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This Acebound Ventures Data Protection Privacy Policy (“Privacy Policy”) sets out the basis and practices that ACEBOUND VENTURES PTE LTD (“The Company”, “Acebound” “we”, “is”, or “our”) follow with respect to the collection, use and/or disclosure of your personal data in accordance with the Personal Data Protection Act (the “PDPA”) of Singapore. This Privacy Policy 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 such purposes which have been notified.

This Privacy Policy is read in conjunction with, and is deemed incorporated by reference, to be part of our Terms of Use.

1. Personal Data

1.1. As used in this Privacy Policy, “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 we have or are likely to have access. Other terms used in this Privacy Policy shall

have the meanings given to them in our Terms of Use or the PDPA (where the context so permits).

1.2. Depending on the nature of your interaction with us, on the Sites or through any Service we provide, the type of information that we may collect includes but is not limited to the following (in no particular order):

(a) Personal data and information - We may collect information with personal identifiers, including your name and identification information such as your NRIC number, contact information such as your address, email address, telephone, mobile and facsimile numbers, nationality, gender, date of birth, marital status, photographs and other audio-visual information.

(b) Employment details – We may collect information from your CV in relation to your current and past occupation (including position, job title and company name), employment history, salary, and/or benefits or education history.

(c) Financial information – We may collect financial information such as credit card numbers, debit card numbers or bank account information and details of any other information that allows us to transact with you and/or provide you with our Services.

(d) Device and technical information - We collect device-specific and other technical information about your mobile or computer device such as the hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number).

(e) Other anonymised data - We may collect information that is not associated with or linked to your personal data and cannot be used to identify you or any other individuals (“Anonymised Data”).

1.3. Most information will be collected when you use the Sites or when you use the Services. However, we may also use various technologies on the Sites which may lead to information being collected automatically by us or from other sources such as advertising, sub-contractors in technical and payment services, analytics providers, search information providers and mailing lists. This information does not generally, but may, contain your personal data. In particular, information is likely to be collected as web beacons, web analytics, cookies.

2. The Purposes For Which We Use your Personal Data

2.1. As there are many circumstances in which we may collect information, we will endeavour to ensure that you are always aware of the information being collected, in particular by third parties. We generally do not collect your personal data unless:

(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, for example Facebook or any other non-Acebound digital platform) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes; or

(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall 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 (except where permitted or authorised by law).

2.2. The purposes for which we use your personal data may include (but are not limited) to any of the following:

(a) performing obligations in the course of or in connection with our provision of the services requested by you;

(b) providing you with services, for instance, extending invitations to talks, events and/or seminars;

(c) verifying your identity;

(d) responding to your requests or enquiries;

(e) evaluative purposes, for instance, for determining which services are suitable for or may be of interest to you;

(f) detecting usage patterns;

(g) troubleshooting crashes associated with specific hardware and software used to access the Sites and Services;

(h) analyzing trends;

(i) administering the sites;

(j) tracking user movements;

(k) gathering broad demographic information for aggregate use of the Services;

(l) processing payment or credit transactions;

(m) providing you updates, newsletter or marketing information about the Services on behalf of ourselves and through our sponsors or other third-party service providers, including notifying you of advertisements, marketing events, initiatives and other promotions;

(n) complying 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;

(o) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

(p) any other purposes for which you have provided the information; and

(q) any other incidental business purposes related to or in connection with the above.

2.3. Your personal data may also be anonymized for use by us and/or our affiliates for other purposes.

2.4. It may be necessary for us to disclose your personal data to our affiliates or to third parties in a manner compliant with the PDPA in order to carry out the purposes set out above. We may disclose or share personal data with such parties who provide necessary services to us, such as for processing activities like verification, website hosting, data analytics and payment processing. We may disclose your personal data in the following circumstances:

(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you;

(b) third party online payment processing companies who will process your payments so that you can use the Services and/or make any related purchases;

(c) our consultants and professional advisers (e.g. accounting firms, audit firms, law firms and/or other professional advisory firms) who are maintaining our records in accordance with legal requirements;

(d) governmental, regulatory or law enforcement bodies who have a legal right to demand for your personal data, in response to a legal request such as a court order, to investigate or report an illegal activity, or to enforce our rights or defend claims;

(e) our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of the our assets (which may include your personal data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding; or

(f) third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.


3. 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.

4. Protection of Personal Data

We will take reasonable steps to protect your personal data which we hold from misuse and loss and from unauthorised access, modification or disclosure. We will not keep your personal data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify your personal data if it is no longer needed.

5. Access to and Correction of Personal Data

5.1. As a general rule, you are entitled to have access to the personal data about you that is in our possession or control, and information about the ways in which your personal data has been or may have been used or disclosed within a year before the date of the request. This can be done by you making a written application to the Designated Person (as defined below) requesting for any such information. We reserve the right to charge a fee (representing our costs in administering your request) for supplying such information to you, and to refuse requests which, in our opinion, occur with unreasonable frequency.

5.2. We will also, where you have requested that we correct an error or omission in your personal data that is kept with us, correct such data as soon as practicable and send the corrected personal data to every organisation to which the personal data was sent before it had been corrected, if applicable, unless that organisation does not need the corrected personal data for any legal or business purpose.

5.3. We may, however choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases where:

(a) We are satisfied on reasonable grounds that the correction should not be made;

(b) The request for access is frivolous or vexatious or the information requested is trivial;

(c) The personal data are related to a prosecution and all the proceedings related to the prosecution have not been completed;

(d) The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm our competitive position; and

(e) The personal data was collected, used or disclosed for the purposes of an investigation and associated proceedings and appeals have not been completed.


6. Disclaimer

To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your personal data.

7. Transborder of Personal Data Outside of Singapore

If your personal data is transferred to a country or territory outside Singapore, for instance, if some services are sub-delegated to overseas resource centres, we will ensure that the recipients thereof provide a standard of protection to your personal data so transferred that is comparable to that which is provided herein.

8. Data Protection of Officer

We have designated the person whose details are set out below as the person (“Designated Person”) who will be responsible for ensuring our compliance with applicable data protection laws. If you have any queries or requests or wish to make any applications concerning your personal information or data, please contact the Designated Person:-

Email: (Attention to the “Data Protection Officer”)


9. Effect of Privacy Policy and Changes to Privacy Policy

9.1. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

9.2. We may revise this Privacy Policy from time to time without any prior notice. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

10. Governing Law

The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy, you must first contact our Data Protection Officer regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.

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