Privacy Policy

Purpose

This privacy policy (this “Privacy Policy”) describes the policies and procedures on the collection, use, disclosure and retention of your information when you provide your information via FLEXII Pte. Ltd. (“the Company”, “we,” “us,” or “our”)’s website or when you use the Services (as defined below) provided by us. We comply with the laws and regulations that may be applicable to the processing of personal data when providing our Services. We take the utmost care in protecting the personal data and privacy of the users of our Services (“you”) and process your personal data in accordance with this Privacy Policy.

We use your personal data to provide and improve our Services. By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• “Account” means a unique account created for you to access any of our Services.
• “Affiliate” means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more than 50% shareholding of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• “Application” means the software program provided by us, named Flexii.
• “Country” means Singapore.
• “Device” means any device that can access the Services such as a computer, a cellphone or a digital tablet.
• “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.
• “Service or Services” refers to the Application.
• “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Services, to provide the Services on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Services is used.
• “Usage Data” refers to data collected automatically, either generated by the use of the Services or from the Service infrastructure itself (for example, the duration of a page visit).

Ways We Collect Your Personal Data and the Information We Collect

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to the following:

1. Email address;
2. First name and last name;
3. Phone number; and
4. Address.

Usage Data

Usage Data is collected automatically when you are using the Services. Usage Data may include information such as your device’s internet protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Services by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device.

Location information collected while using the Application

We may collect the information regarding your location with your consent when you are using our Application to provide some features of our Application based on the locations.

Use of Your Personal Data

We use the Personal Data for the following purpose:

1. to verify your identity;
2. to provide features of our Services;
3. to improve and customize our Services;
4. to provide and maintain our Services, including to monitor the usage of our Services;
5. to manage your Account;
6. to monitor the performance of a contract (ie. the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Services);
7. to contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
8. to provide you with marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
9. to manage your requests;
10. to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
11. to transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
12. to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Service users is among the assets transferred; and
13. for other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, services, marketing and your experience.

Disclosure of Your Personal Data

We may disclose your Personal Data with:

1. Service Providers: We may share your Personal Data with Service Providers to monitor and analyze the use of our Services, to contact you.
2. Vendors: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
3. Affiliates: We may share your Personal Data with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
4. Business partners: We may share your Personal Data with our business partners to offer certain products, services or promotions to you.
5. Users of the Application: To the extent required, we may share your Personal Data to our registered users in order for them to provide the necessary service.
6. Other users: when you share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

We may disclose your Personal Data for any other purpose with your consent.

Withdrawing of Your Consent

The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw your consent and request us to stop using or disclosing your Personal Data for any or all of the purposes listed in this Privacy Policy by submitting your request in writing or via email to our Data Protection Officer at the contact details below. Upon receipt of your written request to withdraw your consent, we will 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. In general, we shall seek to process your request within fifteen (15) business days of receiving it. If you withdraw consent for data use that is essential for us to provide the services that you have subscribed, we may not be able to provide our Services to you, and we shall, in such circumstances, notify you before completing the processing of your request.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.

Accuracy of Your Personal Data

The Company generally relies on Personal Data provided by you. 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.

Access and Correction of Your Personal Data

You may make a request to access your Personal Data which we hold about you or the information about how we use or disclose your Personal Data. You may also make a request to make any correction or update of your Personal Data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) 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 the relevant personal data protection laws).

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or We are legally obligated to retain this data for longer time periods.

We will cease to retain your Personal Data and Usage 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.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless the recipients provide a standard of protection that is at least comparable to standard of the protection required by the applicable laws and regulations applicable to the Company.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

1. comply with a legal obligation;
2. protect and defend the rights or property of the Company;
3. prevent or investigate possible wrongdoing in connection with the Services;
4. protect the personal safety of users of the Services or the public; and
5. protect against legal liability.

Security of Your Personal Data

The security of your Personal Data is important to us. We have implemented appropriate security measures to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risk and loss of any data. While security cannot be guaranteed, we strive to protect the security of your Personal Data and we are constantly reviewing and enhancing our Personal Data security measures.

Data Breach

In the event that we have credible grounds to believe that an incident of Personal Data breach has occurred, we will take reasonable and expeditious steps in accordance with the applicable personal data protection laws.

Children’s Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian for a child under the age of 13 and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without parental consent, we will take steps to remove that information from our servers.

If we need to rely on consent as a legal basis for processing your information, we may require your parent’s consent before we collect and use that information.

Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Data Protection Officer

If you have any questions about this Privacy Policy, you may contact our Data Protection Officer via email: support@flexii.net.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “Last updated” date at the bottom of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of our Services constitutes your acknowledgement and acceptance of such changes.