DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which Ripple Group Holdings Pte Ltd (" ripplecreate ") (“we”, “us”, or “our”) may collect, use, disclose or
otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our
possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal
data for our purposes.
otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our
possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal
data for our purposes.
PERSONAL DATA
As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered
into a contract with us for the supply of any goods or services by us; and
into a contract with us for the supply of any goods or services by us; and
“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.
have or are likely to have access.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION OF PERSONAL DATA
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, account login information for our accounts and accounts on video conferencing platforms, profile photograph, your image and/or voice, video conference recordings, social media profile ID, user presentations, text chat communications, feedback on our services, payment-related information, like your billing address, and any other information you choose to provide.
Information we collect automatically when you interact with us : When you access or use our services or otherwise interact with us, we automatically collect certain information, including:
- Activity information: We collect information about your activity on our services, such as visual and audio files that include users’ video input and output and users’ audio input and output.
- Meeting information: Certain features and integrations of our services will collect meeting details, including the names and email addresses of invitees and participants, the meeting subject and description, meeting location, meeting ID etc.
- Transactional information: When you purchase our services, we collect information about the transaction, such as service details, purchase price, date of the transaction etc.
USE AND DISCLOSURE OF PERSONAL DATA
We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- processing payment or credit transactions;
- complying 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;
- Monitor and analyze trends, usage, and activities in connection with our services and generate reports with our analysis, including real-time reports and alerts;
- Provide, maintain, and improve our services, including maintaining user accounts with us and using information to train and improve our models within our services;
- Personalize your experience with us on our services;
- Send you technical notices, security alerts, support and administrative messages;
- Debug to identify and repair errors in our services
- any other purposes for which you have provided the information;
- transmitting 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;
- any other incidental business purposes related to or in connection with the above; and
We may 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 and services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of ripplecreate or another person. In relying on the legitimate interests exception of the PDPA, ripplecreate will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
- Fraud detection and prevention;
- Detection and prevention of misuse of services;
- Network analysis to prevent fraud and financial crime, and perform credit analysis; and
- Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations
where your relationship with us (for example, pursuant to a contract) has been
terminated or altered in any way, for a reasonable period thereafter.
where your relationship with us (for example, pursuant to a contract) has been
terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING 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 consent and request us to stop collecting, 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.
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 ten (10) business days of receiving it.
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 10 above.
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.
ACCESS TO AND CORRECTION OF PERSONAL DATA
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.
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.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. 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 PDPA).
PROTECTION OF PERSONAL DATA
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 minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure).
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.
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.
RETENTION OF PERSONAL DATA
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 applicable laws.
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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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 the PDPA.
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:
Email address: [email protected]
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice 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.
We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date: 23/12/2021
Last updated: 23/12/2021