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Privacy and Cookie Policy
1. INTRODUCTION
This privacy notice provides you with details of how we collect and
process your personal data through your use of all of our websites owned by
Internet Marketer Pte Ltd.
Internet Marketer Pte Ltd are the data controller and we are
responsible for your personal data (referred to as "we", "us" or
"our" in this privacy notice).
Contact Details
Our full details are: Internet Marketer Pte Ltd
Email address: support@passive.com
Postal address: 51 Goldhill Plaza #08-02 Singapore 308900
It is very important that the information we hold about you is
accurate and up to date. Please let us know if at any time your
personal information changes by emailing us at support@passive.com.
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON
WHAT GROUND WE PROCESS IT
Personal data means any information capable of identifying an
individual. It does not include anonymised data.
We may process the following categories of personal data about you:
- Communication Data that includes any
communication that you send to us whether that be through the
contact form on our website, through email, text, social media
messaging, social media posting or any other communication that
you send us. We process this data for the purposes of
communicating with you, for record keeping and for the
establishment, pursuance or defence of legal claims. Our lawful
ground for this processing is our legitimate interests which in
this case are to reply to communications sent to us, to keep
records and to establish, pursue or defend legal claims.
- Customer Data that includes data relating
to any purchases of goods and/or services such as your name,
title, billing address, delivery address email address, phone
number, contact details, purchase details and your card details.
We process this data to supply the goods and/or services you
have purchased and to keep records of such transactions. Our
lawful ground for this processing is the performance of a
contract between you and us and/or taking steps at your request
to enter into such a contract.
- User Data that includes data about how
you use our website and any online services together with any
data that you post for publication on our website or through
other online services. We process this data to operate our
website and ensure relevant content is provided to you, to
ensure the security of our website, to maintain back- ups of our
website and/or databases and to enable publication and
administration of our website, other online services and
business. Our lawful ground for this processing is our
legitimate interests which in this case are to enable us to
properly administer our website and our business.
- Technical Data that includes data about
your use of our website and online services such as your IP
address, your login data, details about your browser, length of
visit to pages on our website, page views and navigation paths,
details about the number of times you use our website, time zone
settings and other technology on the devices you use to access
our website. The source of this data is from our analytics
tracking system. We process this data to analyse your use of our
website and other online services, to administer and protect our
business and website, to deliver relevant website content and
advertisements to you and to understand the effectiveness of our
advertising. Our lawful ground for this processing is our
legitimate interests which in this case are to enable us to
properly administer our website and our business and to grow our
business and to decide our marketing strategy.
- Marketing Data that includes data about
your preferences in receiving marketing from us and our third
parties and your communication preferences. We process this data
to enable you to partake in our promotions such as competitions,
prize draws and free give-aways, to deliver relevant website
content and advertisements to you and measure or understand the
effectiveness of this advertising. Our lawful ground for this
processing is our legitimate interests which in this case are to
study how customers use our products/services, to develop them,
to grow our business and to decide our marketing strategy.
- We may use Customer Data, User Data,
Technical Data and Marketing Data to deliver relevant website
content and advertisements to you (including Facebook adverts or
other display advertisements) and to measure or understand the
effectiveness of the advertising we serve you. Our lawful ground
for this processing is legitimate interests which is to grow our
business. We may also use such data to send other marketing
communications to you. Our lawful ground for this processing is
either consent or legitimate interests (namely to grow our
business). [NOTE SEE SECTION 4 BELOW]
Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data
refers to data that includes details about your race or
ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions, trade union membership,
information about your health and genetic and biometric data. We
do not collect any information about criminal convictions and
offences.
We do not carry out automated decision making or any type of
automated profiling.
3. HOW WE COLLECT YOUR PERSONAL DATA
We may collect data about you by you providing the data directly
to us (for example by filling in forms on our site or by sending
us emails). We may automatically collect certain data from you
as you use our website by using cookies and similar
technologies.
Please see our cookie policy for more details about this.
We may receive data from third parties such as analytics
providers such as Google based outside the EU, advertising
networks such as Facebook based outside the EU, such as search
information providers such as Google based outside the EU,
providers of technical, payment and delivery services, such as
data brokers or aggregators.
4. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you
marketing communications is either your consent or our
legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we
may send you marketing communications from us if (i) you made a
purchase or asked for information from us about our goods or
services or (ii) you agreed to receive marketing communications
and in each case you have not opted out of receiving such
communications since. Under these regulations, if you are a
limited company, we may send you marketing emails without your
consent. However you can still opt out of receiving marketing
emails from us at any time.
Before we share your personal data with any third party for
their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing
messages at any time by following the opt-out links on any
marketing message sent to you OR by emailing us at support@passive.com
at any time.
If you opt out of receiving marketing communications this
opt-out does not apply to personal data provided as a result of
other transactions, such as purchases, warranty registrations
etc.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out
below:
Service providers who provide IT and system administration
services.
Government bodies that require us to report processing
activities.
Third parties to whom we sell, transfer, or merge parts of our
business or our assets.
We require all third parties to whom we transfer your data to
respect the security of your personal data and to treat it in
accordance with the law. We only allow such third parties to
process your personal data for specified purposes and in
accordance with our instructions.
6. DATA SECURITY
We have put in place security measures to prevent your personal
data from being accidentally lost, used, altered, disclosed, or
accessed without authorisation. We also allow access to your
personal data only to those employees and partners who have a
business need to know such data. They will only process your
personal data on our instructions and they must keep it
confidential.
We have procedures in place to deal with any suspected personal
data breach and will notify you and any applicable regulator of
a breach if we are legally required to.
7. DATA RETENTION
We will only retain your personal data for as long as necessary
to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, accounting, or reporting
requirements.
When deciding what the correct time is to keep the data for we
look at its amount, nature and sensitivity, potential risk of
harm from unauthorised use or disclosure, the processing
purposes, if these can be achieved by other means and legal
requirements.
For tax purposes the law requires us to keep basic information
about our customers (including Contact, Identity, Financial and
Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for
research or statistical purposes in which case we may use this
information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS UNDER GDPR
If You are a citizen or a resident of a country in the European
Union, the GDPR grants You the following rights:
a. Access to Your Personal Data.
You have the right to receive a copy of Your personal data that is
subject to processing by us. Ordinary requests will be granted
without charge to You within one calendar month of when You make the
request. In cases of excessive, unreasonable, or repeated requests
we may charge You a reasonable fee and may require additional time
to grant Your request. Also, we may use reasonable means to confirm
Your identity before granting any request for data so as to prevent
granting fraudulent requests. To request a copy of Your personal
data, please contact us by e-mail at support@passive.com.
b. To have Your Data Corrected.
If Your personal data is erroneous or outdated, You have the right
to have it corrected. To do so, please contact us via e-mail at
support@passive.com, or simply click on the modify your details link
on our emails sent to You.
c. To be Forgotten.
You have the right to be forgotten by us. You may exercise this
right by e-mailing us at support@passive.com. We will comply with
Your request, at no charge to You, within one calendar month by
deleting Your data. We may use reasonable means to confirm Your
identity before granting any request for data so as to prevent the
granting of fraudulent requests.
d. To Restrict Processing of Your Data.
You can request that Your data not be processed via our partners.
You can make that request by e-mailing us at support@passive.com.
and, if you wish, you can even specify which third parties to
restrict from processing Your data. We will respond to Your request,
at no charge to You, within thirty (30) days from when You make Your
request. Please be advised that some of our partners are essential
to our services, so that if You block processing by them, our
services may be unavailable to You.
e. Portability.
You have the right to receive a copy of Your personal data that is
subject to processing by us in a portable format, or to have it
transferred directly from us to another party. Ordinary requests
will be granted without charge to You within one calendar month of
when You make the request. We may use reasonable means to confirm
Your identity before granting any request to transfer data to You or
another party so as to prevent granting fraudulent requests. To
request a copy of Your personal data in a portable format, or to
request a direct transfer of Your data, please contact us by e-mail
at support@passive.com.
You will not have to pay a fee to access your personal data (or to
exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or
excessive or refuse to comply with your request in these
circumstances.
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal
data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our
response.
We try to respond to all legitimate requests within one month.
Occasionally it may take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you.
If you are not happy with any aspect of how we collect and use your
data, you have the right to complain to the Information
Commissioner’s Office (ICO), the UK supervisory authority for data
protection issues (ico.org.uk). We should be grateful if you would
contact us first if you do have a complaint so that we can try to
resolve it for you.
9. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for
their privacy statements. When you leave our website, we encourage
you to read the privacy notice of every website you visit.
10. COOKIES
You can set your browser to refuse all or some browser cookies, or
to alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of this website may
become inaccessible or not function properly. For more information
about the cookies we use, please see our Cookie Policy below.
What Is A Cookie?
- A "cookie" is a
piece of information that is stored on your
computer's hard drive and which records how you move
your way around a website so that, when you revisit
that website, it can present tailored options based
on the information stored about your last visit.
Cookies can also be used to analyse traffic and for
advertising and marketing purposes.
- Cookies are used by
nearly all websites and do not harm your system.
If you want to check or change what types of cookies
you accept, this can usually be altered within your
browser settings. You can block cookies at any time
by activating the setting on your browser that
allows you to refuse the setting of all or some
cookies. However, if you use your browser settings
to block all cookies (including essential cookies)
you may not be able to access all or parts of our
site.
How Do We Use Cookies?
- We use cookies to
track your use of our website. This enables us to
understand how you use the site and track any
patterns with regards how you are using our website.
This helps us to develop and improve our website as
well as products and / or services in response to
what you might need or want.
- Cookies are either:
- Session cookies:
these are only stored on your computer during your
web session and are automatically deleted when you
close your browser – they usually store an anonymous
session ID allowing you to browse a website without
having to log in to each page but they do not
collect any personal data from your computer; or
- Persistent cookies:
a persistent cookie is stored as a file on your
computer and it remains there when you close your
web browser. The cookie can be read by the website
that created it when you visit that website again.
Cookies can also be
categorised as follows:
- Strictly necessary
cookies: These cookies are essential to enable you
to use the website effectively, such as when buying
a product and / or service, and therefore cannot be
turned off. Without these cookies, the services
available to you on our website cannot be provided.
These cookies do not gather information about you
that could be used for marketing or remembering
where you have been on the internet.
- Performance cookies:
These cookies enable us to monitor and improve the
performance of our website. For example, they allow
us to count visits, identify traffic sources and see
which parts of the site are most popular.
- Functionality
cookies: These cookies allow our website to remember
choices you make and provide enhanced features. For
instance, we may be able to provide you with news or
updates relevant to the services you use. They may
also be used to provide services you have requested
such as viewing a video or commenting on a blog. The
information these cookies collect is usually
anonymised.
[Please note that third
parties who advertise on our website (including, for
example, advertising networks and providers of external
services like web traffic analysis services) may also
use cookies, over which we have no control. These
cookies are likely to be analytical/performance cookies
or targeting cookies] |
Privacy And Cookie Policy
/ 24 May 2018 / V1.0
Internet Marketer Pte Ltd |