On the Platform, Users will find digital content, including but not limited to, games, quizzes, and videos (“Content”) which are licensed, and / or purchased, and / or developed by SAS DIGITAL PTE, a private limited company incorporated in Singapore, with its registered office at 60 Robinson Road, #14-04, Singapore Business Federation Center, Singapore (068914) (“We”, “Us”, or “Our”). We own, manage, and operate the Platform.
This Policy is to make You aware of the procedures adopted by Us with respect to collection, use, storage, processing, disclosure, and protection of any information provided by You, while Using the Platform or the Content.
The Platform and / or the Content can also be made available to You within other apps and websites owned by Us (“Company Platforms”) or third-party platforms, including but not limited to, third-party websites, mobile applications, and other internet products (“Third-Party Platforms”).
This Agreement will be applicable to You in entirety even when You Use the Platform and / or the Content from within Company Platforms or Third-Party Platforms. In such cases, all the terms and policies of such Company Platforms or Third-Party Platforms shall also be applicable to You.
We may collect and have access to Your Personal Information (as defined below) when You Use Platform or Content: (i) directly, or (ii) through Company Platforms, or (iii) through Third-Party Platforms.
You must be 18 (eighteen) years of age or older to Use the Content and / or the Platform in any manner. By Using the Content and / or the Platform, You hereby represent and warrant to Us that You are 18 (eighteen) years of age or older, and that You have the right, authority, and capacity to Use the Content and / or the Platform, and that You agree to abide by this Agreement.
All users must be persons who can form legally binding contracts under the laws of Singapore. Persons who are considered 'incompetent to contract' under the Singapore Contract Act, including minors, undischarged insolvents, etc., are not eligible to use the platform and/or access the content..
We respect the privacy of users and are committed to protecting it. This policy is in accordance with the Personal Data Protection Act (PDPA) of Singapore, and the applicable rules thereunder, including any subsidiary legislation and regulations made under the PDPA. We also comply with any other applicable laws of Singapore related to data protection and privacy.
This Policy describes a contractual agreement between the User and Us regarding the User’s Use of the Content and / or Platform. You agree not to enter into any contractual provisions in conflict with this Agreement.
By voluntarily Using Platform and / or Content, and providing Us with information (personal and / or non-personal), You hereby consent to Our use of Your information in accordance with this Policy.
In the event You do not agree with the terms and conditions of this Policy, please do not proceed further to Use Platform and / or Content.
You hereby agree and acknowledge that this Policy shall not be applicable:
- for any collection, handling, process, access, storage, or sharing of Your Personal Information by a Third-Party Platform where the Platform or Content is available, either directly through that Third-Party Platform or through any other source.
- to Company Platforms or Third-Party Platforms that make Platform or Content available to their users.
- to websites, apps, and other internet products You get re-directed to when You click on any advertisement on the Platform or Content.
- to information We collect about You offline or outside of Platform, such as over the phone or in person, except for any information (including feedback) that You provide to us under Section 1.1.1 (iv) of this Policy.
- to information that is collected, handled, stored, processed, accessed, and shared by Third-Party Services (as defined below).
We have no control over and responsibility towards the privacy practices or the content of any of advertisers running promotions on Platform or Content, Third-Party Platforms that make Platform or Content available to their users, and Third-Party Services. You are advised to check the applicable privacy practices and terms of such advertisers, Third-Party Platforms, and Third-Party Services.
- COLLECTION OF INFORMATION
- INFORMATION YOU PROVIDE
- During Your Use of Platform and / or Content, We may collect and process information, including, without limitation, Personal Information from You, which are detailed below:
- We may collect personal information from You while You Use the Platform and / or Content, including but not be limited to, contact information such as name, email address, mailing / residential address with pin code, phone number, gender, cookies, internet protocol addresses, city, region, country of residence, device IDs, and user agents (together, “Personal Information”).
Further, if You choose to disclose information about Yourself in Our online chat rooms or equivalent, comments section, or by creating a profile on Platform (if available), any information, including Personal Information that You disclose in these areas is public information, and maybe accessible to anyone who uses Platform and / or Content. We are not responsible for the actions of any third-parties with whom You share personally-identifiable information through Platform and / or Content.
- Note that since Platform and / or Content maybe Used through Third-Party Platforms, where some of these Third-Party Platforms may be social media platforms, it is Your responsibility to read and understand the terms and privacy policies of such Third-Party Platforms and decide whether You want to use such Third-Party Platforms, before Using the Platform and / or Content through such Third-Party Platforms.
- Further, if You use Your accounts on third-party products (including but not limited Google, Facebook, LinkedIn, and Truecaller) to sign-in to the Platform or sync your profile on such third-party products to Your account on Platform, We will collect information in accordance with the terms of these third-party products.
- Content and / or Platform, may contain advertisements, which could be targeted and interest-based. We may display advertisements to You based on Your Personal Information, and / or based on Your engagement with Platform and / or Content, and /or based on the policies of Third-party Services. Towards this, certain third-party tools that We have integrated on Platform and / or Content, such as Advertising Partners (as defined below) (for instance, Google AdSense), ad server (for instance, Google Ad Manager), web analytics tools (for instance, Google Analytics), Cloud Services Providers (as defined below) (for instance, Amazon Web Services), etc. (collectively, “Third-Party Services”) may directly or indirectly collect Your Personal Information. We may also share Your Personal Information with such Third-Party Services. We will not be responsible and / or liable for the collection, storage, usage, access, and disclosure of Your Personal Information by such Third-Party Services and these would be governed by the privacy policies of these Third-Party Services. It is solely Your responsibility to read, accept (if applicable), and keep Yourself updated with the policies and terms of such Third-Party Services.
- You may refuse to provide the aforementioned Personal Information to Us. However, such refusal may prevent You from receiving all or certain offerings in Platform and / or the Content.
- If You use Your phone number to access Content and / or Platform, We may access Your contacts list on Your device, including any data, such as phone number, name and profile photo available in such contact lists, including, to determine if someone in Your contacts is Using Content and / or Platform.
- Personally-identifying information, if any, that You post during chats, posting comments on Our forums, sending feedback, entering contests, etc. will also be collected by Us.
- We do not make any warranty whatsoever, whether express or implied, relating To fitness or accuracy, reliability, completeness, timeliness, performance, Safety, merchantability, quality, suitability, fitness for a particular Purpose, or authenticity towards your personal information that we collect, Access, use, store, disclose and / or otherwise process, at any particular Time or location.
- You should not use platform and / or content, by means of any mechanism or Technology which conceals your actual geo-location or provides incorrect Details of your location (for example, by using a virtual private network). We will not be responsible or liable for any collection, storage, or Processing of your personal information or any other data if you use any Mechanism or technology which conceals your actual geo-location.
- We also collect and track the following information based on Your engagement on Content and / or Platform. Please note that the below mentioned is an indicative list of information pertaining to Your engagement with the Content and / or Platform that we may collect, use, access, track, disclose, store, and / or otherwise process:
- From Your activity: IP address (static or dynamic), browser type, browser language, pages viewed on Platform and the order of those pages, the amount of time spent on particular pages and Content, the date and time of Use, etc.
- From Your device: Type of device, define manufacturer, advertising identifier, device identifiers (such as IMEI), operating system and version, carrier, language settings, geo-location, network type (2G, 3G, 4G, Wi-Fi), screen resolution, etc.
- From Third-Party Services: Reports on activity, engagement metrics on Platform and Content, usage trends, demographic data, etc.
Cookies are small blocks of data created by a web server when an internet user is browsing a website and are placed on such user’s computer or any other device by such user’s web browser. A cookie file is stored in an internet user’s web browser and allows the service or a third-party to recognize such user and make such user’s next visit easier and the related service more useful.
It is usually possible to stop Your browser from accepting cookies from a website. Please note, however, that if You delete cookies or refuse to accept them, You might not be able to Use all the features the Platform and / or the Content offer. You may not be able to store Your preferences, and some of Our pages might not display properly
All modern browsers allow You to change Your cookie preferences through their settings. These settings will typically be found in the "options" or "preferences" menu. In order to understand these settings, the following links may be helpful:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
- Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
- Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
To find information relating to other browsers, please visit the browser developer's website.
If You are primarily concerned about cookies being generated by Advertising Partners, You may be able to turn these off by going to the Your Online Choices site or any other application that provides a similar service. However, in the event a third-party, including a Third-Party Service, uses statistical identification or other non-cookie technologies (such as eTags and web or browser cache) on Platform or Content, then browser settings that block cookies may have no effect on such technologies.
REASONS FOR COLLECTING INFORMATION
We use Your Personal Information and other information to maintain the general and personalized content and functionality of Platform and / or Content. In addition, We use personal details to make it possible to accommodate Your requests. We will use and retain Your information for such periods as necessary to comply with Our legal obligations, resolve disputes, and enforce Our agreements, including the Agreement.
More specifically, it may be used for one or more of the indicative reasons provided below:
To improve Content and Platform, and to help You efficiently access Platform and / or Content;
To personalize Your experience and make bespoke recommendations;
To help You efficiently access Your information and the progress each time You use Platform and / or Content;
For running advertising and promotions;To resolve Your disputes with Us and to resolve Your grievances;
To carry out Our obligations and to process transactions arising from any contracts entered into between You and Us;
Conduct research and analysis to detect, prevent, mitigate, and investigate fraudulent or illegal activities;
Monitor aggregate metrics such as total number of viewers, visitors, traffic, and demographic patterns and to analyse how the Content and / or Platform is used, diagnose service or technical problems, maintain security, etc.;
To notify You about changes on Platform and / or Content and any breach of the security of Your information and take appropriate action to the best of Our ability to remedy such a breach;
To enable Us to comply with legal and regulatory obligations;
To administer a contest, promotion, survey, etc. or to maintain record of Our dealings with You;
To help You to connect with Your friends from social media network or device's contacts;
To send periodic emails for sharing information and updates pertaining to the Content or Platform, occasional news about Us, updates, related product or service information, etc.;
To enforce or protect Our rights, or any or any of Our affiliates, associates, employees, directors, or officers, or when We have reason to believe that disclosing Personal Information of Users is necessary to identify, contact, or bring legal action against someone who may be causing interference with Our rights, Platform, and / or Content, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
SHARING YOUR INFORMATION
WITH EMPLOYEES, CONTRACTORS, AND AFFILIATED ORGANIZATIONS: Strictly on a need-to-know basis in order to process it on Platform’s behalf or to facilitate smooth functioning of Our business, such as providing Platform, Content, IT support, and customer service. Platform shall share such information, including Personal Information, within its group companies and officers and employees of such group companies for the purpose of processing Personal Information on its behalf. We also ensure that these recipients of such information, including Personal Information, agree to process such information based on Our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
- WITH THIRD-PARTIES: We may share Your information, including Personal Information, with Third-Party Services, Third-Party Platforms, and other third-parties for purposes including but not limited to the conduct of Our business, to provide Platform and Content to You, mitigating fraud and risk, Our compliance with applicable laws, etc.
We may store information in locations outside the direct control of Platform (for instance, on servers or databases located with Cloud Service Providers).
These third-parties may provide You with additional services or information about the products and services they offer. Their handling of Your information, including Personal Information, shall be as per their respective privacy policies and Platform shall not be responsible for the same.
We will not be responsible for any breach of security or for any actions of any third-parties including, without limitation, Third-Party Platforms and Third-Party Services, that receive Your Personal Information. We shall not be liable for any loss or injury caused to You as a result of, You and / or Us providing Your Personal Information to third-parties even if links to such third-party websites are provided on Platform and / or the Content.
We assume no liability for any disclosure of information due to errors in transmission, unauthorised third-party access or other acts of third-parties, including, without limitation, those of Third-Party Platforms and Third-Party Services, or acts or omissions beyond Our reasonable control and You agree that You will not hold Us responsible for any breach of security whatsoever.
- WITH PARENT COMPANY, AFFILIATE, SUBSIDIARY, INVESTOR, OR ACQUIRER: In the event of corporate sale, merger, reorganization, sale of assets, dissolution, or bankruptcy, Your information, including Personal Information, may be part of the transferred assets.
In the unlikely event that We go out of business or enter bankruptcy, Personal Information would be one of the assets that is transferred or acquired by a third-party.
You acknowledge that such transfers as contemplated above may occur, and that any acquirer of Platform may continue to use Your personal information as set forth in this Policy.
- WITH REGULATORY AUTHORITIES: When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including but not limited to cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing this Policy or for complying with the applicable laws and regulations.
PROTECTING YOUR INFORMATION
Your information is important to Us. We use reasonable safeguards as per industry standards to preserve the integrity and security of Your information against loss, theft, unauthorised access, disclosure, reproduction, use, or amendment. To achieve the same, We use reasonable security practices and procedures for the protection of Your information. However, no commercial method of information transfer over the internet or electronic data storage is known to be 100% secure. As a result, We cannot guarantee the absolute security of that information, including Personal Information during its transmission or its storage in Our systems. Be advised that if You send messages or post material containing Personal Information, that information may be collected and used by others.
We store and process Your Personal Information on cloud servers provided by Amazon Web Services (“AWS”) and Microsoft Azure (“Azure”), and We may partner with other cloud service providers in future. AWS, Azure, and other cloud service providers that We may partner with in future are collectively referred to as “Cloud Service Providers”. Currently, all Your information, including Your Personal Information are stored by AWS in servers located in Mumbai, India and Azure servers in Pune, India. However, in future, all Your information, including Your Personal Information, may be maintained by Cloud Service Providers on servers or databases located outside India or to a jurisdiction where the privacy laws may not be the same as those in Your location, region, or country. By using Our offerings through Platform and / or Content, You consent to the transfer of such information to the Cloud Service Providers and to maintenance and storage of Your Personal Information in jurisdictions other than Your jurisdiction. All information, including Personal Information You provide to Us may be stored in locations outside India.
Notwithstanding anything contained in this Policy or elsewhere, the Company shall not be held responsible for any loss, damage, or misuse of Your Personal Information, if such loss, damage or misuse is attributable to a Force Majeure Event (as defined below). For the purposes of this Policy, a "Force Majeure Event" shall mean any event that is beyond Our reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes or industrial action of any kind, riots, insurrection, war, acts of government, pandemics, computer hacking, unauthorised access to computer, computer system or computer network, computer crashes, breach of security and encryption (provided beyond Our reasonable control), power or electricity failure, or unavailability of adequate power or electricity.
You agree and acknowledge that We may retain a copy of all information provided by You as per Our security, recovery, and back-up policies effective at such points in time, even if You stop using Platform and / or Content.
- YOUR RIGHT TO REQUEST
You have a right, subject to the statutory provisions, to have Your Personal Information corrected, updated, amended, blocked, and deleted. We may, however, decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required as reasonably and solely determined by Us at such point in time. You may send an email to Our Grievance Officer and Data Protection Officer (details provided below), with a request to update, correct, block, delete, and amend any Personal Information.
- UNSUBSCRIBING FROM EMAIL COMMUNICATIONS
If You are receiving Our emails and no longer wish to receive them, You may opt out at the time You receive the message by following the unsubscription instructions in that email. Please allow Us reasonable time for Your request to be processed. However, You may not opt out of service-related communications (e.g., account verification, changes / updates to features of the Platform or Content, technical and security notices, etc.).
- LIMITING SCOPE OF SHARING INFORMATION
In event of disagreement with terms of this Policy, You may either not Use the Platform or Content, or You may limit Your level of interaction with the Platform or Content, which could include not providing Us with Personal Information.
- DELETION OF YOUR PERSONAL INFORMATION
If You had previously agreed to this Policy, but no longer agree with this Policy or seek to withdraw Your consent with respect to Your data, please write to the Grievance Officer and Data Protection Officer. Upon withdrawal of Your consent, We will take actions and attempt to delete all Your Personal Information available with Us. We, however, will retain information, including Personal Information about You that is on Our system following Your termination and / or deletion request as per Our security, recovery, and back-up policies effective at such points in time. You understand and acknowledge that, even after removal, copies of personal data or content may remain viewable in cached and archived pages, or if other Users have copied or stored Your personal data or content.
- GOVERNING LAW
- AGGREGATED STATISTICS
Platform may collect statistics about the behavior of Users. When in the aggregate form and not pointing to a particular individual, We may display this information publicly or provide it to others.
Phishing can occur if Users are induced by an individual / entity into divulging personal and / or sensitive personal data by using fraudulent media, including without limitation, websites, phone numbers, and / or e-mail addresses. In the event You provide information to a website or respond to an e-mail which does not belong to Us or is not connected with Us in any manner, You may become a victim to Phishing. We do not send e-mails requesting Users to provide payment information, username, or passwords. However, We may verify the payment information (if applicable), username, password etc. provided by You from time to time.
If You receive a suspicious email on Our behalf, We suggest You do not: (i) reply to it, (ii) open any attachments, (iii) click on links contained in the e-mail, (iv) or provide any information in response to it. You can report suspected fraud involving Us by sending an e-mail to the Grievance Officer and Data Protection Officer respectively. Please include the word "phishing" in the subject line of Your e-mail and provide as much information as possible about the suspected fraudulent activity or message.
- If You have any questions, feedback, or concerns in relation to this Policy or Your information with Us, including if You identify any discrepancies and have any grievances with respect to collection or processing of personal data, please contact: