PRIVACY POLICY

This Privacy Policy applies to all sites, domains and applications provided, is maintained or operated by Sustainable Living Lab Pte. Ltd. (UEN No. 201211858M), a private limited company incorporated under the laws of Singapore, with address at 68 Ceylon Road, Singapore 429650 (the “Company” or “SL2”) and/or its affiliates, carrying on business under the registered mark “SPRYX” (“SPRYX”), including http://spryx.co/ and all related sub-domains (hereinafter the “Platform”). SL2 has in place measures to protect your privacy and Personal Data. This policy describes how we may collect, use, disclose and process Personal Data which is provided to us and applies to any individual’s Personal Data which is in our possession and over which we have control. By accessing, subscribing for an account and/or using the Platform or the services therein or accepting the Terms and Conditions of the Platform, you hereby agree to this Privacy Policy.

1.         General

1.1From time to time, SL2 may collect data which enables an individual to be identified (“Personal Data”) in connection with the use of the Platform. This includes information such as names, contact details, addresses, email addresses, and other identification details of individuals who access or use the Platform.

1.2SL2 may also collect information from or about the devices which are used to access the Platform. Such information includes, but is not limited to:

(a)attributes such as the operating system of the device, hardware version, settings, file and software names and types and device identifiers;

(b)device locations; and

(c)connection information such as the name of the ISP or mobile operator through the Platform is accessed, browser type and IP address.

2.         Provision and Withdrawal of Personal Data

2.1Where Personal Data is provided as required by, pursuant to, or in connection with the use of the Platform, you represent and warrant to SL2 that (i) the relevant individual(s) (such as your spouse, children, parents, students, customers and/or employees) has/have been notified of the purposes for which data will be collected, processed, used or disclosed; and (ii) such individual’s consent for the collection, processing, use and disclosure of such Personal Data by SL2 has been obtained and authorized by such individual.

2.2SL2 must be promptly informed upon becoming aware of the withdrawal by the relevant individual of his/her consent to the collection, processing, use and/or disclosure by SL2 of any Personal Data provided to SL2. The withdrawal of such consent may affect the services which SL2 is able to provide to you. To make a request to withdraw consent previously given, please contact SL2 at enquiries@spryx.co. All requests to have Personal Data removed from SL2’s databases or physical storage facilities will be entertained and performed within its reasonable abilities.

2.3Any consent given in relation to Personal Data shall, unless withdrawn by the relevant individual in accordance with section 2.2 above and/or subject to all applicable laws and regulations, survive death, incapacity, bankruptcy or insolvency of any such individual and the termination or expiration of any account in connection with the use of the Platform.

2.4If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products and services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with SL2. 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 applicable laws.

2.5    The Platform uses tracking technologies to provide services therein. These enable SL2 to understand how you use the Platform and its services therein which, in turn, helps SL2 to provide and improve them. However, the tracking technologies do not access, receive or collect information which can be used to identify you. Below are some examples of the tracking technologies used on the Platform:

(a)Cookies. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on the Platform, estimate and report the total audience size and traffic on the Platform, and conduct research to improve the services on the Platform. You can configure your device's settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of the full services on the Platform.

(b)Flash cookies. The Platform may use Flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

3.          Use of Personal Data

3.1. SL2 may collect, store, process, disclose, access, review and/or use Personal Data in accordance with the Personal Data Protection Act 2012 or any other written law.

3.2.Without prejudice to the foregoing, SL2 may use Personal Data for any of its business purposes, which include, and is not limited to, the following purposes:

(a)to operate, administer any account and/or offer the products and services available on, the Platform;

(b)to verify the identity or authority of representatives of registered clients or Users of the Platform;

(c)to carry out or respond to requests, questions or instructions from verified or authorized representatives or other individuals pursuant to the current security procedures;

(d)to facilitate transactions on the Platform;

(e)to carry out, monitor and analyze SL2’s business;

(f)for the marketing of products and services ancillary or related to the use of the Platform;

(g)in connection with any sale, merger, or similar change of SL2’s business;

(h)to verify to comply with any applicable laws, rules, or regulations in any country; and

(i)to detect, prevent and investigate fraud.

3.3.SL2 may also retain Personal Data for so long as it may deem necessary for the purposes of record retention and for its own business purposes in connection with the operation of the Platform.

3.4By using the Platform, you authorize SL2 to use your information in Singapore and other countries where we operate for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on Personal Data protection (including, but not limited to, the Personal Data Protection Act 2012 of Singapore).

4.          Storage of Data

The Platform uses third-party service providers such as Amazon AWS Cloud services, Microsoft etc., therefore your information may be transferred to and stored on servers in various locations both in and outside of Singapore. We maintain control of your information and protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration.

5.         Disclosure of Data

5.1.SL2 may from time to time also disclose Personal Data to the following (whether inside or outside of Singapore) for the purposes listed above:

(a)any agent, contractor, or third-party service providers which provides operation, administrative or other services to SL2 in connection with SL2’s business operations and/or the Platform;

(b)any person or entity employed by or on behalf of SL2 or is a part of or related to any group of companies of which SL2 forms part; or

(c)any actual or proposed assignee of SL2 or transferee of SL2’s rights in respect of all or any part of the assets or business of SL2.

5.3. Without prejudice to the foregoing, SL2 may disclose Personal Data to any person or entity to whom SL2 is under an obligation or otherwise required to make disclosure pursuant to any applicable laws, including disclosure to courts, tribunals, and/or legal, regulatory, tax and government authorities.

6.          Access, Correction & Update of Data

6.1.You can update your Personal Data through your account profile settings. If you believe that Personal Data we hold about you is incorrect, incomplete or inaccurate, you may request us to amend, correct or update it by contacting us at enquiries@spryx.co.

6.2.Additionally, you may request access to any Personal Data that we hold about you at any time by contacting us at enquiries@spryx.co. Where we hold Personal Data that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your Personal Data.

6.3.There may be instances where we cannot grant you access to the Personal Data that we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

7.         Protection of Data

7.1SL2 will take reasonable steps to protect your Personal Data against unauthorized disclosure. To safeguard your Personal Data from unauthorized 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 authorized third party service providers and agents only on a need-to-know basis.

7.2Despite the foregoing, please note 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.

8.         Retention of Data

8.1We retain such Personal Data as may be required for business or legal purposes, and such purposes may vary according to the circumstances.

8.2We 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.         Links to Third Party Websites

We may provide links to websites and resources operated or provided by third parties, including for example our business partners, with different privacy practices ("Third-Party Websites"). When you use a link online to visit a Third-Party Website, you will be subject to that Website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third-Party Website before providing any information on that Website.

10.Visiting Our Platform from Outside Singapore

If you are visiting our Platform from outside Singapore, please be aware that your information may be transferred to, stored and processed in Singapore where our servers are located and our central database is operated. The data protection and other laws of Singapore and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your privacy is protected. By using our services or by accessing the Platform, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy.

11.       European Union Privacy Rights

11.1Under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an individual protected by the GDPR you may have certain rights in relation to the Personal Data we hold about you, which we set out below.

These rights include:

(a)   The right of access.

(b)   The right of data portability.

(c)    The right of rectification.

(d)   The right of erasure.

(e)   The right to restrict processing.

(f)     The right to object.

11.2To request information about or avail yourself of the above rights, please send an email to enquiries@spryx.co with "GDPR Request" in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that we reserve the right to charge a fee with respect to certain requests. Upon completion of our review, you will be notified if your request has been granted, denied, or exemptions apply.

The Right of Access

11.3You have the right to know whether we process Personal Data about you, and if we do, to access Personal Data we hold about you, how we use it and who we share it with. If you require more than one copy of the Personal Data we hold about you, we may charge an administration fee.

11.4We may not provide you with certain Personal Data if providing it would interfere with another’s rights (eg. where providing the Personal Data we hold about you would reveal information about another person) or where another exemption applies.

The Right of Data Portability

11.5You have the right to receive a subset of the Personal Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party. The relevant subset of Personal Data is data that you provide us with your consent.

11.6If you require us to transfer the Personal Data to a third party, please provide us with relevant details of that third party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. You understand that we may not provide you with certain Personal Data if doing so would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).

The Right of Rectification

11.7You have the right to correct any Personal Data held about you that is inaccurate by logging into your account or contacting us at enquiries@spryx.co.

The Right to Restrict Processing; The Right of Erasure

11.8You may request that we stop processing the Personal Data we hold about you (other than for storage purposes) and/or erase the Personal Data we hold about you in the following circumstances:

(a)you believe that it is no longer necessary for us to hold the Personal Data we hold about you;

(b)we are processing the Personal Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the Personal Data;

(c)we are processing the Personal Data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Personal Data;

(d)you no longer wish us to use the Personal Data we hold about you in order to send you any marketing and/or promotional materials; or

(e)you believe the Personal Data we hold about you is being unlawfully processed by us.

11.9Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., for the defence of legal claims or freedom of expression) and we will inform you in writing if that is the case. Please note that after acceding to your request and/or deleting the Personal Data, we may not be able to provide the same level of services to you due to a lack of information.

11.10To exercise any of your rights under this section, please log into your account or contact us at enquiries@spryx.co.

The Right to Object

11.11At any time you have the right to object to our processing of Personal Data about you by contacting us at enquiries@spryx.co. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.

12.Changes to Privacy Policy

We will occasionally update this Privacy Policy to reflect changes in our practices and services. If we make any material changes in the way we collect, use, and/or share personal data that may impact you, we will notify you by sending an e-mail to the e-mail address you most recently provided us in your account, profile or registration (unless we do not have such an e-mail address), and/or by prominently posting notice of the changes on the Platform. We recommend that you check our Platform from time to time to inform yourself of any changes in this Privacy Policy or any of our other policies. All communications, transactions and dealings with SL2 will be subject to the latest version of this Privacy Policy in force at the relevant time.

 

This Privacy Policy was last updated on 20 March 2023.