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Effective date: 25th April 2017

Our Privacy Policy explains how we, MetLife Innovation Centre Pte. Ltd. (the “Company”, also known as LumenLab), and some of the companies we work with collect, use, share and protect information in relation to our mobile services, web site, and any software provided on or in connection with the Services (as defined in the Terms of Use accessible at www.vitana.sg and your choices about the collection and use of your information.

In addition, we take our responsibilities under Singapore’s Personal Data Protection Act (No. 26 of 2012) (“PDPA”) seriously. We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

By using the Services you understand and agree that, in respect of certain parts of the Services or their respective functions, we may be providing a platform for you to provide materials or collect stories, including photos, videos, voice recordings, text, comments and other materials ("User Content") and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Services, consistent with the terms and conditions of this Privacy Policy and our Terms of Use. The default is for all content to be private and will not be made available to anyone.

This Policy applies to all visitors, users, and others who access the Services ("Users", “you” or “your”).

By submitting any data via the Services or any part of the Services, you consent to us collecting, using, disclosing and processing the data in accordance with this Privacy Policy. By submitting data relating to other individuals (such as your spouse, family members or any other third parties, including minors) via the Services, you represent and warrant that you are authorized to provide such data to us and that you have obtained their consent to the collection, use, disclosure and/or processing of such data in accordance with this
Privacy Policy. You represent and warrant that all data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to the personal data provided by you to us.

It is necessary for us to collect and to retain your data. If you do not provide us with your data, or do not consent to this Privacy Policy, we will not be able to effectively provide products and/or services to you, if at all.


1. INFORMATION WE COLLECT

We collect the following types of information.

Information you provide us directly:

  • Your username, password, e-mail address and other required information when you register for an account.
  • Profile information that you provide for your user profile (e.g., first and last name, picture, phone number).
  • User Content (e.g., photos, comments, and other materials) that you post to the Services.
  • Information contained in communications between you and us. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Services, technical and security notices). Note that you may not opt out of Service-related e-mails.

Analytics information:

We use third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving the Services. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

Cookies and similar technologies:

When you visit the Services, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Services and provide features to you.

We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

Log file information:

Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

When you use our Services, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.

Device identifiers:

When you use a mobile device like a tablet or phone to access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by the Services.

A device identifier may deliver information to us or to a third party partner about how you browse and use the Services and may help us or others provide reports or personalized content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.

Metadata:

Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

Users may be able to add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo), geotag (e.g., to mark your location to a photo), comments or other data. This makes your User Content more searchable by others and more interactive. If you geotag your photo or tag your photo using other's APIs then, your latitude and longitude will be stored with the photo and searchable (e.g., through a location or map feature) if your photo is made public by you in accordance with your privacy settings.


2. HOW WE USE YOUR INFORMATION

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive to:

  • communicate with you;
  • enable you to efficiently purchase and download products, obtain access to services and engage in offered activities;
  • help you efficiently access your information after you sign in;
  • remember information so you will not have to re-enter it during your visit or the next time you visit the Services;
  • provide, improve, test, and monitor the effectiveness of our Services;
  • develop and test new products and features;
  • monitor metrics such as total number of visitors, traffic, and demographic patterns;
  • diagnose or fix technology problems;
  • provide you with information and/or updates on products, services and/or promotions offered by us and selected third parties, including personalized content and information to you and others such as online ads or other forms of marketing;
  • automatically update relevant applications on your device or other Users may run contests, special offers or other events or activities on the Services;
  • respond to your enquiries or complaints.


3. SHARING OF YOUR INFORMATION

We will not rent or sell your information to third parties outside the Company (or the group of companies of which the Company is a part) without your consent, except as noted in this Policy.

Parties with whom we may share your information:

We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with businesses that are legally part of the same group of companies that the Company is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Services (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).

 We also may share your information as well as information from tools like cookies, log files, and device identifiers and location data, with third-party organizations that help us provide the Services to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services under reasonable confidentiality terms.


We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

We may disclose data that you have provided to us to our Service Providers, agents and/or our Affiliates, whether sited in Singapore or outside of Singapore, who process such personal data either on our behalf or otherwise, for the purposes described in this Privacy Policy.

Parties with whom you may choose to share your User Content:

Any information or content that you voluntarily disclose for posting to the Services, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. To change your privacy settings on the Services, please change your profile setting. Once you have shared User Content or made it public, that User Content may be re-shared by others.

If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Services, or if other Users or third parties using the Services’ API have copied or saved that information.


What happens in the event of a change of control:

If we sell or otherwise transfer part or the whole of the Services or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Services may be among the items sold or transferred. You hereby consent to the collection, use, disclosure and/or processing of your data by the Company for the purposes of any purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of the Services or a portion of the Services or of any of the business or assets of the Services. You will continue to own your User Content. The buyer or transferee will have to honour the commitments we have made in this Privacy Policy.



4. HOW WE STORE YOUR INFORMATION

Storage and Processing:

Your information collected through the Services may be stored and processed in Singapore or any other country in which the Company, its Affiliates or Service Providers maintain facilities.

The Company, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in the European Union or other regions with laws governing data collection and use that may differ from Singapore law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.

By registering for and using the Services you consent to the transfer of information to Singapore or to any other country in which the Company, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

We use commercially reasonable safeguards to help keep the information collected through the Services secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, we cannot ensure the security of any information you transmit to us or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and our company, at all times. We are not responsible for the functionality, privacy, or security measures of any other organization.


5. YOUR CHOICES ABOUT YOUR INFORMATION

Your account information and profile/privacy settings:

Update your account at any time by logging in and changing your profile settings.

How long we keep your User Content:

Following termination or deactivation of your account, the Company, its Affiliates, or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes.



6. OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them. Please remember that when you use a link to go from our Services to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content you do so at your own risk.


7. YOUR RIGHTS

We are committed to ensuring that your personal data is stored securely. You have the right to request for access to, to request for a copy of and to request to update or correct your personal data held by us. You have the right at any time to withdraw your consent to the collection, use and disclosure of your personal data request us to limit the processing and use of your personal data. (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes). However, please note that such requests may affect our ability to provide the Services to you. Please direct your requests to our Data Protection Officer as set out in clause 8 below.


8. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Services, please contact us:

Data Protection Officer

Address: MetLife Innovation Centre Pte. Ltd. 9 North Buona Vista Drive #20-05 Singapore 138588

Email Address: DPO@lumenlab.sg


9. CHANGES TO OUR PRIVACY POLICY

We may modify or update this Privacy Policy from time to time, so please review it periodically. We will provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Your continued use of the Services of any part of them after any modification to this Privacy Policy will constitute your acceptance of such modification. If you do not agree to any of the amendments to this Privacy Policy, you must stop accessing and/or using the Services.

Data Protection Policy