USER PRIVACY POLICY

Updated on 22/11/2023

The purpose of this Privacy Policy (“this Policy”) is to inform you of how SHARELAH SG PTE LTD manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to SHARELAH SG PTE LTD, its related corporations and affiliates, (collectively referred to herein as "Sharelah", "us", "we" or "our"), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Sharelah’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to Sharelah nor does it affect any rights which Sharelah may have at law in connection with the collection, use or disclosure of your Personal Data. Sharelah may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our websites. Please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the Sharelah’s Terms and Conditions.

In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Sharelah’s Conditions, the Privacy Policy shall prevail. All defined terms contained in the Sharelah’s Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

Your Personal Data

In this Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us:

(a) Your name;

(b) Email address;

(d) Gender;

(e) Telephone number;

(f) Location information;

(g) Your payment related information, such as your bank account or credit card information, and your credit history; and,

(h) any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

Collection of Personal Data

We collect your Personal Data when you voluntarily provide it to us. Some general examples where you may provide Personal Data to us could be when you:

Create an account;

Using of Sharelah;

Interact with our social media pages;

Participate in contests or events organised by us;

Contact customer support; or

Otherwise communicate with us.

Purposes for the collection, use and disclosure of your Personal Data

Generally Sharelah collects, uses and discloses your Personal Data for the following purposes:

To process your application for a Sharelah account;

To maintain your account with us;

Communicating with you, whether it is through the application, phone calls or SMS message, to inform of changes and development to Sharelah’s policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to Sharelah’s product and services offered to you;

Responding to your queries and requests and responding to complaints;

Conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you;

Process and manage your rewards;

Verifying your identity;

Preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing other commercial risks;

Protecting and enforcing our contractual and legal rights and obligations;

Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends

Conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks; and,

Compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.

3.2 We may transfer the information described in this Policy to, and process and store it in the country you reside or other countries, some of which may have less protective data protection laws than the region in which you reside, while we will take appropriate measures to protect your personal information in accordance with this Policy and applicable laws.

Disclosure of Personal Data

Sharelah will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

Sharelah affiliates;

Agents, contractors or third party service providers who provide operational services to Sharelah;

The Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

Anyone to whom we transfer or may transfer our rights and duties;

Banks, credit card companies and their respective service providers;

Our professional advisors such as our auditors and lawyers;

Relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

Any other party to whom you authorise us to disclose your Personal Data.

Sharelah and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology (“Cookies”) in connection with your use of Sharelah. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of Sharelah. Cookies may be persistent or stored only during an individual session.

Sharelah may allow third parties to use Cookies on Sharelah to collect the same type of Personal Data for the same purposes Sharelah does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.

If you do not wish for your Personal Data to be collected via Cookies on Sharelah, you may also be able to limit our sharing of some of this Personal Data through your mobile device settings, or by submitting your details here.

Withdrawal, Access and Correction of your Personal Data

Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found here.

Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to Sharelah on your behalf.

Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Sharelah may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with Sharelah and your being in breach of your contractual obligations or undertakings, and Sharelah’s legal rights and remedies in such event are expressly reserved.

Marketing and promotions

We may use your Personal Data to market Sharelah and Sharelah’s partners’ sponsors’ and advertisers’ products, services, events or promotions. For example, we may send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and notify, invite and manage your participation in our events or activities;

We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

Amendments and updates

Sharelah shall have the right to modify, update or amend the terms of this Policy at any time by placing this updated Policy on Sharelah. By continuing to use Sharelah, you signify your acceptance of such modifications, updates or amendments.

Analytics and Advertising Services provided by others

9.1 We may change this Policy from time to time. If we make significant changes in the way we treat your personal information, or to this Policy, we will provide you notice through the Services or by some other means, such as email. Your continued use of Sharelah after such notice constitutes your consent to the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices.

Governing Law

10.1 This Policy shall be governed in all respects by the laws of Singapore.

11.1 If you have any questions about this Privacy Policy, please contact us at info@sharelah-sg.com , or write us at. SHARELAH SG PTE. LTD., at 565 MacPherson Road #03-00