This Privacy Policy (“Policy”) sets out the basis which we may collect, use, disclose or otherwise process your personal data.

For the purpose of this Policy, “we”, “us” and “our” shall refer to Tickled Media Pte Ltd and its affiliates (including but not limited to subsidiaries).

“Data Protection Laws” refer to, where applicable, the Singapore Personal Data Protection Act 2012, the European Union General Data Protection Regulation and/or such other legislation in relation to data protection.

1.         What personal data is collected from you?

1.1. “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

1.2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, national identification number and contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

2.         When is personal data collected from you?

2.1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by Data Protection Laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

2.2. Instances when we collect your personal data include:

2.2.1.  When you register for or use any of our services on websites owned and/or operated by us.

2.2.2.  When you take part in any contest, survey or promotion conducted by us and/or our business partners.

2.2.3.  When you register as a member of websites owned and/or operated by us, or hosted by us on behalf of our business partners or use services on such websites.

3.         What is the personal data used for?

3.1. Personal data which we collect may be used and disclosed by us to our affiliates, business partners and contractors (who may be based outside Singapore) for the following purposes:

3.1.1.  to respond to your requests and queries;

3.1.2.  to provide goods and services to you;

3.1.3.  to verify and process your personal particulars and payments;

3.1.4.  to communicate with you;

3.1.5.  to enforce contractual and legal rights and obligations;

3.1.6.  to manage your relationship with us;

3.1.7.  for marketing research, user profile and statistical analysis;

3.1.8.  to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and those of third-party organisations;

3.1.9.  for our business partners to contact you for the purposes of marketing, promoting and/or selling products and/or services, and/or inviting you to events;

3.1.10.   to comply with law, the requests of law enforcement and regulatory officials, or orders of court; and

3.1.11.   for any other purposes for which we have obtained your consent, including during the registration process under our Member Terms and Conditions[OC1] .

3.2. In the event that you participate in contests or other promotional programs on our websites sponsored or organised by third parties or purchase goods and services offered by third parties or offer goods and services to third parties on our sites, your information may be disclosed to and used by such third parties.

3.3. We may also disclose your personal data 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.

4.         How to withdraw consent?

4.1.    The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is 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 or via email to our Data Protection Officer at the contact details provided below.

4.2. 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 10 business days of receiving it.

4.3. Whilst 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 in the manner described in Clause 4.1 above.

4.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under Data Protection Laws.

5.    How to access and correct  your personal data

5.1. If you wish to make (a) an access 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 correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

5.2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

5.3. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 60 days after receiving your request, we will inform you in writing within 60 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 Data Protection Laws).

6.    How your personal data is protected?

6.1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

6.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

7.         Accuracy of personal data

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

8.         Retention of personal data

8.1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by Data Protection Laws.

8.2. 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.

9.         Transfers of personal data outside of Singapore

We may transfer or permit the transfer of your personal data to countries outside where you have provided your personal data from. These include Malaysia, Philippines, Thailand, Indonesia and Vietnam for any of the purposes set out in this Policy. We will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under Data Protection Laws.

10.      Data protection officer

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner: send your message through with subject: Data Protection Concern.

11.  Use of cookies

11.1. We use “cookies”, where a small data file is sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

11.2. Like many website operators, we may use an independent company (the “Third Party Market Research Company”) to measure and analyse Internet usage across our websites. We use the Third Party Market Research Company’s services to collect the following information on the usage of our websites, including:

11.2.1.   The number of page views (or page impressions) that occur on our websites;

11.2.2.   The number of unique visitors to our websites;

11.2.3.   How long these unique visitors (on average) spend on our websites when they do visit; and

11.2.4.   Common entry and exit points into our websites.

11.3. This information is collated by the Third Party Market Research Company and provided to us to assist in analysing the usage of our websites. Such data is also accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other Internet portals.

11.4. Pages on our websites may include software which enables the Third Party Market Research Company and us to track visitors to our websites.

11.5. As you browse the current website, advertising cookies will be placed on your computer so that we can understand what you are interested in. Our display advertising partners, then enable us to present you with retargeting advertising on other sites based on your previous interactions.

11.6. We acknowledge that some or all of the information used/collected above may be classified as personal data as per Data Protection Laws and shall be governed by such accordingly.

12.      Effect of notice and changes to notice

12.1. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.12.2. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.