Effective date: 25th April 2017
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.
This Policy applies to all visitors, users, and others who access the Services ("Users", “you” or “your”).
1. INFORMATION WE COLLECT
We collect the following types of information.
Information you provide us directly:
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:
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.
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 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
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.
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:
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.
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
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
Data Protection Officer
Address: MetLife Innovation Centre Pte. Ltd. 9 North Buona Vista Drive #20-05 Singapore 138588
Email Address: DPO@lumenlab.sg
Data Protection Policy