Privacy Policy 

This privacy notice discloses the privacy practices (“Privacy Policy”) of EXXA NETWORK LIMITED, having its service office at 360, Orchard Road, #06-07 International Building, Singapore 238869 (the “Company”, “we”, “us” and “our”) and applies solely to the information collected on the Company site (“Site”) and application (“App”), the Site and the App collectively referred to as (the “Platforms”). The Privacy Policy describes how Company uses and protects the information that you give while using the Platforms and intends to provide visitors and registered users of the Company’s Platforms (“You” or “Your”) with clear and complete information about the data and information that collected and the way that data and information is stored and used. The Company values the privacy of its users. Your privacy is important to us.

Before using the Platforms, we advise You to read this Privacy Policy and contact us at the e-mail address at [email protected] if You have any questions or concerns. By interacting with us and by submitting information to us, or signing up for any services offered by us, You agree and consent to the Company, its related corporations as well as the Company’s representatives collecting, using, disclosing and sharing amongst themselves Your data in strict accordance with the terms of this Privacy Policy.

For avoidance of doubt, this Privacy Policy forms a part of the Company’s Website & App Terms of Use (EXXA – Terms of Use). In the event of any conflict between this Privacy Policy and the Terms of Use, the Privacy Policy will prevail in relation to the usage of Your Personal Data, as defined below. All defined terms in the Terms of Use shall apply to this Privacy Policy unless specifically stated.

I. INFORMATION COLLECTED:
The Company only collect information wherever it is essential and only where it is relevant to our or its operations so as to be able to provide You with the best experience and service. The Company shall not collect, use or disclose Your personal information unless You give consent to us for the collection, use or disclosure of Your personal information. The Company promises to only collect and use personal information as mentioned below:

 Your personal information which identifies You, including Your birth date, IP address, login information, browser details and settings and details regarding Your operating system;

 contact information such as e-mail addresses and telephone numbers;

 information on how you purchase and use the company’s software and services; and

 Your Payment related information including Your bank account number and Your credit or debit card details.
The items so collected shall constitute “Personal Data”, which is defined under the Personal Data Protection Act of Singapore (the “PDPA”) to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. Personal Data collected by the Company shall be subject to complete protection by the Company in accordance with applicable law.

II. COLLECTION OF PERSONAL DATA:
Generally, the Company will collect Personal Data when You:
a) register on the Platforms;

b) submit Personal Data to us voluntarily;
c) make payments to us, through our Platforms or otherwise (where applicable);
d) use the Company’s services; or
e) establish contact with us through the site, by telephone, post, e-mail or through any other means.
When You browse our Platforms, You generally do so anonymously. You will not be required to provide any personal details while browsing the Platforms.
The Company collects Personal Data in two ways. The first is when You provide us with information while using the Platforms, including filling out forms or contacting the Company using the given contact details. The second is when You browse the Platforms, where technical non-identifiable data is collected.

You should ensure that all Personal Data that You submit to us is complete, accurate, true and correct. Failure on Your part to submit this information accurately may result in our inability to provide You with the best possible experience while using our Platforms and any of our products.

III. INFORMATION PROTECTION:
Browsing the Platforms will not require You to provide any personal details, so no sensitive Personal Data is automatically collected. You will remain anonymous and You will remain unidentified until You choose to register an account on the Platforms.

The Company will protect Your Personal Data in strict accordance with applicable laws, including in accordance with the provisions of the PDPA. Nevertheless, You acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to the Company is done so at Your own risk. The Company does not warrant or guarantee that the information You provide will not be accessed, copied, used, or disposed of in breach of its security measures, and You agree not to hold us liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, the Company will, as far as reasonably possible, promptly notify all affected persons.

Unless required by law or a Court order or direction, or unless as relevant for the purpose stated:

 The Company will not sell, share or trade Your Personal Data collected online with third parties, except unless strictly necessary to complete a payment or under a direction by a court of law or judicial authority; and

 Personal Data collected online will be for internal Company use only, and will be viewed by Company employees on a strict need to know basis only.

By accepting these conditions, and by continuing to use the Platforms, You agree and accept that all information provided by You will be true and will be kept up to date during Your continuing use of the Platforms.

IV. USER UNDERTAKING:
Users agree to provide up to date, accurate and correct personal information details, as requested by the Company. You agree that the Company shall not be liable for the misuse of any such details unless the misuse is as a result of the Company’s actions or proven gross negligence.

V. AGE OF CONSENT
By using the Platforms, You represent that You are at least the age of 18 years old, or you have given us your consent to allow any of your minor dependents to use the Platforms as the case may be.
The Company strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Platforms are not intended for use by minors, the Company respects the privacy of minors who may inadvertently use the internet or the mobile application.

VI. COMPANY UNDERTAKING:
The Company will endeavour to ensure that all information collected is safely stored. The Company will protect all information by:

 Implementing and maintaining security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of Your information;
 Restricting third party access to Your Personal Data unless absolutely necessary; and
 Not retaining Your Personal Data for any time period longer than required to fulfil the purpose(s) listed below.
VII. COLLECTION AND USE OF DATA:
The Company may use Your Personal Data for the purposes below if we deem it necessary to do so for its legitimate interests. If You are not satisfied by this, You have the right to object in certain circumstances (see the section headed “Data Protection Rights” below).

1. Purposes for Collecting Personal Information
Generally, the Company may use Your information for:

 Responding to queries and questions;
 Verifying Your identity;
 Providing You with: our software online, login authentication, age verification, remembering Your settings, and hosting back end infrastructure;
 For managing the infrastructure and the business operations of the Company;
 Protecting and enforcing the Company’s legal rights and obligations;
 Compliance with applicable rules, laws and regulations, codes of practice or guidelines;
 To maintain Your account with us;
 To verify Your particulars in relation to the services we provide to You;

 To provide You with the services You have signed up for and for improving and developing the Company’s software, services and Platforms;
 Traffic optimization, data analytics and research, including profiling and the use of services such as Google Analytics, managing landing pages and heat mapping our Platforms;
 Sending You communications about our services, products and features that You have agreed to receive;
 Communicating with You, if required, to inform You of any new services or developments relating to the Company or the services we provide; or
 Any purpose relating to the above.

2. Downloading the App:
If You download the App, the Company may use information:
 Where the App includes App Subscription Services, to process Your application for these services;
 To maintain Your account with us;
 To verify and process Your personal particulars and payments in relation to the provision of services related to the App;
 Communicating with You, if required, to inform You of any new services or developments relating to the Company or the services we provide; and/or
 Any purpose relating to the above.

3. Additional Purposes:
In addition, where permitted by applicable law, the Company may also collect and use data collected from You for:
 Providing services, products and benefits to You;
 Sending You details of additional products, services that may be of use to You and that may enhance the quality of the product that the Company delivers to You; and
 In relation to particular products and services or in Your interactions with the Company, we may also specifically notify You of other purposes for which we collect, use and disclose Your Personal Data for these Additional Purposes as well.

VIII. EXCEPTIONS:
The Company is committed in its endeavour to comply with applicable law governing the protection of Personal Data. However, in exceptional circumstances, if the Company is required by law or by a court order or direction to disclose personal information, we will do so.

IX. DISCLOSURE OF PERSONAL DATA:
The Company will take reasonable steps to protect Your Personal Data against unauthorised disclosure. Subject to the provisions of applicable law, the Personal Data will be used only for the purposes stated in Clause VI above or to the following third parties, wherever located:
a) Company Affiliates. The Company will share information with its affiliates, who help us to provide and support our services and other business-related functions;
b) Banks, credit cards or service providers. The Company will share information with its third-party service providers, who help us provide and support our services and other business-related functions;
c) Professional advisors such as lawyers or auditors;
d) Relevant government regulators, authorities, law enforcement agencies or a court of law. The Company will only disclose Personal Data when we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect Your vital interest or those of any other person; and
e) Any other person with Your consent.

X. ADDITIONAL PRIVACY POLICY FOR PLATFORMS AND SERVICE USERS

1. Persons who have subscribed to use the Platforms for free (“Subscribers”) Note:
This section applies to all Subscribers:
As part of the signing-up process that is available to Subscribers on the Platforms, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.
All the statements in this Privacy Policy apply to all Subscribers, and all Subscribers are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Data or sensitive personal information to the Company, failing which they are required to leave the Platforms immediately.

If You have inadvertently submitted any such information to the Company prior to reading the privacy statements set out herein, and You do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then You may access, modify and delete such information by using options provided on the Platforms. In addition, You can, by sending an e-mail to [email protected], inquire whether the Company is in possession of your Personal Data, and You may also require us to delete and destroy all such information.
The Company will communicate with the Subscribers through the Platforms or via e-mail. The Subscribers can change their e-mail address by re-subscribing and sending an e-mail to [email protected] for the deletion of previous e-mail.

All of the Company’s employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.

To the extent necessary to provide Subscribers with our services, the Company may provide their Personal Data to third party contractors who work on behalf of or with us to provide Subscribers with our services, to help us communicate with Subscribers or to maintain the Platforms. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Platforms, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these services in accordance with their own privacy policies. In such circumstances, You consent to us disclosing your personal information to contractors, solely for the intended purposes only.

Subscribers may choose to unsubscribe from marketing communications that they receive from the Company or manage their preferences via the links provided at the end of every such e-mail and/or promotional communication.

2. Persons who register and have accounts to use the Platforms and App (“Members”) Note:
This section applies to all Members:
Accordingly, a condition of each Member’s use of and access to the Platforms and our services is their acceptance of the terms of this Privacy Policy. Any Member who does not agree with any provisions of the same has the option to discontinue the services provided by us immediately by contacting us at [email protected]

All the information provided to us by a Member, including Personal Data or any sensitive personal information, is voluntary. You understand that we may use certain information of yours, which has been designated as Personal Data under the PDPA, (i) for the purpose of providing You the services, (ii) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (iii) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. We also reserve the right to use information provided by or about the Member for the following purposes:

(a) Responding to queries and questions;
(b) Verifying Your identity;
(c) Providing You with: our software online, login authentication, age verification, remembering Your settings, processing payments and hosting back end infrastructure;
(d) For managing the infrastructure and the business operations of the Company;
(e) Protecting and enforcing the Company’s legal rights and obligations;
(f) Compliance with applicable rules, laws and regulations, codes of practice or guidelines;
(g) To maintain Your account with us;
(h) To verify Your particulars and payments in relation to the services we provide to You;
(i) To provide You with the services You have signed up for and for improving and developing the Company’s software, services and Platforms;
(j) Traffic optimization, data analytics and research, including profiling and the use of services such as Google Analytics, managing landing pages and heat mapping our Platforms;
(k) Sending You communications about our services, products and features that You have agreed to receive;
(l) Communicating with You, if required, to inform You of any new services or developments relating to the Company or the services we provide; or

(m) Any purpose relating to the above.

If You have voluntarily provided your Personal Data to us for any of the purposes stated above, You hereby consent to such collection and use of such information by us.
Collection, use and disclosure of information which has been designated as Personal Data under the PDPA requires your express consent. By affirming your assent to this Privacy Policy, You provide your consent to such use, collection and disclosure as required under applicable law. Our services may be unavailable to You in the event such consent through an e-mail is not given.

You are responsible for maintaining the accuracy of the information You submit to us, such as your contact information provided as part of account registration. If your personal information changes, You may correct, delete inaccuracies, or amend information by making the change on your account page or by contacting us at [email protected] We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If You provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or we have reasonable grounds to suspect that the information provided by You is untrue, inaccurate, out of date or incomplete, we may, at our sole discretion, discontinue the provision of our services to You. There may be circumstances where we will not correct, delete or update your Personal Data, including (i) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (ii) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

If You wish to cancel your account or request that we no longer use your information to provide You services, contact us through [email protected] We will retain your information for as long as your account with the Services is active and as needed to provide You the services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymised and aggregated, and then may be held by us as long as necessary for us to provide our services effectively, but our use of the anonymised data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in us being unable to provide You with our services or to terminate any existing relationship we may have with You.

If You wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the services, You may do so via your e-mail and/or account.

This Privacy Policy applies to services that are owned and operated by us. We do not exercise control over the websites displayed as search results or links from within its services. These other websites may place their own cookies or other files on the Member’s computer, collect data or solicit personal information from the Member, for which we are not responsible or liable. Accordingly, we do not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by us of the website, the website’s provider, or the information on the website. If You decide to visit a third party website linked to our Platforms, You do this entirely at your own risk. We encourage the Member to read the privacy policies of that third party website.

We do not collect information about the visitors of the Platform from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Members (the collection, use, storage and disclosure of which each user must agree to in order for us to effectively render the services).

We maintain a strict “No-Spam” policy, which means that we do not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.

We have implemented best international market practices and security policies, rules and technical measures to protect the Personal Data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorised access to the Member’s electronic devices through which the Member avails the services, we shall not be held liable for any loss whatsoever incurred by the Member.

We implement reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of our business. The reasonable security practices and procedures implemented by us include, but not limited to: ensuring that any Personal Data is protected by password.

No administrator at the Company will have knowledge of your password. You accept that you are responsible for keeping confidential Your username and password to your account with. Be sure to log off from the Platforms when finished. The Company does not undertake any liability for any unauthorised use of your account and password. If You suspect any unauthorised use of Your account, You must immediately notify the Company by sending an email to [email protected] You shall be liable to indemnify the Company due to any loss suffered by it due to such unauthorised use of your account and password.

We take your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your Personal Data in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when we, in our sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the terms under this Privacy Policy.
We take all reasonable steps to ensure that all unsolicited information is destroyed immediately.

3. Casual Visitors Note:
No sensitive personal data or information is automatically collected by us from any Visitors of the Platforms, who are merely perusing the Platforms.
Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such visitors are also required to read and understand the privacy statements set out herein, failing which they are required to exit the Platforms immediately.

If You, as a Visitor, have inadvertently browsed any other page of this Site prior to reading the privacy statements set out herein, and You do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by us. All Visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as we cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Site.

You are not a Visitor if You have willingly submitted any Personal Data or personal information to us through any means, including e-mail or through the registration process on the Platforms. All such visitors will be deemed to be, and will be treated as, Members for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons..

XI. TRANSFER & STORAGE OF PERSONAL DATA
Information collected in accordance with this Privacy Policy may be transferred, stored, or processed outside of Singapore. We will comply with our obligations under the PDPA and Personal Data Protection Regulations 2014 in relation to Personal Data transferred, stored, or processed outside Singapore for as long as the data remains in our possession or control during the transfer. We will take appropriate steps to ensure that, the recipient of the Personal Data who is located outside Singapore is legally obliged to provide to the Personal Data a comparable a standard of protection. However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore, in order to provide You with the services You request, You are deemed to consent to such transfer, storage, or processing in providing Your Personal Data to us during Your use of the Platforms. You may at any time inform us that You wish to withdraw Your consent to such transfer, storage, or processing of Your Personal Data.
Note to residents of the European Union (EU)
Whenever the Company needs to transfer Your Personal Data out of the EU, we will require Your explicit consent. Please contact the Company if You want further information on the specific mechanism used by us when transferring Your Personal Data out of the EU.

XII. YOUR DATA PROTECTION RIGHTS
You have the following data protection rights:

(a) Right to Access. The right to request (i) copies of the Personal Data the Company holds about You at any time, or (ii) that the Company modify, update or delete such information. If the Company provides You with access to the Personal Data the Company holds about You, the Company will not charge for this, unless Your request is ‘manifestly unfounded or excessive.’ In situations where the Company is legally permitted to do so, we may refuse Your request. If the Company refuses Your request, we will tell You the reasons why;
(b) Right to Correct. The right to have Your Personal Data rectified if it is inaccurate or incomplete; and
(c) Right to Erasure. The right to request that the Company delete or remove Your Personal Data from its systems