2. By ‘we’, ‘us’ in this policy, we mean ‘Connexify’.
The type of personal information we collect
- We collect certain personal information about visitors and users of our website.
6. The most common types of information we collect include things like: member names, email addresses, phone numbers, IP addresses, billing address details, payment information such as payment agent details, transactional details, support queries, website administration information, app store account credentials, server information and web analytics data.
How we collect personal information
- We collect personal information directly when you provide it to us, automatically as you navigate through the website, or through other people when you use services associated with the website.
8. We collect your personal information when you provide it to us when you complete registration and buy products or services on our website, subscribe to a newsletter, email list, submit feedback, submit support ticket, enter a contest, fill out a survey, or send us a communication.
Personal information we collect about you from others
- Although we generally collect personal information directly from you, on occasion, we also collect certain categories of personal information about you from other sources. In particular:
a. financial and/or transaction details from payment providers in order to process a transaction;
b. other third party sources/ and or partners, whereby we receive additional information about you (to the extent permitted by applicable law), such as demographic data or fraud detection information, and combine it with information we have about you. For example, fraud warnings from service providers like identity verification service. We also receive information about you and your activities on and off the Connexify website through partnerships, or about your experiences and interactions from our partner ad networks. We also receive information about you as a rights holder from our third-party partners when you purchase our products or services from them.
How we use personal information
- We will use your personal information:
a. To fulfil an order or a contract, or take steps linked to a contract: in particular, in facilitating and processing transactions that take place on the website, like where you purchase an item from our store.
b. Where this is necessary for purposes which are in our, or third parties, legitimate interests. These interests include:
i. operating the website;
ii. providing you with services described on the website;
iii. verifying your identity when you sign in to our website;
iv. responding to support tickets, and helping facilitate the resolution of any disputes;
v. updating you with operational news and information about our website, products and services e.g. to notify you about changes to our website, upgrade of product purchased by you, website disruptions or security updates;
vi. carrying out technical analysis to determine how to improve the website, products and services we provide;
vii. monitoring activity on the website, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the website;
viii. managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the website or asking for your feedback or whether you want to participate in a contest or survey;
ix. managing our legal and operational affairs (including, managing risks relating to content and fraud matters);
x. training our staff about how to best serve our customers;
xi. improving our products and services; and
xii. providing general administrative, support, performance functions and activities.
c. Where you give us consent:
i. providing you with marketing information about products and services which we feel may interest you; and
d. For purposes which are required by law.
e. For the purpose of responding to requests by government, a court of law, or law enforcement authorities conducting an investigation.
When we disclose your personal information
- We will disclose personal information to the following recipients:
a. Companies and ventures that are in the “Connexify Pte. Ltd”;
b. service providers who assist us in connection with the ways we use personal information (as set out above), in particular: website hosting providers; marketing and analytics services; security and fraud prevention services; payment processing services.
c. our professional advisers (lawyers, accountants, financial advisers etc.);
d. regulators and government authorities in connection with our compliance procedures and obligations;
e. a purchaser or prospective purchaser of all or part of our assets or our business, and their professional advisers, in connection with the purchase;
f. a third party to respond to requests relating to a criminal investigation or alleged or suspected illegal activity;
g. a third party, in order to enforce or defend our rights, or to address financial or reputational risks;
h. a rights holder in relation to an allegation of intellectual property infringement or any other infringement; and
i. other recipients where we are authorised or required by law to do so.
Where we transfer and/or store your personal information
- We are based in Singapore with our servers based in Singapore so your data will be processed in SIngapore. We do this on the basis of your consent to this policy. In order to protect your information, we take care where possible to work with service providers who we believe maintain an acceptable standard of data security compliance.
Data that flows between each of your sub-processors is done on the server-side of our operation. This information is never cached and is sent directly to the subprocessor using a secure connection and private keys provided by the subprocessor. These private keys are never stored on any of the servers in flat files.
List of Sub processors
Google cloud hosting ( https://cloud.google.com )
Mailchimp (Newsletters - https://mailchimp.com/ )
Sendgrid (Email Processor - https://sendgrid.com/ )
Google Analytics ( https://privacy.google.com/businesses/compliance/ )
PayPal (Payment Processor - https://www.paypal.com/us/webapps/mpp/ua/privacy-full )
OSticket (Ticket System - http://osticket.com/ )
How you can access your personal information
- You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us at any time. To make an access or correction request, contact our privacy inspector using the contact details at the end of this policy.
Marketing Choices regarding your personal information
- Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.
16. You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our website may not work properly in your case.
Cookies and web analytics
18. When you visit our website, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:
a. your IP address or proxy server IP address;
b. the URL you requested;
c. the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection;
d. the date and time of your visit to the website;
e. the length of your session;
f. the pages which you have accessed;
g. the number of times you access our site within any month;
h. the URL you look at and information relating to it;
i. the website which referred you to our website; and
j. the operating system which your computer uses.
Information about children
- Our website is not suitable for children under the age of 16 years, so if you are under 16 we ask that you do not use our website or give us your personal information. If you are from 16 to 18 years, you can browse the website but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our Sites.
Information you make public or give to others
How long we keep your personal information
When we need to update this policy
- We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.
24. When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.
How you can contact us
- Data Protection Officer: We have a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. You may contact this officer if you have any questions about our privacy practices, deletion of data or the way in which we have been managing your personal information This Data Protection Officer can be reached at the following address: Connexify Pte Ltd. 1 COLEMAN STREET #10-06 THE ADELPHI Singapore 179803 or email@example.com
If you’re a user or visitor in the European Economic Area these rights also apply to you:
- For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “ GDPR ”), we are a ‘data controller’ of your personal information. How you can access your personal information
2. You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.
3. These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.
4. Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.
5. If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.
Connexify Pte Ltd
1 COLEMAN STREET #10-06