By using this website and mobile app, submitting information or using any of our products and/or services, you are agreeing with and accepting the terms and the practices outlined in this Privacy Policy. If you do not agree with and accept this Privacy Policy, please do not use this website and mobile app, provide information to us or use our products and/or services.
This Privacy Policy covers the collection and use of any personal data that we gather when you are on this website and mobile app and when you are using our services. Also, this Privacy Policy covers the use of any personal data that our business partners may share with us. This Privacy Policy does not cover personal data (if any) that may be collected elsewhere, including without limitation offline and on other sites linked to and from this website and mobile app as well as the practices of third parties that the Company does not control or own, or individuals that the Company does not employ or manage.
This Privacy Policy may be modified from time to time so check back often. Your continued access of this website and mobile app or provision of your personal data to us or continued use of our products or services (as the case may be) following the posting of changes or revisions to the terms of our Privacy Policy will constitute your agreement with and acceptance of the changes or revisions to the Privacy Policy.
1. INTRODUCTION
This Privacy Policy is written to better explain how we collect and use your personal data. This Privacy Policy is a binding contract and you must agree to it to the same extent as our Terms & Conditions in order to use our services.
2. PERSONAL DATA YOU PROVIDE TO US
This website and mobile app generally collects personally identifying information (such as, for example, your name, email address, contact address, phone number, etc.) with your specific knowledge and consent. This includes but is not limited to create an account with us, enter a raffle sweepstakes or giveaway and complete a survey, etc. You can choose not to provide us with certain personal data, but we may not be able to process your applications, or you may not be able to take advantage of many of our special features.
3. PUBLIC AREAS
When you post, contribute or share any content to a public area of this website and mobile app, the content you submit will be made available to the general public. To protect your privacy, we would recommend that you exercise caution when submitting, sharing or posting on such public area any personal data or sensitive information such as but not limited to your full name, address, phone number, or any other information that would allow other users or third parties to locate you or obtain information about you. You are entirely responsible for your use of this website and mobile app, for all of the contents that you submit or post on this website and mobile app, for any and all activities that occur under your account, and for ensuring, protecting and safeguarding the confidentiality and the security of your account. We shall not be held liable for any claims, loss or damage resulting from a breach of the foregoing, or your use of and contributions on this website and mobile app, or any unauthorized use of your account.
4. AUTOMATIC INFORMATION
Our servers may automatically collect automatic and/or aggregate information about your computer or electronic device when you visit this website and mobile app, including but without limited to the website and mobile app that referred you, Internet Protocol (“IP”) address, the type and configuration of the internet browser of your computer or electronic device, browsing preference such as language settings and font size, geo-location information and operating system of the computer or electronic device used for accessing our websites, and other usage and traffic information. The Company uses this automatic and/or aggregate information to analyze trends, gather and prepare statistics or demographic information and administer this website and mobile app so that we may provide improved web experiences to our users. Such automatic and/or aggregate information is not collected in a manner that would identify you personally. We may provide automatic and/or aggregate information, which are not personal data, to our partners about how our users, collectively use this website and mobile app. We may share this information with our partners, so that they may further understand the usage of their areas and this website and mobile app, so that they too can provide you with a better web experience. There may also be occasions when we are legally required to disclosure or provide access to our database in order to cooperate with police investigations or other legal proceedings or otherwise comply with any applicable laws or regulations, court order or lawful requests from any government authority. In those instances, the data is provided only for that purpose. For the avoidance of doubt, this Privacy Policy in no way restricts or limits our collection and use of such automatic and/or aggregate information.
5. USE AND PROVISION OF PERSONAL DATA
We may collect, use, store and provide your personal data for any of the following purposes, including:
To enhance or improve user experience, this website and mobile app and/or our products and/or services, or to facilitate our performance of our services or any services offered on this website and mobile app.
To register, verify, process and maintain membership programs for our users.
To process, verify, operate, manage, administer and maintain gaming experience for our users.
To create an online marketplace where users can communicate directly and negotiate transactions of goods and services.
To conduct and process any contests, raffle sweepstakes, giveaways and/or surveys that we may from time to time organize in relation to this website and mobile app, our business, products and/or services, and to announce the winners of the relevant contests and/or sweepstakes (as the case may be) on this website and mobile app or any other medium/channels as may be required under the applicable laws.
To detect, investigate, identify and protect against and/or preventing fraudulent transactions and other misuses of our websites and/or other activities on this website and mobile app which may violate our Privacy Policy, Terms & Conditions or may be illegal.
To enforce our Privacy Policy.
To provide third party service provider(s) engaged by us to provide services for or in relation to this website and mobile app, to process data on our behalf, to provide information technology support to us and/or conduct maintenance of our servers, data banks and databases, including but not limited to IT contractor(s), website and mobile app analytic service provider(s), data processor(s) and service provider(s) for database management systems.
To provide third party content provider(s) engaged by us, including interactive and social media providers, to provide services for or in relation to this website and mobile app, to allow the provider to host the content on our sites.
To provide our third-party advertising and promotional agencies and consultants and those organisations or online platforms selected by us to carry out marketing campaigns on our behalf and to measure the delivery and effectiveness of such advertisements (for example, client campaign tracking)
To purchaser(s)/assignee(s) as part of any re-organization, merger, transfer or sale of our business.
To comply with or as permitted by any applicable laws or regulations, court order or lawful request from any government authority.
6. COOKIES
In order to distinguish you from other users—especially other users on the same network as you— we would use cookies to track your specific computer or electronic device. Cookies are small computer text files that are sent from a website and mobile app to the browser of your computer or electronic device and are stored on your device. Generally, cookies do not recognize you personally and are not harmful to your device. Cookies are used by websites that you visit and browse to improve your website and mobile app browsing experience and provide the website and mobile app operators with non-personal data or analytical information to help improve the quality of their websites for their users’ website and mobile app browsing experience. For example, we use cookies to save your device’s browsing preferences and settings. For these reasons we require that you keep cookies enabled when using our websites. Please note that if you choose to disable cookies on your computer or electronic device, you may find that some of the features and functionality of this website and mobile app may not work properly. Additionally, our cookies may be accessible by third parties or provided by third parties including, for example, Google via Google AdSense on this website and mobile app. We do not have any control over and are not responsible or liable for such third parties’ collection and use of the cookies. Please refer to those third parties’ relevant policies regarding their collection and use of cookies for further information.
7. THIRD PARTY WEBSITES
This website and mobile app may contain links to third party websites, advertisers or services that are not owned or controlled by us. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party websites, advertisers or services or their use of your personal data. If you access a third party website and mobile app from this website and mobile app, you do so at your own risk and you understand that neither this Privacy Policy nor our Terms & Conditions apply to your use of such sites. We would encourage you to review the privacy policies and terms of use of any third party website and mobile app, advertisers or service that you visit or use before providing your personal data to those third parties, and we shall not be liable in relation to your activities on or with those other third party websites, advertisers or services.
8. THIRD PARTY ACCESS TO YOUR PERSONAL DATA
Without prejudice to the provisions in Clause “Use and Provision of Personal Data” above, we endeavor to do our best to protect your personal data from being accessed by third parties. However, since we may employ outside maintenance personnel or use third party service providers to provide website and mobile app, information technology and/or data processing services to us or to host our material, there are third party entities which may have custody or access to your information. Because of this, it is necessary that you permit us to give access to your personal data to such third party entities to the same extent that you authorize us to do so. For greater certainty, every authorization which you grant to us in this Privacy Policy, you also grant to any third party entities that we may hire, contract, instruct or otherwise retain the services of for the purpose of operating, hosting, maintaining, repairing, or otherwise improving or preserving this website and mobile app or its underlying files or systems, or for data processing on our behalf, or for providing information technology support to us, and/or for conducting maintenance of our servers, data banks and/or databases (as the case may be). To the fullest and maximum extent as is permitted under the applicable laws, you agree not to hold us liable for the actions of any of these third parties, even if we would normally be held vicariously liable for their actions, and that you must take legal action against them directly should they commit any tort or other actionable wrong against you.
Additionally, we may store your personal data or share them with other third parties as set out in Clause “Use and Provision of Personal Data” for the relevant purposes as set out in this Privacy Policy. Please refer to Clause “Use and Provision of Personal Data” above for further information regarding our purposes of use and transfer of personal data and the relevant data transferees that may be involved. Without prejudice to the foregoing, the following is a non-exhaustive list of other entities that we may store, share, or transfer your information with in accordance with the provisions of this Privacy Policy:
Google Analytics
Google AdSense
9. AMENDMENTS
We may amend this Privacy Policy from time to time, and the amended version will be posted on this website and mobile app in place of the old version. The changes in this Privacy Policy become effective as soon as the changes are published to this website and mobile app. If you continue to use the website and mobile app after the changes become effective, it will signify your agreement to be bound by such modifications or revisions.
If you do not agree with the revised/updated Privacy Policy, you must immediately cease using this website and mobile app and service.
10. VALIDITY
Severance of any provision of this Privacy Policy is held to be invalid or unenforceable for any reason by a court of competent jurisdiction, such provision shall be deemed to be severed from this Privacy Policy. Such unenforceability or invalidity shall not in any way affect the enforceability and/or validity of the remaining provisions of this Privacy Policy which shall continue in full force and effect.
11. DATA RETENTION AND DELETION
We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for satisfying any legal, accounting or reporting requirements or to comply with our data retention practices.
If you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), the following additional sections apply:
Grounds for Using Your Personal Information: we rely on the following legal basis to process your personal information:
• It may be necessary for us to use and disclose your personal information for the performance and fulfillment of the contract between us and to provide you with our services;
• We may use and disclose your personal information where it is necessary for our legitimate interests (or those of a third party) and your interest and fundamental rights do not override those interests;
• If you specifically consent to certain uses of your personal information, we may use your personal information in a manner consistent with that consent; and
• We will also process, transfer, disclose and preserve personal information when we have a good faith belief that doing so is necessary.
• If applicable pursuant to the GDPR, you have the right to withdraw previously provided consent for our processing of your personal information by contacting us [email protected]
Such individuals also have the following rights:
• Right to access – This right allows individuals to obtain confirmation that his or her personal information is being process and allows individuals to request details of the processing of his or her personal information, including, without limitation, categories of recipients to whom the personal information have been or will be disclosed and purposes of processing.
• Right to rectify – This right allows individuals to rectify any inaccurate personal information about him or her.
• Right to restrict processing – This right allows individuals to block or suppress processing of personal information under certain circumstances.
• Right to be forgotten – This right is also known as the “right to erasure.” It is an individual’s right to have personal information erased or to prevent processing in specific circumstances.
• Right of data portability – This right allows individuals to move, copy or transfer personal information from one place to another in a secure manner without interrupting the integrity and usability of the information.
• Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.
To exercise any of the following rights, you may contact us at [email protected]
12. CONTACT
Any inquiries about your rights under this Privacy Policy, or any other matters regarding your privacy, can be directed to [email protected]. You have the right to request access to and/or correction of your personal data held by us. If you wish to make such request, please contact us by email marking “Attention: Personal Data Access / Correction Request” on your correspondence.
If there is any inconsistency between the English and Chinese versions of this Privacy Policy, the English version will prevail.
This Privacy Policy was last updated on 1 February, 2021.
