Last Revised: June 30, 2014
The PDPA has made a further distinction between Personal Data and Business Contact Information which specifies the scope of application of the Act itself.
“Personal Data” refers to data about an individual who can be identified from that data; or from that data and other information that the organisation is likely to have access. On the other hand, “Business Contact Information” is defined as “an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.”
For the avoidance of doubt, the PDPA does not cover Business Contact Information.
Acceptance of the Policy
Which information we may collect on our Users?
We collect two types of data and information:
A. Non-personal Information - The first type of information is non-identifiable and anonymous information (“Non-personal Information”). To put it simply, we have no idea what is the identity of the User from which we have collected the Non-personal Information. Like most websites on the Internet the Non-personal Information which is being gathered consists of technical information and behavioral information, without limitation, details such as:
- Type of operation system (e.g. Windows, Linux, etc.)
- Type of Browser (e.g. Firefox, Chrome etc.)
- Browser and keyboard language (e.g. English)
- IP Address
- Your approximate geographic location
- Any Similar technical information
- User activity such as log-ins, date, and time of access.
- Overall, impersonal statistical information regarding total amount of e-mails that were sent, received, opened and/or hyperlinks clicked by the recipient(s).
Please note that in order to collect the Non-Personal Information we may use common third party analytics services such as: Google Analytics , Facebook Insights etc.
B. Personal Information – The other type of information is individually identifiable information (“Personal Information“). To put it simply, this information may identify an individual or is of a private and/or sensitive nature. Personal Information which is being gathered consists of any personal details provided voluntarily by the User (e.g. User’s name, email address, company etc.) mainly by registration to the Platform and/or sync services of such Personal Information on our Platform. The clicks, mouse movements and similar information with regard to the User’s session (e.g. the fact that User has chosen to click on a certain link or access a certain webpage) may be identifiable and regarded as Personal Information. We also respect and treat any email you may send to us as Personal Information.
To avoid confusion, rest assured that any Non-personal Information combined with Personal Information shall be regarded as Personal information.
When you connect to third-party services provider (“Third-Party Services Provider”) via the Platform, for the first time, you will be asked to permit such Third-Party Services Provider to share with us information about you, such as: Basic Information (your first and last name, your profile picture and/or its URL & gender); Your latest Profile Status update; Pages you admin, your living location and hometown as specified in your profile; information regarding and/or relating to posts and/or posts in your news feed; Your user ID number, which is linked to publically available information such as name and profile photo.
How do we collect information on our Users?
Following are our main methods of collecting information on our Users
A. We collect information while you install, access, browse, view or otherwise use the Platform. In other words, when you use or otherwise access the Platform we are aware of your usage of the Platform, and may gather, collect and record the information relating to such usage. For example, when you connect to the Platform, your computer tells us your IP address.
B. We collect information which you provide us voluntarily. For example, when you wish to register to the Platform, we may ask you to provide certain Personal Information which shall be kept on our servers. Each time you will be interested in providing information voluntarily we may ask you to consent to the collection and public display of such information.
C. We will store, on our Platform, your customized templates , including and not limited to, your uploaded images and any other information you included in your templates, with our online backup & sync services.
D. We will store, on our Platform, your email distribution lists, including and not limited to, email addresses that were imported to or created on our platform, and any additional fields that were imported to or created on our platform.
E. We may track overall, Non-personal, email usage and hyperlink engagement. We will do so using standard email tracking methods, such as measuring hyperlink clicks and/or embedding a tiny tracking image. We do so to measure and improve the performance and quality of our services.
What are the purposes of collecting the information?
Non-personal Information is collected in order to:
- Enhance the User’s experience on the Platform (e.g. by determining the best location for buttons and links etc.).
- Learn about the preferences of Users and general trends on our Platform (e.g. understand which functionality of our Platform is more popular than others).
- Better understand the priorities and interests of our potential customers and partners in order to better suit their needs and increase the efficiency of our sales and marketing processes.
- Administer the Platform, help diagnose problems with our server, to gather broad demographic information.
Personal Information is collected in order to:
- Register you as a user of the Platform and to control access to your personal account.
- Personalize your experience on the Platform.
- Provide you with certain Features, services and information you have asked us to provide.
- Allow us to update you with news and tailored information regarding new features, offers and display content and advertising on or of the Services that we believe might be of relevance to you
- Manage your account and provide you with customer service, and to generally manage the Services and our business.
Sharing Personal Information with third parties
We may use your Personal Information for planning, research, design and marketing of services, letting our partners and affiliates service you with commercials and services, rendering assistance to law enforcement, government or regulatory agencies, or complying with any applicable laws or any order of court.
Any information disclosed in the public areas of the Site (such as message boards and forums) becomes public information. You should exercise caution when disclosing your personal information in this way.
We don’t under any circumstances, sell your email distribution lists, contact people on your lists, market to people on your lists, steal your lists, or share your lists with any other party, unless it’s required by law. If someone on your list complains or contacts us, we may then contact that person. Only authorized employees have access to view email distribution lists. You may export (download) your email distribution lists from our platform at any time, as long as we have a copy.
Deletion of Personal Information
If for any reason you wish to delete your Personal Information, you should send an email to the address email@example.com, and we will make reasonable efforts to delete any such information pursuant to any applicable privacy laws.
During your use of the Site, we may issue to and request from your computer blocks of data known as "cookies" to enable more convenient browsing when you revisit the Site. A cookie is a type of data which is sent from the Site to your Internet browser software, and is stored on your computer. Storing cookies does not have any adverse effect on your computer. You must not alter any cookies sent to your computer from the Site and you must ensure that your computer sends correct and accurate cookies in response to any relevant request from the Site.
We take a great care in maintaining the security of the Platform and your information therein, and in preventing unauthorized access to the Platform through use of standard industry technologies and internal procedures. However, we do not guarantee that unauthorized usage or access will never occur. We cannot assure that no unpermitted use of your locally personalized information is made by any third-party with access to your computer You are solely responsible for protecting your computer and your locally stored personal information in any way from unpermitted access and use. Users using the Platform agree to keep their password in strict confidence and not disclose such password to any third party.
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