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    TERMS OF SERVICE

    Background

    These terms define the relationship between you and Spore Sixtyfive Pte. Ltd. (as defined below). Please read all of the following terms and conditions of service (this “TOS”) carefully before using this website or any of our Services (as defined below). By continuing to access, link to, or use this website and the information contained hereon, including but not limited to text, content, photographs, video, audio and graphics (“our site”), or any service on our site, you confirm that you accept this TOS and that you agree to comply with them. If you do not agree to the terms, you must not access or otherwise use our site or any of our Services. When we refer to “Spore Sixtyfive Pte. Ltd.”, “we”, “us” “our”, we refer to Spore Sixtyfive Pte. Ltd. and its affiliates, whereby the term “affiliate” with respect to a party hereto shall mean any person or entity that controls, is controlled by, or is under common control with, such party (with “control” meaning the ability to control via board control, equity ownership, contract or otherwise).

    Our Privacy Policy  also applies to your use of our site and is incorporated into this TOS by reference.

     

    Services

    This TOS applies to our site and other websites, applications, communications and other services, whether online or offline, that state that they are offered under or incorporate this TOS (the “Services”), including the offsite collection of data for those Services, such as our advertisements, marketing and other communications. We operate our site at our sole discretion and shall have the right to change, modify or suspend any aspect or feature of our site and/or any Services.

     

    Updates

    We may modify this TOS or our Privacy Policy from time to time without any prior notice. As changes to this TOS or our Privacy Policy take effect when they are posted on our site, you may determine if any such revision has taken place by referring to the date on which this TOS was last updated and should visit this website periodically to note any changes. Your continued use of any of our Services, including without limitation our site, constitutes your acknowledgement and acceptance of such updated terms. Any terms and conditions proposed by you which are in addition to or which conflict with this TOS are expressly rejected by Spore Sixtyfive Pte. Ltd. and shall be of no force or effect.

     

    Your Account and Membership

    [You acknowledge and agree that to access certain Services, you may be required to register as a member. In such cases, your use of such Services in your capacity as a member is subject to the terms and conditions you received or accepted when you signed up as a member and in your capacity as a member.

    Specifically, as a member, you acknowledge that certain features on our site are used by a community of members, and you hereby agree and undertake to:

    • Treat all users with respect and civility;
    • Not to harvest or otherwise collect information about users, including their contact details;
    • Not to annoy, pester, solicit, harass, threaten, offend, insult, abuse, defame, or injure any other users, or commit any unlawful or tortious acts against other users; and
    • Not to spam, mail bomb, send viruses, spyware, malware, worms or other damaging material to other users, or act in any manner that adversely affects the use of the Services by other users.]

    [If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential and must not disclose such information to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provisions of this TOS. If you know or suspect that anyone other than yourself knows your account details, you must promptly notify us or close your account, failing which you shall be held liable for any misuse arising out of or in connection with your account.]

    [Save as expressly provided for in this “Your Account and Membership” section, terms and conditions under this TOS apply to your use of our site, and the content made available on or through our site, as well as any relevant Services, in your capacity as a website user or visitor, without the need for any registration. As such, in the event of a conflict or any inconsistency of the terms and conditions herein and that which govern your relationship with us in your capacity as a member, the terms and conditions in the latter shall prevail.]

     

    Service Availability

    We may change, suspend or end any Service or your use thereof (including where applicable, cancel any account that you may have), or change and modify prices (if applicable) prospectively at any time in our discretion. Notwithstanding any terms or conditions to the contrary in this TOS, to the extent allowed under law, these changes may be effective without any notice or for any reason whatsoever. We may also impose restrictions on certain features or restrict your access to parts or the entire Services or Site without notice or liability. We reserve the right to suspend, limit or terminate your use and access to the Services (and where applicable, cancel any account you may have) at any time at our sole discretion without further notice and for any reason whatsoever.

     

    Intellectual Property Rights

    We are the owner or the licensee of all intellectual property rights in our site, including but not limited to text, content, photographs, video, audio, graphics, user interface design or logo, net domain names, specifications, know-how, service marks, ethical or moral rights hereon, the material published on our site, and/or any parts of the Services (whether or not registered as well as all rights to use for registration). All such rights are reserved. Our site is also protected as a collective work or compilation under Singapore copyright and other laws and treaties. All individual articles, columns and other elements making up our site are also copyrighted works. You agree to abide by all applicable copyright and other laws, as well as any additional copyright notices or restrictions contained on our site.

    Nothing in this TOS or your use of our site grants you any ownership or rights in our site, the Services, the content or information made available through the Services, or any of our trademarks, trade names, service marks, copyrights, or logos, except as expressly provided for under this TOS. You must not use any part of the content on our site for commercial purposes without obtaining a licence to do so from us or our licensors.

    In particular, without our prior consent in writing:

    • Our status (and that of any identified contributors) as the authors of content on our site must always be acknowledged (except where the content is user-generated).
    • You may print off one copy, and may download extracts, of any page(s) from our site for your personal non-commercial use and you may draw the attention of others within your organisation to content posted on our site provided that any copyright and/or proprietary notices are retained.
      • You must not modify the paper or digital copies of any materials you have printed off or downloaded in any way, and you must not use any illustrations, photographs, video or audio sequences or any graphics separately from any accompanying text.
      • You must not use the paper or digital copies of any materials you have printed off or downloaded for any commercial, business or otherwise mass-market activities.

    If you print off, copy, download, share or repost any part of our site in a manner that is not in accordance with the above, your right to use our site will cease immediately and you must, at our option, return or destroy any copies of the materials you have made.

    • You must not recompile, decompile, disassemble, reverse engineer, distribute, publish, display, perform, modify, upload to, link to, create derivative works from, transmit, or in any way exploit any part of our site.
    • You must not use any of the trademarks, trade names, service marks, copyrights, or logos of Spore Sixtyfive Pte. Ltd. in any manner which creates the impression that such items belong to or are associated with you or are used with Spore Sixtyfive Pte. Ltd.’s consent, and you acknowledge that you have no ownership rights in and to any of such items.
    • You must not offer any part of our site for sale or distribute it over any other medium including but not limited to over-the-air television or radio broadcast, a computer network or hyperlink framing on the internet.

     

    Acceptable Use Policy and Restriction of Use

    You may not use our site or any Service for any illegal purpose, for the facilitation of the violation of any law or regulation, or in any manner inconsistent with this TOS. You must at all times comply with applicable law and regulations when accessing our site and utilising any of the Services, including but not limited to uploading user content to our site. You may not input, distribute, upload, post, email, transmit or otherwise make available any content through our site that: (a) is promotional in nature, including solicitations for funds or business, without the prior written authorisation of Spore Sixtyfive Pte. Ltd., or constitutes junk mail, spam, chain letters, pyramid schemes or the like; (b) is unlawful, harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, libellous, invasive of another’s privacy, hateful, or racially, ethnically or otherwise objectionable; (c) you do not have the right to make available under any law or under contractual or fiduciary relationships (such as inside information, proprietary and confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements); (d) infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; (e) contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware, or telecommunications equipment; (f) is harmful to minors; or (g) constitutes the personally identifiable information of any other person that such person has not authorised you to disclose.

    You agree to use our site solely for your own non-commercial use and benefit, and not for resale or other transfer or disposition to, or use by or for the benefit of, any other person or entity. You agree not to use, transfer, distribute, or dispose of any information contained in our site in any manner that could compete with the business of Spore Sixtyfive Pte. Ltd. or any of its suppliers.

    Our site and the information contained therein may not be used to construct a database of any kind. Nor may our site be stored (in its entirety or in any part) in databases for access by you or any third party or to distribute any database services containing all or part of our site. You may not use our site in any way to improve the quality of any data sold or contributed by you to any third party.

    You may neither interfere with nor attempt to interfere with nor otherwise disrupt the proper working of our site, any activities conducted on or through our site or any servers or networks connected to our site. You may neither obtain nor attempt to obtain through any means any materials or information on our site that have not been intentionally made publicly available either by public display on our site or through accessibility by a visible link on our site. You shall not violate the security of our site or attempt to gain unauthorised access to our site, data, materials, information, computer systems or networks connected to any server associated with our site, through hacking, password timing or any other means. You may neither take nor attempt any action that, in the sole discretion of Spore Sixtyfive Pte. Ltd., imposes or may impose an unreasonable or disproportionately large load or burden on our site or the infrastructure of our site. You shall not use or attempt to use any “scraper,” “robot,” “bot,” “spider,” “data mining,” “computer code,” or any other automated device, program, tool, algorithm, process or methodology to access, acquire, copy, or monitor any portion of our site, any data or content found on or accessed through our site, or any other website information without the prior express written consent of Spore Sixtyfive Pte. Ltd.. You may not forge headers or otherwise manipulate identifiers in order to disguise the origin of any other content.

     

    Licence

    You acquire absolutely no rights or licences in or to our site and materials contained within our site (including images, details, data, illustrations, designs, icons, photographs, video clips, text, software, graphics, scripts, logos, and other materials that are part of our site) other than the limited right to utilise our site in accordance with this TOS. Such materials may be provided by trademarks, service marks, copyrights and other intellectual or ownership rights owned by Spore Sixtyfive Pte. Ltd.. Should you choose to download content from our site, you must do so in accordance with this TOS. Such download is licensed to you by Spore Sixtyfive Pte. Ltd. ONLY for your own personal, non-commercial use in accordance with this TOS.

    When you upload or post content to our site, you grant the following rights to use that content: a perpetual, nonexclusive, irrevocable, fully paid, royalty-free, sublicensable and transferable (in whole or in part) worldwide right and licence in any and all media, now known or later developed, (a) to us to use, publish, reproduce, display, modify, transmit digitally, create derivative works based upon, distribute, copy, and otherwise exploit, such content for any purpose whatsoever (including, without limitation, advertising, commercial, promotional and publicity purposes) in Spore Sixtyfive Pte. Ltd.’s sole discretion without additional notice, attribution or consideration to you or to any other person or entity and (b) any other user to access, store, or reproduce such material for that user’s personal use. You grant Spore Sixtyfive Pte. Ltd. the right to use the name that you submit in connection with such content.

     

    User-Generated Content

    Our site may include information and materials uploaded by other users of our site. This information and the materials have not been verified or approved by us. The views expressed by other users on our site do not represent our views or values. The information and materials made available through our site may contain typographical errors or inaccuracies as we do not control the information provided by other users that is made available through our site.

    You represent and warrant that you own or otherwise control all of the rights to the material that you submit; that the material you submit is truthful and accurate; that use of the material you supply does not violate this TOS.We reserve the right to edit, restrict or remove any content you provide for any reason at any time in our sole discretion. This includes where Spore Sixtyfive Pte. Ltd. receives a complaint from another user or a notice of intellectual property infringement or other direction for removal, or where in Spore Sixtyfive Pte. Ltd.’s sole and absolute opinion such content is in breach of this TOS, or is illegal or otherwise objectionable, or for any other reason as Spore Sixtyfive Pte. Ltd. may see fit.

     

    Notification of Infringement

    Spore Sixtyfive Pte. Ltd. reserves the right to investigate notices of copyright, trademark and other intellectual property infringement (“Infringement”) on our site (“Infringing Material”) and take appropriate action.

    If you believe that your work has been used or copied in a way that constitutes Infringement and such Infringement is occurring on the Site, please notify Spore Sixtyfive Pte. Ltd. in writing immediately in the form and containing the information prescribed by the Copyright Act 2021 of Singapore, as may be amended from time to time (“Infringement Notice”). All Infringement Notices shall be sent to Spore Sixtyfive Pte. Ltd. addressed to [email protected]and in consideration of us reviewing such notices, you agree that you shall not take any legal action or exercise any legal remedy you may have against Spore Sixtyfive Pte. Ltd. in respect of any Infringing Material, unless and until you have first given Spore Sixtyfive Pte. Ltd. the Infringement Notice and reasonable opportunity to remove the Infringing Material, but Spore Sixtyfive Pte. Ltd. refuses or fails to remove the Infringing Material. Where Spore Sixtyfive Pte. Ltd. removes the Infringing Material in response to your Infringement Notice, you agree not to exercise and you hereby waive, any right of action against Spore Sixtyfive Pte. Ltd. under applicable law which you may have in respect of any Infringing Material appearing on our site prior to such removal.

     

    No Warranty

    To the extent under applicable law, Spore Sixtyfive Pte. Ltd. : (a) does not warrant and disclaims all implied warranties and representations (for example warranties of merchantability, fitness for a particular purpose, accuracy of data, and non-infringement); (a) does not guarantee that the Services will function without interruption, errors or omissions; and (c) provide the Services (including content and information) on an “as is” and “as available” basis.

    Spore Sixtyfive Pte. Ltd.  makes no warranty of any kind, express or implied, as to our site, including, but not limited to, non-infringement, non-infringement of third party rights, title, any implied warranties or merchantability or fitness for a particular purpose or use. Spore Sixtyfive Pte. Ltd. does not warrant that our site is compatible with your equipment or that our site, or e-mail sent by Spore Sixtyfive Pte. Ltd. or its representative, is free of errors or viruses, worms or “Trojan horses,” or any other harmful, invasive, or corrupted files, and is not liable for any damage you may suffer as a result of such destructive features.

    The content on our site is provided for general information only. It is not intended to amount to advice (whether investment, accounting, legal, tax or other advice) on which you should rely. You must, at all times, obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on our site. Any financial or investment information on our site are for use in Singapore only and are intended for your general information only. You should not rely upon such information in making any particular investment or other decision which should only be made after consulting with a fully qualified financial adviser. Although we make reasonable efforts to update the information on our site, we make no representations, warranties or guarantees, whether express or implied, that the content on our site is accurate, complete or up to date. Any use you make of the information provided on our site is entirely at your own risk and we will not be liable for any damages or losses (including any loss of data or profits) resulting from your use of our site.

    [Any expressions of opinion, estimates and projections on our site are those of the authors at the date of writing and are subject to change at any time without prior warning. They do not necessarily reflect our view. We may discontinue, or make changes in, our Services, the information, data and documents, and the products or services described herein, at any time without prior notice. All information marked with any date is published as of such date only. There is no obligation or responsibility is undertaken to update or amend any such information.]

     

    [No Offer

    Nothing contained on our site constitutes an offer or part offer to provide asset management or advisory services, either on a discretionary or non-discretionary basis, other than under the terms of an agreement that accords with applicable laws and regulations. No information contained on our site shall be deemed to constitute an invitation to subscribe for or otherwise acquire securities, derivative products, or units in mutual funds.]

     

    Linking to Our Site

    You may provide a link to our site, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it. You must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. The website in which you are linking must comply in all respects with the content standards set out in our “Acceptable Use Policy and Restriction of Use” section set out above.

    We reserve the right to withdraw linking permission without notice.

    If you wish to link to or make any use of content on our site other than that set out above, please contact us at [email protected].

     

    Third Party Sites or Services

    Our Services may provide You with access to third party sites or services (“Third Party Sites”). Any access or use of any such Third Party Site is entirely at your own discretion and risk.

    Further, your use of any Third Party Site shall be governed by the terms and conditions of that website. It is your sole responsibility to review the terms and conditions of a Third Party Site before accessing or using the said website.

    We are not responsible for the availability, content, or accuracy of other Third Party Sites, services, or goods that may be linked to, or advertised on, our site. We do not: (a) make any warranty, express or implied, with respect to the use of the links provided on, or to, our site; (b) guarantee the accuracy, completeness, usefulness or adequacy of any other Websites, services, goods, or advertisements that may be linked to the our site; or (c) make any endorsement, express or implied, of any other Websites, services, goods, or advertisements that may be linked to our site.

    To the extent permissible by law and without prejudice to any other provisions in this TOS, we disclaim any and all liability for any loss, damage and any other consequence arising from or relating to, whether directly or indirectly, to your access to any Third Party Site or any information you provide to or any transaction conducted on such Third Party Site or any act, omission, default on the part of the third party.

     

    Services that We are Not Obligated to Perform

    We have no obligation to monitor or enforce any intellectual property rights that may be associated with content you provide us, but we have the right to enforce any rights which we may have through any means we see fit. We do not control or endorse all of the content, messages or information found on our site or external sites that may be linked to or from our site and, therefore, we specifically disclaim any responsibility with regard thereto.

    We have no obligation to accept, display, review, monitor, or maintain any content submitted by users, user forum posts, commentary, ratings or compliments (“Comments”). We have the right to delete content or Comments from our Sites without notice for any reason at any time in our sole discretion. We may move, re-format, edit, alter, distort, remove or refuse to exploit content or Comments without notice to you and without liability. Notwithstanding the forgoing rights, we reserve the right to treat content provided by users and Comments as content stored at the direction of users for which we will not exercise editorial control except as required to enforce the rights of third parties and applicable content restrictions below when violations are brought to our attention.

     

    Limitation of Liability

    You agree that your use of our site is at your sole risk and acknowledge that our site and anything contained within the website, including, but not limited to, content, services, goods or advertisements are provided “as is” and “as available”.

    To the fullest extent permissible by law, Spore Sixtyfive Pte. Ltd. shall not be liable and shall assume no liability for any losses, damages or expense of any kind howsoever caused as a result of the use of or access to the Services, or your inability to use or access the Services, including any loss or damages suffered as a result of relying on the Services and/or in connection with this TOS.

    You agree that in no event shall Spore Sixtyfive Pte. Ltd. be liable to you for any damages, losses, expenses, liabilities under any causes of action (whether in contract or tort including, but not limited to negligence, or otherwise) caused through the use of, or the inability to use or access our site or the Services or any other website. In the event that Spore Sixtyfive Pte. Ltd.is liable for damages despite the foregoing provision, you agree that Spore Sixtyfive Pte. Ltd.’s aggregate liability to you for any and all causes of action shall not exceed in aggregate of S$50.00.

    To the fullest extent permissible by law, under no circumstances, including but not limited to negligence, shall Spore Sixtyfive Pte. Ltd., its suppliers, agents, directors, officers, employees, representatives, partners, successors, or assigns be liable to you for direct, indirect, incidental, consequential, special, punitive, or exemplary damages even if such damages were foreseeable or Spore Sixtyfive Pte. Ltd. has been advised specifically of the possibility of such damages, arising from use of or inability to use our site, the Services or any links or items on our site or any provision of this TOS, such as, but not limited to, loss of revenue or anticipated profits or lost business.

     

    Indemnity

    You agree, at your own expense, to indemnify, defend and hold harmless Spore Sixtyfive Pte. Ltd., its suppliers, agents, directors, officers, employees, representatives, partners, successors, and assigns from and against any and all claims, damages, liabilities, costs, and expenses, including legal costs and expenses, including any other professional fees, arising out of or in connection with our site, directly or indirectly, from your access of and/or use of our site, including without limitation: (a) a violation or alleged violation of this TOS by you or anyone using your computer (or account, where applicable) including any breach of any covenant or agreement to be performed by you hereunder; (b) any claims of infringement of any intellectual property right of any third party, or any right of privacy or publicity, is libellous or defamatory, or otherwise results in injury or damage to any third party; (c) any deletions, additions, insertions or alterations to, or any unauthorised use of, our site by you or someone using your computer (or account, where applicable); or (d) any misrepresentation or breach of representation or warranty made by you contained herein.

    Spore Sixtyfive Pte. Ltd. reserves the right to all remedies available at law and in equity. You agree to pay any and all costs, damages, and expenses, including, but not limited to, all legal fees and costs awarded against or otherwise incurred by or in connection with or arising from any such claim, suit, action, or proceeding attributable to any such claim. Spore Sixtyfive Pte. Ltd. reserves the right to assume the exclusive defence and control of any matter otherwise subject to indemnification by you, in which event you will fully cooperate with Spore Sixtyfive Pte. Ltd. in asserting any available defence. You acknowledge and agree to pay our legal fees and expenses incurred in connection with any and all lawsuits brought against you by Spore Sixtyfive Pte. Ltd. under and in connection with this TOS, our Privacy Policy and any other terms and conditions of service on our site, including without limitation, lawsuits arising from your failure to indemnify Spore Sixtyfive Pte. Ltd. pursuant to this TOS.

     

    Assignment

    You may not assign, novate or otherwise transfer any of your rights or obligations under or in connection with this TOS to any party.

    We may assign, novate or otherwise transfer our rights and obligations under or in connection with this TOS to another party. We may also delegate or sub-contract any obligations under this TOS. Notwithstanding the above, we will inform you if any of these happen and will ensure that such assignment, novation, transfer, delegation or sub-contract will not have a material adverse effect on your rights under this TOS.

     

    Governing Law and Jurisdiction

    This TOS shall be governed and construed in accordance with the laws of Singapore (including the Evidence Act 1893 of Singapore and the Electronic Transactions Act 2010 of Singapore, both as may be amended from time to time), without regard to any conflict of law provision. The courts of Singapore shall have exclusive jurisdiction to hear and determine any suit, action or proceeding, and to settle any disputes (the “Disputes”) which may arise out of or in connection with our site or this TOS or our Privacy Policy (including any dispute regarding the existence, validity or termination of this TOS or our Privacy Policy respectively), and for such purposes, you agree to submit to the jurisdiction of the courts of Singapore. Each party hereby waives any objection which it might at any time have to the courts of Singapore being nominated as the forum to hear and determine any proceedings and to settle any disputes. Notwithstanding the above, no Spore Sixtyfive Pte. Ltd.  group entity shall be prevented from taking proceedings relating to a Dispute in any other courts with jurisdiction. To the extent allowed by law, any Spore Sixtyfive Pte. Ltd. r group entity may take concurrent proceedings in any number of jurisdictions.

    Notwithstanding the above, you are responsible for complying with the laws of the jurisdiction from which you are accessing our site, and you agree and confirm that you will not access or use the information on our site in violation of such laws. You also agree that our failure to enforce any rights under this TOS will not constitute any waiver of any terms or conditions in this TOS.

     

    Miscellaneous

    Except as expressly stated otherwise in this TOS, an individual or a corporate entity who is not a party to this TOS shall have no right under the Contracts (Rights of Third Parties) Act 2001 of Singapore, as may be amended from time to time, to enforce any term or condition of this TOS.

    If any provision of this TOS is unlawful, invalid or unenforceable, this shall not affect the rest of the terms and conditions under this TOS.

    To the extent permissible by law, any claim or cause of action arising out of or related to use of our Site, under this TOS or in connection with the Services, these must be filed within 1 year after such claim or cause of action arose or be forever barred.

    The content on our site is not intended for use by or distribution to any individual or legal entity in any jurisdiction or country where such distribution, publication or use would be contrary to the law or regulatory provisions or in which the Spore Sixtyfive Pte. Ltd. entities do not hold the necessary registration or licence. Such individuals or legal entities in respect of whom such prohibitions apply, should not access or use our site.

     

    Questions

    If you have any questions about this TOS, please contact us at [email protected] All questions, feedback and other suggestions submitted will be treated as non-confidential and non-proprietary and may be disclosed or used by Spore Sixtyfive Pte. Ltd. in its sole discretion, without any obligation to compensate you.

     

    Updates

    This TOS may be updated from time to time without any prior notice. As changes to this TOS take effect when they are posted on our site, you may determine if any such revision has taken place by referring to the date on which this TOS was last updated and should visit our site periodically to note any changes. Your continued use of any Service, including without limitation our site, constitutes your acknowledgement and acceptance of such changes. We shall not be responsible or liable to you for any expense, loss, damage, liability or other consequence suffered by you or incurred by you in connection with any of the foregoing actions.

     

    Last Updated 10 April 2023

    Privacy Policy

    Privacy Policy

    Spore Sixtyfive Pte. Ltd. and its affiliates (“we”, “us” or “our”) respect the privacy rights of our users (“you” or “your”) and are strongly committed to protecting your privacy. This Privacy Policy aims to give you information on how we collect, process, use, disclose and retain your personal information through our websites, applications or such other electronic services provided by us, your purchase of or signing up to our products or services (whether online or offline, including newsletters), or when you attend any of our events, courses or programs (collectively our “Services” and each a “Service”). For the purposes of this Privacy Policy, the term “affiliate” with respect to a party hereto shall mean any person or entity that controls, is controlled by, or is under common control with, such party (with “control” meaning the ability to control via board control, equity ownership, contract or otherwise).

    This Privacy Policy is based on the Personal Data Protection Act 2012 of Singapore (as may be amended, supplemented or otherwise modified from time to time, the “PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Singapore (the “PDPC”).

    Notwithstanding the above, we will take steps to comply with all applicable laws with regards to data privacy, including where local laws are more stringent than this policy. For the purposes of this Privacy Policy, the term “applicable laws” shall mean applicable laws, regulations, codes of practice, guidelines, or rules as may be amended, supplemented or otherwise modified from time to time. If you are a European Union resident, please also refer to our General Data Protection Regulation Privacy Statement, which can be found here.

    Please review this Privacy Policy in its entirety carefully before using our website, or otherwise providing us with any of your personal information. This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal information by us. Specifically, this Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use, disclosure and/or retention of your personal information.

    Consent

    We will notify you of the purpose for collection, processing, usage or disclosure of your personal information before we collect, process, use or disclose such personal information respectively, including through the use of this Privacy Policy. By using and continuing to use this website, you consent to the collection, processing, usage and disclosure of your personal data for the purposes set out in this Privacy Policy.

    Under certain circumstances, we may deem that you have provided consent when you voluntarily provide your personal information for specific relevant purposes. For example, when you provide your name and contact information for the creation of an account, it is deemed that you have provided consent in relation to the creation of a profile linked to such account.

    We may also rely on exceptions to the need for consent under certain circumstances such as the following:

    • Such personal information is publicly available;
    • Such personal information is required for debt recovery from you or another person to us;
    • Such personal data is disclosed to us or otherwise obtained directly or indirectly from a public agency; and
    • Such personal data is disclosed to us as part of another person’s or entity’s contractual obligations or otherwise by contractual necessity.

    Information We Collect

    We may collect and process certain types of personal information. “Personal information” is data that relates to you and can (on its own or in combination with other information) identify you as an individual, whether true or not. It does not include data that has been aggregated or made anonymous whereby you can no longer be identified using means reasonably available to us.

    Personal information includes, among other things, personal information that you voluntarily provide on this website, which may include your:

    • Verification information: name; address; e-mail address(es); telephone number(s); date of birth; gender; race; nationality; and passport number;
    • Contact information: residential, mailing or billing address(es); e-mail address(es); and telephone number(s);
    • Payment information: credit or debit card numbers; and bank account, billing or other financial information;
    • Professional, academic or employment and information: company name; title; team; and other status and records;
    • Information relating to your use of the Services both offline and online ((where relevant, through cookies, pixels, web server logs, web beacons or other similar technologies – For more information, our Cookie and Other Digital Markers Policy can be found here): internet protocol address of your device; geo-location data; time, date or frequency of use; and preferences in relation to use;
    • Biometric information: photographs; and other audio-visual information and recordings; and
    • Social Media Information: social media and other instant messenger usernames; screen names; passwords and other profile and contact information relating to such social media and instant messenger,

    and any other types of information that you choose to upload, communicate or otherwise provide to us or that we may collect about you through our provision of any Services or your transactions with us in general, which may include any inquiries or feedback which we receive from you.

    In addition, we may also collect personal information provided by other organisations such as your employer, company or third-party sources (including other entities we believe you have authorised to provide such personal information for and on your behalf, such as business partners, unaffiliated third-party social media companies, data brokers and analysts (via data analytics tools or otherwise), or other information providers, or other commercially and publicly available and legitimate sources as permissible by applicable law). We set out the privacy policies of certain relevant third-party websites for your reference – Kindly familiarise yourself with these and ensure that you are comfortable with them:

    We also may collect information about you that is not personal information, which may include anonymised or aggregated information, intellectual property or other company information shared with us, from your use of the Services or otherwise. Where necessary, we may combine this information with personal information or other information that we receive from or about you to provide the Services you require in the manner set out below, which combination of such information possibly could be used to identify you personally.

    How We Collect, Use and Process Your Personal Information

    We may collect, use and/or process your personal information for the following purposes:

    • providing you with our online or offline Services;
    • carrying out your instructions or responding to your enquiries, requests for information submitted by your or on your behalf;
    • checking or verifying your identity and/or suitability as a client for certain Services;
    • administering and managing our relationship with you;
    • for any promotion, business development, marketing or other communications, including that relating to newsletters or promotional material which may consist of texts, photographs, videos, or such other audio-visual content;
    • for any logistical or administrative purposes in connection with any of our Services, including informing you or any updates or changes to any Service;
    • contacting or corresponding with you through various means including voice calls, text messages, email, or post to administer and manage your relationship with us, including the processing of and attending or responding to any feedback, opinions or comments;
    • processing payment, billing, invoicing or other credit-related actions;
    • complying with applicable law or in response to a subpoena, court order, government request, or other legal process for or in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
    • protecting, enforcing and/or complying with our contractual, legal rights and/or obligations, as applicable;
    • operating and maintaining our systems and carrying out our business operations or internal protocols and policies properly including to ensure the safety and security of our users, representatives and all relevant persons in both physical and online environment, including the prevention of fraud, abuse, or other illegal or prohibited activities; and
    • for any other incidental or ancillary purposes related to or in connection with the above, including audit requirements and carrying out market-related, evaluative, or similar research and analysis to review, develop, improve or enhance our Services.

    Certain personal information collected is processed and stored with our workspace management system provider OfficeRnD Ltd, which is an ISO 27001 and GDPR certified, and SOC 2 (for Security, Availability, Confidentiality and Privacy) compliant organisation to ensure that your personal information is securely stored. For more information on OfficeRnD Ltd’s privacy policy, please see here.

    Disclosure of Personal Information and Other Information

    We may disclose your information, including personal information:

    • to our affiliated or related group companies, where they are directly or indirectly involved in the provision of Services;
    • to any entity to whom we assign, novate or otherwise transfer or may assign, novate or otherwise transfer our rights and obligations in connection with the Services, whether in relation to a merger, acquisition or sale of all or a portion of our assets or otherwise;
    • where swift disclosure is required to respond to an emergency threatening the life, safety or health of you or any other persons;
    • where applicable laws or regulations require such disclosure, such as producing relevant documents or information for the compliance with a subpoena, court order, government request, or other legal process, whether in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
    • where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services you require;
    • to third-party service providers, agents, professional advisors and other organisations we have engaged to perform any of the functions listed in the section above for us, including (a) referring websites and applications, (b) social media services where accessed through our website or applications, (c) payment, workspace management and other backend related systems, as well as their respective representatives; and
    • where you have created an account and have publicly disclosed any personal information through your profile, member networks, chat rooms or other groups available to other account holders.

    Please review the privacy policies of any website or application that referred you to our websites or applications, or which you are accessing from our websites or application as we are unable to place limitations on their use of personal information.

    Accuracy and Security of Personal Information

    Where personal information is submitted by you on behalf of another person or concerns another person other than yourself, you represent and warrant to us that all the necessary consents procured in accordance with applicable law, for such purposes stated in the relevant sections of this Privacy Policy have been obtained from the relevant person(s) and that you have retained proof of these consents, such proof to be provided to us upon our request.

    Where we have an ongoing relationship with you, it is crucial that you update us of any changes or updates to your personal information. As such, we may from time to time do data verification exercises for you to provide us with any such updates.

    We strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We take reasonable effort to implement appropriate administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorised use, copying, disclosure, or modification; and (b) to ensure the integrity of the personal information, as encapsulated in our internal data protection rules and PDPA compliance policies. For example, we have the Azure Web Application Firewall set up in place and use the HTTPS protocol throughout our websites and web applications to provide centralised protection from common vulnerabilities and exploits in general, as well as to specifically ensure that our user communications with the servers are encrypted so that personal information are unlikely to be hijacked by third parties without authorisation. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is 100% secure, in particular the transmission of data over open or public networks. Therefore, we recommend against transmitting any confidential or sensitive data over open or public networks.

    In the unlikely event that we suffer a data breach in relation to personal information, we will assess whether the data breach is notifiable, and will attempt to notify the affected persons and/or the PDPC where it is assessed to be notifiable. To be clear, a data breach does not trigger any obligation to notify affected persons and/or the PDPC. For this purpose, a “data breach” in relation to personal information means (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of personal information; or (b) the loss of any storage medium or device on which personal information is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal information is likely to occur.

    Retention of Data

    Any personal information in our possession or under control will be destroyed and/or anonymised when:

    • the purpose for which the personal information was collected is no longer served by the retention of such personal information, including to address any complaints, as well as develop or improve our Services in line with feedback; and
    • the retention is no longer necessary for any audit, legal, regulatory, or business purposes, including the maintenance of business records in accordance with record retention requirements under applicable law or for business analysis purposes, as well as make or defend against any legal claims.

    Transfer of Personal Information to Other Countries

    Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information, as data in transit or otherwise to and in various countries around the world that may have different levels of privacy protection than your country. By submitting your personal information, you consent to such transfers and processing. We take reasonable steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal information are in place and that any transferred data is processed only in accordance with the PDPA, the GDPR and any other applicable law. Specifically, we have or will have in place appropriate contractual and/or commercial agreements or arrangements to ensure that while under certain circumstances your personal information may be disclosed or transferred to countries which do not have requirements of data protection that is comparable to that under the PDPA, parties will abide by the requirements under applicable law. Where it is necessary for relevant third parties to further disclose personal data onward to other third parties, we will endeavour to ensure that these parties also abide by the PDPA or such applicable law.

    Access, Correction and Withdrawal

    The consent that you provide for the collection, use, disclosure and retention of all or any parts your personal information will remain valid until such time it is being withdrawn by you in writing.

    You may request to access and/or correct the personal information currently in our possession or withdraw your consent for the collection, use, disclosure and/or retention of your personal information in our possession or under our control at any time by contacting us at [email protected]. Where appropriate, such request may be referred to the relevant data protection officer. To the extent possible, we may take steps to verify your identity before granting access or making any changes to your personal information to protect your privacy.

    For a request to access personal information, we will process your request within a reasonable amount of time from when the request is made.

    For a request to correct or update personal information, we will process your request as soon as practicable after the request has been made. Such correction or update may involve necessary verification, which may include sending the corrected or updated personal information to other organisations to which the personal information was disclosed within a year before the date the correction or update was made (unless that other organisation does not need the corrected personal information for any legal or business purpose), or if you so consent, only to specific organisations to which the personal information was disclosed by us within a year before the date the correction or update was made.

    While we will, in most instances, provide a copy of the requested information or make the requested correction or update, where we are unable to provide you with any records of personal information or to make a correction or update requested, we shall, where required under applicable law or otherwise appropriate, inform you of the reasons why we are unable to do so. Please note that depending on the request that is being made, we will only need to provide you with access to the personal information contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal information that we have on record, if the record of your personal information forms a negligible part of the document.

    We may also charge a reasonable fee for the handling and processing of your requests to access, correct and/or update your personal information. You will be notified in advance of such costs.

    For a request to withdraw your consent to the processing of personal information, we will process your request within a reasonable amount of time from when the request is made. Our ability to provide Services to you after such withdrawal may be affected. We will notify you of any impact before processing your request.

    Telemarketing Policy

    If you have registered your Singapore telephone number with any or all of the Singapore Do Not Call (“DNC“) registers (being the No Voice Call Register, the No Text Message Register and the No Fax Message Register), we will not send you promotional and marketing messages via SMS, fax, calls and other means, to the extent the respective Register(s) is/are applicable. However, if you have previously consented to our sending you such calls or messages to your Singapore telephone or facsimile number(s), we will continue to do so until you withdraw such consent in writing, regardless of your DNC nominations (prior or subsequent to such consent).

    Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS, fax, calls or any means, about Services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages by requesting for withdrawal in writing.

    Your Account

    Where applicable, you may be required to create an account to use our site and/or the Services. If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

    Questions or Feedback

    If you have any questions about this Privacy Policy or any other queries in relation to how we manage, protect and/or process your personal information, please contact us at [email protected]. Where appropriate, such request may be referred to the relevant data protection officer.

    Updates

    This Privacy Policy may be updated from time to time without any prior notice. As changes to this Privacy Policy take effect when they are posted on this website, you may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated and should visit this website periodically to note any changes. Your continued use of any Service, including without limitation this website, constitutes your acknowledgement and acceptance of such changes.

    Last Updated 20 April 2023

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