“personal data” means data, whether true or not, about a customer 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
(a) Personal data and contact information. We may collect information with personal identifiers including your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information.
(b) 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).
(c) 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”).
4. Most information will be collected when you use the Site or Service. However, we may also use various technologies on the Site which may lead to information being collected automatically by us or from other sources such as advertising, analytics providers, search information providers and mailing lists. This information does not generally, but may, contain your personal data.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
5. 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”) 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 written 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).
6. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) analysing trends;
(d) administering the Site;
(e) tracking user movements;
(f) gathering broad demographic information for aggregate use of the Service;
(g) sending you marketing information about the Service including notifying you of our marketing events, initiatives and other promotions;
(h) 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;
(i) any other purposes for which you have provided the information;
(j) 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; and
(k) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(l) managing your relationship with us; and
(m) any other incidental business purposes related to or in connection with the above.
7. 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 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 goods and/or services requested by you; or
(b) 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;
(c) 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;
(d) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
8. We do not sell, rent, licence or otherwise disclose your personal data to third parties. We are careful in our selection of third party service providers, and when we disclose your personal data to such parties, we shall require them to ensure that they are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations as set out in the PDPA.
9. We may also disclose aggregated information that is Anonymised Data about our users, including but not limited to the total number of our users and their overall demographics.
10. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
TRANSFERS OF PERSONAL DATA OUTSIDE SINGAPORE
11. Pursuant to the purposes and activities as set out herein, it may be necessary for us to transfer your personal data out of Singapore for storage, processing and use by Motion Ventures and its affiliates or any Motion Ventures Sponsors. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such personal data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the PDPA.
WITHDRAWING YOUR CONSENT
12. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided in clause 25 below.
13. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
14. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Service to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 25 below.
15. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
16. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you, or (b) information about the ways in which we use or disclose your personal data, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided in clause 25 below.
17. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
18. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
19. 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. Examples of measures we have implemented include authentication and access controls, securely erase storage media in devices before disposal, and usage of one time password (otp)/2 factor authentication (2fa)/ multi-factor authentication (mfa) to secure access.
20. 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 personal data by constantly reviewing and enhancing our security measures. However, we cannot accept responsibility for misuse or loss of, or unauthorised access to your personal data.
21. 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 unauthorised or unintended use, access or disclosure of your personal data.
ACCURACY OF PERSONAL DATA
22. 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 in clause 25 below.
RETENTION OF PERSONAL DATA
23. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
24. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
DATA PROTECTION OFFICER
Attn: MV Data Protection Officer
Email Address: firstname.lastname@example.org
26. All requests for correction or for access to your personal data must be in writing. We will endeavor to respond to your request within thirty (30) days, and if that is not possible, we will inform you of the time by which we will respond to you.
27. All complaints will be evaluated by Motion Ventures in a timely manner. After Motion Ventures has completed its evaluation, our Data Protection Officer (or duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.
28. We may be prevented by law from complying with any request that you make. We may also decline any request that you may make if the law permits us to do so.
Last updated : 07/09/2023