect your personal data. However, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure, which means we cannot guarantee its absolute security.
6. Data Retention
6.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
6.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
6.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other legal purposes.
6.4 In some circumstances you can ask us to delete your data: see below for further information.
6.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. Protection Of Personal Data
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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, and up-to-date antivirus protection.
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. Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
9. Our Service Providers
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use the following third-party Service Providers to monitor and analyze the use of our Service:
- Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
11. Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
12. Children’s Privacy
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children have provided us with personal data, please contact us. If we become aware that we have collected personal data from Children without verification of parental consent, we take steps to remove that information from our servers.
13. Your Consent
By submitting your personal data to us, you consent to the collection, use, disclosure and processing of your personal data as set out in this policy. You may withdraw your consent at any time by submitting a request to us at the contact details below. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.>br>
We will seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you or stated above (except where permitted or authorised by law).
14. Access to Your Personal Data
14.1 You have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal data, please send an email via the email address stated below. Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service (and will inform you of the amount before we start processing your request). We will respond to your request as soon as reasonably possible.
In exceptional circumstances, we reserve the right to deny you access to your information and may provide you with an explanation as required by applicable laws.
14.2 We may also request you to update your personal data. We want to ensure that your personal data is accurate and up to date and seek your assistance to ensure that such information is current, complete and accurate. If any of the information that you have provided to us changes, for example if you changed your email address, name or payment details, or if you wish to cancel your registration, please let us know the correct details by either sending an email or updating the particulars via the web portal, dashboard or platform that is made available for you to access the Service.
14.3 You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
15. Transferring Your Personal Data Outside of Singapore
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under applicable laws. By submitting your personal data to us, you further consent to these transfers for the purposes specified above.