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Privacy Policy

Effective Date: 01 August 2024

Published on: 01 August 2024

“This Privacy Policy (“Policy”) outlines how Siara Tech Solutions Pte. Ltd. and its affiliates (“Siara”, “we”, “us”, “our”) handle and process the personal data we collect from you.”‍

DEFINITIONS
  1. “Affiliate” means any person or entity that directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with a specified person or entity.
  2. “Data Intermediary” means an organization that processes Personal Data on behalf of another organization, excluding employees of that organization.
  3. “End-User” means any individual or entity with whom the Subscriber interacts while using the Service(s).
  4. “Personal Data” means any information, whether true or not, relating to an individual who can be identified from that information alone or in combination with other information to which the organization has or is likely to have access.
  5. “Process” or “Processing” means any operation or set of operations performed on Personal Data, whether automated or not, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, making available, alignment, combination, restriction, erasure, or destruction.
  6. “Service(s)” shall have the meaning assigned to it under the Terms.
  7. “Subscriber” means the natural or legal person who subscribes to the Service(s) by agreeing to the Terms.
  8. “Terms” means the binding agreement between Siara and you governing access to and use of the Service(s), available at Terms & Conditions .
  9. “Website(s)” means the websites operated by Siara.
  10. “You” and “Your” refer to an identified or identifiable natural person whose Personal Data is processed by Siara.
HOW YOUR DATA IS COLLECTED?
  1. Direct Collection. Siara collects most of your Personal Data directly from you when you:
    • Subscribe to any of Siara’s Service(s) by agreeing to the Terms;
    • Use or view Siara’s Website(s), including through cookies stored in your browser;
    • Submit web forms on our Website(s) or interact with the Website(s) through features such as participating in surveys, contests, promotions, sweepstakes, requesting customer support, or other communications with us; and
    • Download and use the Service(s), during which Siara automatically collects information about the type of device you use and its operating system version in order to fulfill our agreement with you.
  2. Indirect Collection. Siara may also receive your Personal Data indirectly in the following ways:
    • From third-party sources, including databases and social media platforms, but only where we have verified that such third parties have obtained your consent or are otherwise legally permitted or required to disclose your Personal Data to us; and
    • Where you authorize Siara to connect with a third-party service, Siara may access and store your name, email address(es), current city, profile picture URL, and other Personal Data made available by such third-party service. This information will be used and disclosed in accordance with this Privacy Policy.
PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED
  1. To facilitate your access to the Website(s) and Service(s).
  2. To process and complete payment transactions.
  3. To provide customer service and support.
  4. To communicate with you regarding your use of the Service(s), including updates to our Terms or other policies.
  5. To inform you about new features in the Service(s) or new service offerings.
  6. To conduct research, analysis, and development activities (including, but not limited to, data analytics, surveys, and profiling) aimed at improving our Service(s) and facilities, enhancing your relationship with us, or benefiting you by improving any of our Service(s).
  7. To organize seminars, events, or other marketing and promotional activities.
  8. To investigate and prevent fraudulent transactions, unauthorized access to the Website(s) and Service(s), and other illegal activities.
  9. To personalize your experience with the Website(s) and Service(s).
  10. For other purposes for which Siara obtains your consent.
SHARING OF PERSONAL DATA
  1. You acknowledge and agree that Siara may share your Personal Data with its group companies and third-party service providers, including providers such as SendGrid and Twilio, in order to offer you Siara’s Service(s) and/or to send you information or updates related to the Service(s) where you are a Subscriber.
  2. In processing your order as a Subscriber, Siara may transmit your Personal Data to, and use information obtained from, credit reference agencies for the purpose of preventing fraudulent transactions.
  3. Siara may share your Personal Data with third-party service providers that host, maintain, and support Siara’s Website(s), applications, backup services, storage solutions, payment processing, analytics, and other related services. Such third-party service providers may access or process your Personal Data solely for the purpose of providing these services to Siara.
  4. Siara may disclose your Personal Data to third-party providers who assist in conducting marketing and promotional activities on our behalf.
  5. Siara may be required to disclose your Personal Data in response to: (a) lawful requests by public authorities, including to meet national security or law enforcement requirements; and/or (b) subpoenas, court orders, legal processes, or to establish, exercise, or defend Siara’s legal rights.
  6. Siara may also share your Personal Data to assist in the investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any individual, violations of Siara’s Terms, or as otherwise required by law.
INTERNATIONAL TRANSFER
  1. Siara primarily processes Personal Data in Singapore. However, Personal Data may be transferred outside Singapore for the purposes outlined in Section 4. Siara will ensure that any recipient of your Personal Data provides a level of protection that is at least equivalent to the protection offered under applicable data protection laws.
RETENTION OF PERSONAL DATA
  1. Siara retains Personal Data for as long as there is an ongoing legitimate business need to do so.
  2. Where there is no longer a need to retain Personal Data as described in Section 6.1, Siara will either delete or aggregate such data. If deletion or aggregation is not possible, Siara will securely store your Personal Data and isolate it from further processing until deletion becomes possible.
SECURITY OF PERSONAL DATA
  1. Siara implements appropriate technical and organizational measures to protect the Personal Data it collects and processes. These measures are designed to provide a level of security suitable to the risks involved in processing your Personal Data. If you have any questions about the security of your Personal Data, please contact us as described in this Privacy Policy.
YOUR RIGHTS
You are entitled to the following rights:
  1. Access, Correction, and Deletion. You have the right to request access to, correction of, or deletion of your Personal Data. If you wish to request a copy of the Personal Data we hold about you, seek information on how we use or disclose your Personal Data, or request a correction or update, you may submit your request in writing or via email to our Data Protection Officer using the contact details provided below.
    • Please note that a reasonable fee may be charged for an access request. If applicable, we will inform you of the fee before processing your request.
    • We will respond to your request as soon as reasonably possible, generally within thirty (30) business days. If we are unable to respond within this timeframe, we will notify you in writing within thirty (30) days, indicating when you can expect a response. If we cannot provide you with the requested data or make the requested correction, we will generally explain why, unless we are not required to do so under applicable law.
  2. Opt-Out of Marketing Communications. You have the right to opt out of receiving marketing communications from Siara at any time. You may do so by clicking the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing, such as postal mail or telemarketing, please contact us directly.
  3. Withdrawal of Consent. You may withdraw your consent at any time. Please note, however, that withdrawing consent does not affect our right to continue collecting, using, and disclosing Personal Data where such activities are permitted or required by applicable laws without consent.
NOTICE TO END-USERS AND OTHER EXCLUSIONS
  1. Siara’s Service(s) are designed for enterprise use. Siara is not responsible for the privacy or security practices of its Subscribers, which may differ from this Privacy Policy. Subscribers of the Service(s) are solely responsible for creating their own privacy policies and ensuring compliance with all applicable laws, regulations, privacy policies, agreements, and other obligations related to the collection of Personal Data through the use of the Service(s) by End-Users. Siara processes the Personal Data of End-Users on behalf of Subscribers as a Data Intermediary. If you are an individual interacting with a Subscriber through the Service(s), please contact the Subscriber directly for any inquiries or requests regarding your Personal Data.
  2. Siara’s Website(s) may contain links to other websites. This Privacy Policy applies only to Siara’s Website(s). If you click on a link to another website, please review that website’s privacy policy. Siara encourages you to understand the Personal Data practices of any linked websites by reviewing their respective privacy statements.
  3. This Privacy Policy does not apply to aggregated information, which provides statistical summaries about groups of users and does not include names, contact details, or any other information that could identify an individual.
DATA PROTECTION AND PRIVACY CLAUSE
  1. Data Collection and Use. Siara is committed to safeguarding individual privacy and ensuring that Personal Data is processed in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), Singapore’s Personal Data Protection Act (PDPA), Malaysia’s Personal Data Protection Act (PDPA), and applicable U.S. federal and state laws. Personal Data collected by Siara will be:
    • Processed lawfully, fairly, and transparently;
    • Collected for specified, explicit, and legitimate purposes, and not further processed in ways that are incompatible with those purposes;
    • Adequate, relevant, and limited to what is necessary for the purposes for which it is processed;
    • Accurate and, where necessary, kept up to date;
    • Retained only for as long as necessary for the purposes for which the data was collected; and
    • Processed securely, with appropriate technical or organizational measures to protect against unauthorized or unlawful processing, accidental loss, destruction, or damage.
  2. Consent. Where required by applicable law, Siara will obtain the necessary consent from individuals before collecting or processing their Personal Data. Individuals have the right to withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  3. Data Subject Rights. Siara respects the rights of individuals to access, correct, delete, or restrict the processing of their Personal Data. Individuals may also exercise their right to data portability and object to the processing of their Personal Data under certain circumstances. Siara will facilitate the exercise of these rights in compliance with applicable data protection laws.
  4. International Data Transfers. Siara ensures that any cross-border transfer of Personal Data complies with applicable data protection laws. Where Personal Data is transferred outside the European Economic Area (EEA), Siara will implement appropriate safeguards, such as Standard Contractual Clauses (SCCs), to ensure the data is protected in accordance with the GDPR or other relevant legal frameworks.
  5. Data Security. Siara employs appropriate technical and organizational measures to protect Personal Data from unauthorized access, alteration, disclosure, or destruction. These measures are regularly reviewed and updated to maintain the ongoing security of Personal Data.
  6. Data Retention. Personal Data will be retained only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations. Siara will securely delete or anonymize Personal Data that is no longer required.
  7. Data Breach Notification. In the event of a Personal Data breach, Siara will notify the relevant supervisory authorities and affected individuals, as required by law. Siara will take immediate steps to mitigate the impact of the breach and prevent future occurrences.
  8. Compliance and Accountability. Siara is committed to complying with all applicable data protection laws and will regularly review and update its data protection practices. Siara will maintain appropriate records of data processing activities and will demonstrate compliance with its data protection obligations.
CONTACT INFORMATION
  1. For any inquiries, feedback, or requests regarding our Personal Data protection policies and procedures, please contact our Data Protection Officer using the details below:
CHANGES TO THE POLICY
  1. Siara regularly reviews this Privacy Policy and may update it from time to time. Amendments to this Privacy Policy may be made at any time. You will be notified of such changes only where the updates are considered significant, in accordance with applicable laws.

Contents

Privacy Policy

Effective Date: 01 August 2024

Published on: 01 August 2024

“This Privacy Policy (“Policy”) outlines how Siara Tech Solutions Pte. Ltd. and its affiliates (“Siara”, “we”, “us”, “our”) handle and process the personal data we collect from you.”‍

DEFINITIONS
  1. “Affiliate” means any person or entity that directly or indirectly, through one or more intermediaries, controls, is controlled by, or is under common control with a specified person or entity.
  2. “Data Intermediary” means an organization that processes Personal Data on behalf of another organization, excluding employees of that organization.
  3. “End-User” means any individual or entity with whom the Subscriber interacts while using the Service(s).
  4. “Personal Data” means any information, whether true or not, relating to an individual who can be identified from that information alone or in combination with other information to which the organization has or is likely to have access.
  5. “Process” or “Processing” means any operation or set of operations performed on Personal Data, whether automated or not, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, making available, alignment, combination, restriction, erasure, or destruction.
  6. “Service(s)” shall have the meaning assigned to it under the Terms.
  7. “Subscriber” means the natural or legal person who subscribes to the Service(s) by agreeing to the Terms.
  8. “Terms” means the binding agreement between Siara and you governing access to and use of the Service(s), available at Terms & Conditions .
  9. “Website(s)” means the websites operated by Siara.
  10. “You” and “Your” refer to an identified or identifiable natural person whose Personal Data is processed by Siara.
HOW YOUR DATA IS COLLECTED?
  1. Direct Collection. Siara collects most of your Personal Data directly from you when you:
    • Subscribe to any of Siara’s Service(s) by agreeing to the Terms;
    • Use or view Siara’s Website(s), including through cookies stored in your browser;
    • Submit web forms on our Website(s) or interact with the Website(s) through features such as participating in surveys, contests, promotions, sweepstakes, requesting customer support, or other communications with us; and
    • Download and use the Service(s), during which Siara automatically collects information about the type of device you use and its operating system version in order to fulfill our agreement with you.
  2. Indirect Collection. Siara may also receive your Personal Data indirectly in the following ways:
    • From third-party sources, including databases and social media platforms, but only where we have verified that such third parties have obtained your consent or are otherwise legally permitted or required to disclose your Personal Data to us; and
    • Where you authorize Siara to connect with a third-party service, Siara may access and store your name, email address(es), current city, profile picture URL, and other Personal Data made available by such third-party service. This information will be used and disclosed in accordance with this Privacy Policy.
PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED
  1. To facilitate your access to the Website(s) and Service(s).
  2. To process and complete payment transactions.
  3. To provide customer service and support.
  4. To communicate with you regarding your use of the Service(s), including updates to our Terms or other policies.
  5. To inform you about new features in the Service(s) or new service offerings.
  6. To conduct research, analysis, and development activities (including, but not limited to, data analytics, surveys, and profiling) aimed at improving our Service(s) and facilities, enhancing your relationship with us, or benefiting you by improving any of our Service(s).
  7. To organize seminars, events, or other marketing and promotional activities.
  8. To investigate and prevent fraudulent transactions, unauthorized access to the Website(s) and Service(s), and other illegal activities.
  9. To personalize your experience with the Website(s) and Service(s).
  10. For other purposes for which Siara obtains your consent.
SHARING OF PERSONAL DATA
  1. You acknowledge and agree that Siara may share your Personal Data with its group companies and third-party service providers, including providers such as SendGrid and Twilio, in order to offer you Siara’s Service(s) and/or to send you information or updates related to the Service(s) where you are a Subscriber.
  2. In processing your order as a Subscriber, Siara may transmit your Personal Data to, and use information obtained from, credit reference agencies for the purpose of preventing fraudulent transactions.
  3. Siara may share your Personal Data with third-party service providers that host, maintain, and support Siara’s Website(s), applications, backup services, storage solutions, payment processing, analytics, and other related services. Such third-party service providers may access or process your Personal Data solely for the purpose of providing these services to Siara.
  4. Siara may disclose your Personal Data to third-party providers who assist in conducting marketing and promotional activities on our behalf.
  5. Siara may be required to disclose your Personal Data in response to: (a) lawful requests by public authorities, including to meet national security or law enforcement requirements; and/or (b) subpoenas, court orders, legal processes, or to establish, exercise, or defend Siara’s legal rights.
  6. Siara may also share your Personal Data to assist in the investigation and prevention of illegal activities, suspected fraud, situations involving potential threats to the physical safety of any individual, violations of Siara’s Terms, or as otherwise required by law.
INTERNATIONAL TRANSFER
  1. Siara primarily processes Personal Data in Singapore. However, Personal Data may be transferred outside Singapore for the purposes outlined in Section 4. Siara will ensure that any recipient of your Personal Data provides a level of protection that is at least equivalent to the protection offered under applicable data protection laws.
RETENTION OF PERSONAL DATA
  1. Siara retains Personal Data for as long as there is an ongoing legitimate business need to do so.
  2. Where there is no longer a need to retain Personal Data as described in Section 6.1, Siara will either delete or aggregate such data. If deletion or aggregation is not possible, Siara will securely store your Personal Data and isolate it from further processing until deletion becomes possible.
SECURITY OF PERSONAL DATA
  1. Siara implements appropriate technical and organizational measures to protect the Personal Data it collects and processes. These measures are designed to provide a level of security suitable to the risks involved in processing your Personal Data. If you have any questions about the security of your Personal Data, please contact us as described in this Privacy Policy.
YOUR RIGHTS
You are entitled to the following rights:
  1. Access, Correction, and Deletion. You have the right to request access to, correction of, or deletion of your Personal Data. If you wish to request a copy of the Personal Data we hold about you, seek information on how we use or disclose your Personal Data, or request a correction or update, you may submit your request in writing or via email to our Data Protection Officer using the contact details provided below.
    • Please note that a reasonable fee may be charged for an access request. If applicable, we will inform you of the fee before processing your request.
    • We will respond to your request as soon as reasonably possible, generally within thirty (30) business days. If we are unable to respond within this timeframe, we will notify you in writing within thirty (30) days, indicating when you can expect a response. If we cannot provide you with the requested data or make the requested correction, we will generally explain why, unless we are not required to do so under applicable law.
  2. Opt-Out of Marketing Communications. You have the right to opt out of receiving marketing communications from Siara at any time. You may do so by clicking the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing, such as postal mail or telemarketing, please contact us directly.
  3. Withdrawal of Consent. You may withdraw your consent at any time. Please note, however, that withdrawing consent does not affect our right to continue collecting, using, and disclosing Personal Data where such activities are permitted or required by applicable laws without consent.
NOTICE TO END-USERS AND OTHER EXCLUSIONS
  1. Siara’s Service(s) are designed for enterprise use. Siara is not responsible for the privacy or security practices of its Subscribers, which may differ from this Privacy Policy. Subscribers of the Service(s) are solely responsible for creating their own privacy policies and ensuring compliance with all applicable laws, regulations, privacy policies, agreements, and other obligations related to the collection of Personal Data through the use of the Service(s) by End-Users. Siara processes the Personal Data of End-Users on behalf of Subscribers as a Data Intermediary. If you are an individual interacting with a Subscriber through the Service(s), please contact the Subscriber directly for any inquiries or requests regarding your Personal Data.
  2. Siara’s Website(s) may contain links to other websites. This Privacy Policy applies only to Siara’s Website(s). If you click on a link to another website, please review that website’s privacy policy. Siara encourages you to understand the Personal Data practices of any linked websites by reviewing their respective privacy statements.
  3. This Privacy Policy does not apply to aggregated information, which provides statistical summaries about groups of users and does not include names, contact details, or any other information that could identify an individual.
DATA PROTECTION AND PRIVACY CLAUSE
  1. Data Collection and Use. Siara is committed to safeguarding individual privacy and ensuring that Personal Data is processed in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), Singapore’s Personal Data Protection Act (PDPA), Malaysia’s Personal Data Protection Act (PDPA), and applicable U.S. federal and state laws. Personal Data collected by Siara will be:
    • Processed lawfully, fairly, and transparently;
    • Collected for specified, explicit, and legitimate purposes, and not further processed in ways that are incompatible with those purposes;
    • Adequate, relevant, and limited to what is necessary for the purposes for which it is processed;
    • Accurate and, where necessary, kept up to date;
    • Retained only for as long as necessary for the purposes for which the data was collected; and
    • Processed securely, with appropriate technical or organizational measures to protect against unauthorized or unlawful processing, accidental loss, destruction, or damage.
  2. Consent. Where required by applicable law, Siara will obtain the necessary consent from individuals before collecting or processing their Personal Data. Individuals have the right to withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
  3. Data Subject Rights. Siara respects the rights of individuals to access, correct, delete, or restrict the processing of their Personal Data. Individuals may also exercise their right to data portability and object to the processing of their Personal Data under certain circumstances. Siara will facilitate the exercise of these rights in compliance with applicable data protection laws.
  4. International Data Transfers. Siara ensures that any cross-border transfer of Personal Data complies with applicable data protection laws. Where Personal Data is transferred outside the European Economic Area (EEA), Siara will implement appropriate safeguards, such as Standard Contractual Clauses (SCCs), to ensure the data is protected in accordance with the GDPR or other relevant legal frameworks.
  5. Data Security. Siara employs appropriate technical and organizational measures to protect Personal Data from unauthorized access, alteration, disclosure, or destruction. These measures are regularly reviewed and updated to maintain the ongoing security of Personal Data.
  6. Data Retention. Personal Data will be retained only for as long as necessary to fulfill the purposes for which it was collected or as required by applicable laws and regulations. Siara will securely delete or anonymize Personal Data that is no longer required.
  7. Data Breach Notification. In the event of a Personal Data breach, Siara will notify the relevant supervisory authorities and affected individuals, as required by law. Siara will take immediate steps to mitigate the impact of the breach and prevent future occurrences.
  8. Compliance and Accountability. Siara is committed to complying with all applicable data protection laws and will regularly review and update its data protection practices. Siara will maintain appropriate records of data processing activities and will demonstrate compliance with its data protection obligations.
CONTACT INFORMATION
  1. For any inquiries, feedback, or requests regarding our Personal Data protection policies and procedures, please contact our Data Protection Officer using the details below:
CHANGES TO THE POLICY
  1. Siara regularly reviews this Privacy Policy and may update it from time to time. Amendments to this Privacy Policy may be made at any time. You will be notified of such changes only where the updates are considered significant, in accordance with applicable laws.
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