Privacy and Cookies
-
Privacy and Cookies
- This is the privacy and cookies policy
of Ask Experts Anything (“AEA”) and its affiliated organisation(s)
as listed on
https://www.www.askexpertsanything.com/
.
(each an “affiliated organisation”). The terms “we”, “us”
and “our” in this Policy refer to Ask Experts Anything, and/or any
affiliated organisation(s) which has adopted this Policy, as
appropriate.
- Application.
AEA and each affiliated organisation have different channels of
collecting personal data, but each is committed to complying with
this Policy in its collection, use and disclosure of personal data,
to ensure that there is accountability and uniformity in the way we
protect your personal data. Although this Policy is in common use by
AEA and the affiliated organisations, each is responsible to you to
the extent of its own collection, use and disclosure of your personal
data, and its own actions.
- Compliance
with this Policy. This Policy
applies to all personal data you provide to us, or that we may
collect about you. If you do not accept this Policy, please do not
provide any personal data to us.
We may also require you to accept this
Policy when you contact, interact, transact or deal with us, or when
you access and use our website, applications or services. If you
notify us that you do not accept this Policy, we may not be able to
establish a relationship with you or be able to service your
requests.
In
recognition of our operations beyond Singapore, to places such as the
European Union (the “EU”), United States or the United Kingdom,
we have been especially keen to ensure that this Policy takes account
of the relevant data protection principles operating overseas. In
particular we have measured and modelled this Policy against the high
standards of protection for personal data as contained and promoted
in the EU’s benchmark General Data Protection Regulation (EU)
2016/679 (the “GDPR”).
- Contacting
Us. You may contact our Data
Protection Officer if you have any feedback or enquiries in relation
to your personal data or about this Policy, or wish to make any
request, in the following manner:
Data Protection Officer
Email address:
dpo@xprenia.com
- Governing
Law and Dispute Resolution.
Irrespective of the country from which you access or use our site,
products or services, to the extent permitted by law, this Policy
shall be governed in accordance with the laws of Singapore without
regard to choice or conflicts of law principles, and you hereby agree
to submit to the exclusive jurisdiction of the courts of Singapore to
resolve any claims or disputes which may arise in connection with
this Policy. Any
disputes concerning this Policy and claims concerning breach or
inadequacy of Personal Data protection raised by an EU Individual
will be dealt with in accordance (to the maximum permissible extent)
with the GDPR.
- Effect
of this Policy and Changes to this Policy.
This Policy applies in conjunction with any other policies,
contractual clauses and consent clauses that apply in relation to the
collection, use and disclosure of your personal data by us. We may
revise this Policy from time to time without any prior notice, to
comply with applicable laws or as we update our data usage and
handling processes. The updated Policy will supersede earlier
versions and will apply to personal data provided to us previously.
You may determine if any such revision has taken place by referring
to the date on which this Notice was last updated. Your continued use
of our website, application and products/services constitutes your
acknowledgement and acceptance of such changes.
-
Personal Data
- What
Personal Data We Collect. The
personal data we collect depends on the purposes for which we require
the personal data and what you have chosen to provide. This may
include your name, address, contact information (for example,
telephone number and email address), identification number,
photograph, video image and any other information that may identify
you or is personal to you.
- How
We Collect Personal Data. We
collect personal data pertinent to our relationship with you. We may
collect your personal data directly or indirectly through various
channels, including when:
- you use our services or enter into
transactions with us (or express interest in doing so);
- you apply to be a member of any of
our programs, respond to our promotions, or subscribe to our mailing
lists;
- you visit our website, download or
use our mobile applications;
- you register an account with us
through our website or applications;
- you transact with us, contact us or
request that we contact you through various communication channels,
for example, through social media platforms, messenger platforms,
face-to-face meetings, telephone calls and emails;
- we seek information about you and
receive your personal data in connection with your relationship with
us, for example, if you are a customer, investor or shareholder; or
-
you submit your personal data to us
for any other reason.
Depending on your relationship with us, we may also collect your personal data from third
parties, including:
- from Xprenia (see https://www.xprenia.com/)
and any affiliated organisations;
- from your family members or friends
who provide your personal data to us on your behalf; and
- from public agencies or other
public sources.
Our website and applications may also
contain or involve certain technologies that automate the collection
of data (including personal data). These technologies include
cookies, web beacons and web analytics. If you do not wish to have
your data collected through such technologies you may disable the
operation of these technologies on your devices (where possible), or
you may refrain from using our website and applications.
- Voluntary
Provision of Personal Data.
Your provision of personal data to us is voluntary and you have the
right to withdraw your consent for us to use your personal data at
any time by submitting a request to us. Your withdrawal will take
effect after your request is processed. However, if you choose not to
provide us with the personal data we require, it may not be possible
for us to fulfil the purposes for which we require the personal data,
including providing products and services which you need from us.
- Providing
Personal Data Belonging to Others.
In certain circumstances, you may also provide the personal data of
persons other than yourself (including your family members). If you
do so, you are responsible for informing him/her of the purposes for
which we require his/her personal data and warrant that you are
validly acting on behalf of him/her to consent to our collection, use
and disclosure of his/her personal data.
- Accuracy
and Completeness of Personal Data.
We generally rely on personal data provided by you (or your
authorised representative). In order to ensure that all personal data
that you provide is current, true, accurate and complete, please
promptly update us of any changes to the personal data by informing
us via email (refer to paragraph 1.4 above for contact details).
- Minor.
If you are a child, minor or not of legal age, please inform and seek
the consent of your parent or guardian, before you provide your
personal data to us. If you are a parent or guardian and you have
reason to believe your child or ward has provided us with their
personal data without your consent, please contact us to request for
erasure of their personal data (refer to paragraph 1.4 above for
contact details).
-
Purposes
-
We collect, use and disclose your
personal data where:
- you have given us consent;
- necessary to comply with our legal
or regulatory obligations;
- necessary for our business
interests, provided that this does not override your interests or
rights; and/or
- necessary to perform a contract or
transaction you have entered into with us, or provide a service that
you have requested or required from us.
-
General
Purposes.Generally, we
collect, use and disclose your personal data for purposes connected
or relevant to our business, including:
- processing your transactions with us,
or to provide products and services to you;
- managing your relationship with us;
- facilitating your use of our
platforms, products and services;
- assisting you with your requests,
enquiries and feedback;
- administrative purposes, g.
accounting, risk management and record keeping, business research,
data, planning and statistical analysis, and staff training;
- security and safety purposes, g.
protecting our platforms from unauthorised access or usage and to
monitor for security threats, and your image may be captured by
security cameras;
- carrying out research, data and
statistical analysis;
- compliance with laws and
regulations, internal policies and procedures, e.g. audit,
accounting, risk management and record keeping;
- enforcing legal obligations owed to
us, or responding to complaints, litigation or investigations
concerning us;
- managing and engaging third parties or
data processors that provide services to us, e.g. IT services, data
analytics, marketing, and other professional services;
- such purposes that may be informed to
you when your personal data is collected;
- carrying out our legitimate business
interests (listed below); and/or
- any other reasonable purposes
related to the aforesaid
- Marketing
Purposes. Where you give us
consent, we collect, use and disclose your personal data for purposes
of:
- managing and/or administering your
request to receive news (including events and product launches),
promotions and marketing information from us (and/or our affiliates
or related entities) and on our products/services;
- analysing and/or profiling your
purchases, transactions and/or likes or dislikes so as to be better
able to send you relevant or targeted news (including events and
product launches), promotion and marketing information from us
(and/or our affiliates or related entities) and on our
products/services; and/or
- sending you news (including events
and product launches) and promotions from us (and/or our affiliates
or related entities) as well as marketing information from us (and/or
our affiliates or related entities) and on our products/services.
- Business.
Our business interests include:
- managing our business and
relationship with you, and providing services to our users and
customers;
- protecting our rights and interests
and those of our users and customers;
- preventing and investigating
possible misuse of our website, applications and services;
- understanding and responding to
inquiries and feedback;
- understanding how our users use our
website, applications and services;
- identifying what our users want and
improving our website, applications, services and offerings;
- enforcing obligations owed to us,
or protecting ourselves from legal liability; and
- sharing data in connection with
acquisitions and transfers of our business.
- Purposes
involving Xprenia Pte Ltd and any Affiliated
Organisations. Ask Experts Anything
has responsibility for Xprenia Pte Ltd as well as any
affiliated organisations. For administrative efficiencies and to
allow Ask Experts Anything to better serve your needs, your personal data
will also be collected, used and disclosed to Xprenia Pte Ltd
and any affiliated organisations for the following purposes:
- facilitating the provision of
centralised administrative and management services;
- facilitating use of centralised
resources e.g. shared information technology resources and systems;
- facilitating internal audits,
reporting and management of our operations; and/or
- facilitating the conduct of
centralised business activities and functions e.g. data analytics.
- The purposes listed in paragraphs
3.2, 3.3, 3.4 and 3.5 may continue to apply even in situations where
your relationship with us (for example, pursuant to a contract) has
been terminated or altered in any way, for a reasonable period
thereafter (including, where applicable, a period to enable us to
enforce our rights under any contract with you).
- Use
Permitted Under Applicable Laws. We
may also collect, use, disclose and process your personal data for
other purposes, without your knowledge or consent, where this is
required or permitted by law.
- Contacting
You. When using your personal
data to contact you for the above purposes, we may contact you via
mail, e-mail, SMS, telephone, pop-up notifications (when you are
using our applications), or any other means.
We will not contact you for marketing
purposes unless with your consent, or we are exempted by applicable
law from having to obtain consent. When contacting you for marketing
purposes, we will not contact you through your telephone number,
unless you have specifically consented to such a mode of
communication. If you do not wish to receive any communication or
information from us, or wish to restrict the manner by which we may
contact or send you information, you may contact us to do so.
-
Disclosure of Personal Data
-
Disclosure
to Xprenia Pte Ltd and any Affiliated Organisations.
We may disclose or share your personal data with BlackStorm
Consulting Pte Ltd and any affiliated organisations for the purposes
described in paragraph 3.2, 3.3, 3.4 and 3.5.
- Other
Disclosures. We may also
disclose or share your personal data in connection with the purposes
described in paragraphs 3.2, 3.3 and 3.4:
- where such disclosure is required for
performing obligations in the course of or in connection with our
provision of the goods or services requested by you; or
- to third party service providers,
agents, regulatory authorities and other organisations we have
engaged.
When disclosing personal data to third
parties, we will (where appropriate and required by applicable law)
enter into contracts with these third parties to protect your
personal data in a manner that is consistent with applicable laws
and/or ensure that they only process your personal data in accordance
with our instructions.
-
Transfers of Personal Data Out of Singapore
-
We may transfer your personal data
out of Singapore for the purposes set out in paragraph 3. When
transferring personal data outside Singapore, we will require
recipients of the personal data to protect personal data at a
standard comparable to that under the laws of Singapore. For example,
we may enter into legally enforceable agreements with the recipients
to ensure that they protect your personal data.
-
Protection of Personal Data
-
Retention
of Personal Data. We may retain
your personal data for as long as it is necessary to fulfil the
purposes for which it was collected, to satisfy our business and
legal purposes, or as required or permitted by applicable laws. How
long we keep your personal data depends on the nature of the data.
Certain information may also be retained for longer where we are
required to do so by law. We will cease to retain your personal data,
or remove the means by which the data can be associated with you, as
soon as it is reasonable to assume that such retention no longer
serves the purpose for which the personal data was collected, and is
no longer necessary for legal or business purposes.
-
Anonymised
Data. In some circumstances we
may anonymise your personal data so that it no longer identifies you,
in which case we are entitled to retain and use such anonymised data
without restriction, including for data analytics.
-
Unauthorised
Access and Vulnerabilities. While
we take reasonable precautions to safeguard your personal data in our
possession or under our control, we cannot be held responsible for
unauthorised or unintended access that is beyond our control,
including hacking or cybercrimes. We also do not guarantee that our
website and applications are invulnerable to security breaches, or
that your use of our website and applications is safe and protected
from viruses, worms, Trojan horses, and other vulnerabilities. While
security cannot be guaranteed, we strive to protect the security of
your information and are constantly reviewing and enhancing our
information security measures.
-
Links to Third Party Websites
- When clicking on a link within a book-a-session step or in a book-a-session email,
you may be taken to a third party website,
the use of which has been arranged by and is the responsibility of the third-party organisation.
- On this website, you may be asked to
submit some information about yourself. Please make sure you are
familiar with the terms and conditions and privacy policy of the
third party website before submitting your information.
- The third party entity will only use
your personal information for the purpose stated in the course and in
accordance with the terms of the third party website.
- Whether you follow a link in a listing
and submit your personal information or not, your booking session progress
will in no way be affected. Nor will your Ask Experts Anything profile.
-
Use of Cookies and Similar Technologies
- Cookies.
Our website uses cookies to
enhance your experience of Ask Experts Anything and to better understand
how people use our website. This may also include cookies from third
party websites. Cookies are small files containing small amounts of
information which are automatically downloaded into your computer (or
other electronic devices) when you access the sites. Cookies help us
to measure the number of visits, average time spent, page views and
other statistics relating to your access to our website. This
information allows us to better administer our website, and provide a
more tailored and user-friendly service to our users. Cookies also
enable you to use or access certain features or services of our
website. Each time you visit our website from the same computer or
device, the cookie will be retrieved from your computer or device,
enabling our website to recognise your computer or device as having
previously visited our website and thereby increase the functionality
of our website on your computer or device. Therefore, generally, we
use cookies on to:
- recognise your browser as a previous
visitor and save any preferences that may have been set during your
last visit to our website;
- obtain information about your
preferences, online movements and use of the Internet;
- track website analytics and carry
out research and statistical analysis to help improve our content,
products and services and to help us better understand our visitors’
or customers’ requirements and interests;
- customise and target our marketing
and advertising campaigns and those of our partners more effectively
by providing personalised interest-based advertisements;
- measure and research the effectiveness
of our interactive online content, features, advertisements, and
other communications;
- make your online experience more
efficient and enjoyable.
- The information we obtain from our use
of cookies will not usually contain your personal data. Although we
may obtain information about your computer or other electronic
devices such as your IP address, your browser and/or other internet
log information, this will not usually identify you personally. In
certain circumstances, we may collect personal information about you
but only where you voluntarily provide it or where you subscribe to
our services through our website. The information we obtain through
the use of cookies may be combined with other personal data relating
to you. In most cases, we will obtain your consent in order to use
cookies on our website. The exception is where the cookies are
strictly necessary in order for us to operate our website and/or to
provide you with a service you have requested. Most web browsers and
devices can be set to notify you when you receive a cookie or to
prevent cookies from being sent. If you use these features, you may
limit the functionalities we can provide you when you visit our
website. You are free to block, delete, or disable the cookies if
your device permits so. You can manage your cookies and your cookie
preferences in your browser or device settings. If you have recently
disabled one or more cookies, we will stop using the disabled cookies
to collect any further information. However, we may still use
information collected from such cookies prior to your selecting the
‘disable’ preference setting. If you will like to opt-out of all
other types of technologies we employ on our website, you may do so
by changing your browser settings to block, delete or disable these
technologies as your browser or device permits.
- Third
Party Cookies. Third party
cookies are set by a third party site separate from our website. We
have no control over the cookies used by the third parties. For
further information on how the third parties use cookies, please
refer to the cookies policies on their respective websites.
- Managing
Cookies.
Most
web browsers allow some control of most cookies through the browser
settings. To find out more about cookies, including how to see what
cookies have been set, visit
www.aboutcookies.org
.
or
www.allaboutcookies.org
Find out how to
manage cookies on popular browsers:
Google
Chrome
Microsoft
Edge
Mozilla
Firefox
Microsoft
Internet Explorer
Apple
Safari
To find information
relating to other browsers, visit the browser developer’s website.
To opt out of being
tracked by Google Analytics across all websites, visit
http://tools.google.com/dlpage/gaoptout
.
-
Your Rights
- Withdrawal
of Consent. The consent that
you provide for the collection, use and disclosure of your personal
data will remain valid until such time it is being withdrawn by you
in writing. You may withdraw consent and request us to stop using
and/or disclosing your personal data for any or all of the purposes
listed above by submitting your request in writing and email to our
Data Protection Officer (refer to paragraph 1.4 above for contact
details). Upon receipt of your written request to withdraw your
consent, we may require reasonable time (depending on the complexity
of the request and its impact on our relationship with you) for your
request to be processed and for us to notify you of the consequences
of us acceding to the same, including any legal consequences which
may affect your rights and liabilities to us. In general, we shall
seek to process your request within fourteen (14) days of receiving
it. While we respect your decision to withdraw your consent, please
note that depending on the nature and scope of your request, we may
not be in a position to continue providing our goods or services to
you and we shall, in such circumstances, notify you before completing
the processing of your request. Should you decide to cancel your
withdrawal of consent, please inform us in writing and email to our
Data Protection Officer (see paragraph 1.4 above for contact
details). Please note that withdrawing consent does not affect our
right to continue to collect, use and disclose personal data where
such collection, use and disclose without consent is permitted or
required under applicable laws. If
you are located in the EU, we will seek and rely on your consent as a
legal basis for using your personal data
where
we have expressly sought it for specific purpose(s). You will be
asked to provide clear and affirmative consent to the collection,
processing and use of your personal data. If we do rely on your
consent to a use of your personal data, you have the right to change
your mind at any time (but this will not affect any processing that
has already taken place).
- Access
to and Correction of Personal Data.
If you wish to make (A) a request for access to a copy of the
personal data which we hold about you or information about the ways
in which we use or disclose your personal data, or (B) a request to
correct or update any of your personal data which we hold about you,
you may submit your request in writing and email to our Data
Protection Officer (refer to paragraph 1.4 above for contact
details). Where permitted by law, we may charge you a fee to process
your access request. If so, we will inform you of the fee before
processing your request. We will respond to your request as soon as
reasonably possible. Should we not be able to respond to your request
within thirty (30) days after receiving your request, we will inform
you in writing within thirty (30) days of the time by which we will
be able to respond to your request. If we are unable to provide you
with any personal data or to make a correction requested by you, we
shall generally inform you of the reasons why we are unable to do so
(except where we are not required to do so under the PDPA). We may
also be permitted under applicable laws to refuse a request.
- Limitations.
We may be permitted under
applicable laws to refuse your request to exercise your rights, for
example, we may refuse (A) a request for erasure where the personal
data is required for in connection with claims, or (B) an objection
request and continue processing your personal data based on
compelling legitimate grounds for the processing.
Effective date: 28 September 2022
Last updated: 28 September 2022
