Please read this Privacy Policy so that you are aware and understand the purposes for which we collect, use and disclose your Personal Data. This Privacy Policy informs you of how Straatosphere manages personal data in accordance with the Personal Data Protection Act 2012 (“the PDPA”).

You hereby agree and consent to Straatosphere, its related entities, affiliates and subsidiaries (individually and collectively referred to herein as “Straatosphere”, “us”, “we” or “our”) collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data in the manner set forth in this Privacy Policy.

This Privacy Policy does not affect any rights which Straatosphere may have at law in connection with the collection, use or disclosure of your Personal Data. Straatosphere may from time to time update this Privacy Policy. You agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Site.

For avoidance of doubt, this Privacy Policy forms a part of the Site’s Terms and Conditions (‘Terms and Conditions’). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Terms and Conditions, the Privacy Policy shall prevail. All defined terms contained in the Terms and Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1)          Your Personal Data

a)          In this Privacy 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. Depending on the nature of your interaction with us, Personal Data which you may be provide to us include:

i)           Your name, passport or other identification number, telephone number(s), mailing address, email address and 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;

ii)          Information about your use of our Site and Services, including cookies, IP address and newsletter subscription details, but only to the extent that Straatosphere may identify you from such information;

iii)        Payment related information, such as your bank account or credit card information, and your credit history;

and

iv)        Information about your usage of and interaction with our Site and/or Services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Site.

2)          Collection of Personal Data

a)          Straatosphere collects Personal Data when you:

i)           Submit forms relating to any of our products or Services;

ii)          Register for or use any of our Services on our Site, or other websites owned or operated by us or when you register as a member of our Site or other websites owned and/or operated by us, or use services on such other websites;

iii)        Use some of our Services, e.g. our newsletter subscription service;

iv)        Request to be included in an email or other mailing lists;

v)         When you respond to our promotions, contests and other initiatives;

vi)        When you submit your Personal Data to us for any other reason.

b)          When browsing our Site, you generally do so anonymously but please see the section below on cookies.

c)          If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.

d)          You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.

3)          Purposes for the Collection, Use and Disclosure of Your Personal Data

a)          Straatosphere collects, uses and discloses your Personal Data for the following purposes:

i)           Responding to your queries and requests and responding to feedback and complaints;

ii)          Matching any Personal Data held which relates to you for any of the purposes listed herein;

iii)        Verifying your identity;

iv)        Protecting and enforcing our contractual and legal rights and obligations;

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

vi)        Any other purpose relating to any of the above.

b)          Straatosphere may also collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

i)           If you have a newsletter subscription with us:

A)         To process your application for newsletter subscription;

B)         To maintain your newsletter subscription with us;

C)         To verify and process your personal particulars and payments (if applicable) in relation to provision of our newsletter subscription service;

D)         To provide you with the goods and services which you have signed up for;

E)         Communicating with you to inform you of changes and development to Straatosphere policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

F)          Conducting market research for statistical, profiling and statistical analysis for the improvement of products and services provided to you; and

G)         Resolving complaints and handling requests and enquiries;

H)         Processing of your Personal Data in relation to any of the purposes stated above.

ii)          If you submit advertisements to us:

A)         To verify and process your personal particulars and payments made for the posting of the advertisements;

B)         Communicating with you to inform you of changes and development to Straatosphere policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

C)         Resolving complaints and handling requests and enquiries.

c)          Where permitted under the PDPA, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

i)           Providing services, products and benefits to you, including promotions, loyalty and reward programmes;

ii)          Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Straatosphere or other third parties;

iii)        Administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;

iv)        Sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and

v)         Conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.

d)          In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4)          Disclosure of Personal Data

a)          Straatosphere will take reasonable steps to protect your Personal Data against unauthorised disclosure.

b)          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:

i)           Straatosphere affiliates;

ii)          Vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on Straatosphere’s sites, whether in conjunction with us or not;

iii)        Our professional advisors such as our auditors and lawyers;

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

v)          Any other party to whom you authorise us to disclose your personal data.

5)          Third Party Sites

a)          Straatosphere may provide links to other/external sites (“Third Party Sites”) that may be of relevance and interest to users, or that may be operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Site. Once you have left our Site, and are on a Third Party Site, please learn about the privacy policies of such third party websites to determine how they will handle any information they collect from you.

6)          Use of Cookies

a)          When accessing our Site, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as frequency of use, the number of page views (or page impressions) that occur on the Site and common entry and exit points into Site.

b)          We use cookies, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our Site. 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.

c)          We may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Aggregate Information from our Site.

d)          Please note that we do not have access to or control over the cookies or other technologies which the above-mentioned Third Party Market Research Companies may use to collect your information. The use of cookies or other technologies by these Third Party Market Research Companies are not covered by this Privacy Policy and are subject to their own privacy policies.

e)          Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, please note that you may not be able to enter certain part(s) of our Site after doing so.

7)          Withdrawal of Consent, Correction of Personal Data and Contacting Us

a)          Should you wish to:

i)           Withdraw your consent to the collection, use and/or disclosure of your personal data provided to us for any of such purpose listed above;

ii)          Have any enquiries or feedback with regard to the collection, use and/or disclosure of your personal data provided to us for any of such purpose listed above;

iii)        Wish to obtain access to your personal data in our records; or

iv)        Wish to make corrections to your personal data in our records,

please contact us as follows: editorial@straatosphere.com

b)          In the event 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 Straatosphere on your behalf.

c)          Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Straatosphere 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 Straatosphere and your being in breach of your contractual obligations or undertakings, and Straatosphere’s legal rights and remedies in any such event are expressly reserved.

8)          Governing Law

a)          This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore.

b)          You hereby agree to submit to the exclusive jurisdiction of the Singapore courts.