Last updated: 06 June 2017

This Privacy Policy applies to majority of our websites / applications / platforms / software / technology platforms / services (collectively “Aleph Properties“) and the information collected during your access of any of the Aleph Properties. However, there may be occasions where there is a need to have a slightly different privacy policy. Whenever any of the Aleph Properties have a different privacy policy it will be made clear that the privacy policy differs from this general Aleph Privacy Policy.

The information which is collected across Aleph Properties is controlled by The Aleph Group PTE Limited (“Aleph”), a company registered in Singapore and is further subject to the Terms of Service as made available on https://culturemachines.com/?page_id=6209.

Special Notice: Aleph Properties are not aimed at children under 13 years of age and we will not collect, use, provide or process in any other form any personal information of children under the age of 13 deliberately.

We therefore also ask you, if you are under 13 years of age, please do not send us your personal information (for example, your name, address and email address). If you are under 13 years of age and you nevertheless wish to ask a question or use this website in anyway which requires you to submit your personal information please get your parent or guardian to do so on your behalf.

INFORMATION COLLECTED: PERSONAL DATA

Aleph is committed to compliance with all applicable county- specific data privacy laws. Protecting the privacy and security of your personal data is of highest importance to Aleph. Personal data (such as your name, phone number, email address, billing information etc) is collected across Aleph Properties on various instances including, without limitation:

Registration: if you open an account with us, sign into any of the Aleph Properties with a Google/YouTube/Facebook account using your existing applicable login credentials or create a new account on any of the Aleph Properties to purchase products or services, send us an email, leave comments or share personal information with us, with your express consent, we collect this information. This obviously depends on what information you choose to provide but it may include your login credentials meant to log into a third-party platform such as Facebook etc. You do not have to share this information with us, but without it you may not be able to access certain content, features or service on the Aleph Properties. We use this information for business purpose and to operate and provide Aleph’s services.

Requested Information: if you submit an inquiry or similar function on the Aleph Properties, any information you provide, including any contact name, address, email address, telephone number, financial information, etc., will be used by Aleph in order to respond to such inquiry or request and may be archived by us indefinitely for future reference.

Blog Posting/ General Posting: if you post comments on the blog, or on any public areas across Aleph Properties (or elsewhere on the internet) that information may be collected and used by anyone, including Aleph. (We strongly recommend that you do not post any information that allows strangers to identify or locate you. Posting such information may result in unsolicited and unwanted contact from others, to say the least.)

Subscriptions: You may provide an email address or other contact information or otherwise interact with Aleph Properties in order to commence receiving a subscription-based function or service, such as a newsletter or mailing.

INFORMATION COLLECTED: NON-PERSONAL DATA

When you access any of the Aleph Properties, we may automatically (i.e. not by registration) collect non-personal data (e.g. type of internet browser and operating system used, domain name of the website from which you were directed, average time spent on sites, pages viewed).

In order to tailor our communications with you to make sure that we are addressing your specific needs and not overwhelming you with unwanted information, we use cookies to handle propensity management. A cookie is a piece of information that is stored on your computer’s hard drive by your web browser. Dependent on the settings of the device or web-browser this data may be stored on the user’s device so that the device can later return that data to the same website. Cookies can be used by online services, such as websites or ad technologies, to recognize an Internet- or mobile-connected device that they have encountered before.

Like most web businesses, we use automated mechanisms (eg, cookies and/or pixels) to keep track of user interactions with our Aleph Properties. We collect information such as your internet protocol address, browser type and access times. We also use third party services such as Google Analytics to gather and analyse your user information to learn more about the way you interact with our content and help us to improve your experience when visiting the Aleph Properties.

We will not use cookies to collect personally identifiable information about you. However, should you wish to do so, you can choose to reject or block the cookies set by Aleph or the websites of any third-party suppliers by changing your browser settings – see the Help function within your browser for further details. Please note that most browsers automatically accept cookies so if you do not wish cookies to be used you may need to actively delete or block the cookies. Note, however, that if you reject the use of cookies you will still be able to visit our websites but some of the functions may not work correctly.

PURPOSE OF COLLECTION OF DATA

This Privacy Policy is meant to help you understand what information we collect, why we collect it, how we use that information and the choices we offer, including how to access and update information.

We would therefore use your personal information in order to:

  1. respond to queries or requests submitted by you
  2. process orders or applications submitted by you 
  3. administer or otherwise carry out our obligations in relation to any agreement you have with us
  4. anticipate and resolve problems with any goods or services supplied to you
  5. create products or services that may meet your needs.

To optimise our services we may wish to use your personal data for direct marketing. As we respect your privacy we will only use your personal data for this purpose when you are aware thereof and if required we will request your consent prior to using your personal data for direct marketing.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We respect the confidentiality of the personal data you have provided to us. However, please note that we may disclose your personal data which is required based on the applicable law and/or regulations to certain third parties without first obtaining your consent in certain situations. Like most websites, third parties may also directly gather user information through automated means such as cookies. For example, companies who place ads on the Aleph Properties may drop their own cookies on the computers of users who view their ads. This Privacy Policy does not cover how third parties gather and use such data. For all other instances of disclosure of personal data to third parties with your express consent, we will provide for adequate forms of protection over such personal data and confidentiality and security in the handling and administration of your personal data by such third parties in compliance with the Singapore Personal Data Protection Act 2012 (PDPA).

Service Providers: Aleph uses other companies, agents or contractors (“Service Providers“) located across the world to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, infrastructure and IT services, to personalize and optimize our service, to process credit card transactions or other payment methods, to provide customer service, to collect debts, to analyze and enhance data (including data about users’ interactions with our service), and to process and administer consumer surveys. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services to us.

Promotional offers: Aleph may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.

Protection: Aleph and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Aleph, its users or the public, as required or permitted by law.

Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.

In addition, the Services may contain links to third party websites and content. Aleph does not control these websites and/or content and these third parties’ privacy policies may be different from our own. You access linked websites or third-party content at your own risk.

SECURITY/STORING OF INFORMATION

Any information collected by Aleph is stored on servers that Aleph manages, using standard security procedures and practices appropriate to the nature of the information. No data transmission over the internet can be guaranteed to be 100% secure and as a result, Aleph cannot guarantee the security of any information you transmit on or through the Aleph Properties.

Except as otherwise permitted or required or authorised under the Singapore Personal Data Protection Act 2012 (PDPA) or any other written law, we will retain your personal data until it no longer serves the purposes for which it was collected and we no longer require it for legal or business purposes (including legal, accounting, tax or other reporting requirements or obligations). We may, instead of destroying or deleting personal data, make it anonymous so that it cannot be associated with you.

CHANGES TO PRIVACY POLICY

Aleph reserves the right to change this Privacy Policy at any time. If we make any substantial changes to this Privacy Policy and the way in which we use your personal data we will post these changes on this page. It is solely your responsibility to check our Privacy Policy on a regular basis and keep yourself apprised of any new changes if you are accessing/using any of the Aleph Properties.

DISPUTE RESOLUTION

This Privacy Policy is governed by the laws of Singapore. You agree that any action to enforce or adjudicate your rights under this document shall be brought in the courts in Singapore.

CONTACT US

If you have any questions about our privacy practices, please email us at legal@thealephgroup.sg

Additionally, if at any time you wish us to stop using your information for any or all of the above purposes, please contact us as set out above. We will stop the use of your information for such purposes as soon as it is reasonably possible to do so.

Please be assured that we will not use your information for any of the purposes if you have indicated that you do not wish us to use your information in this way when submitting the information or at a later stage.

However, by submitting your personal data to us, you will be treated as having given your permission – where necessary and appropriate – for disclosures referred to in this policy.

ADDITIONAL NOTE

Our properties may feature Nielsen proprietary measurement software, which will allow you to contribute to market research, such as Nielsen TV Ratings. To learn more about the information that Nielsen software may collect and your choices with regard to it, please see the Nielsen Digital Measurement Privacy Policy at http://www.nielsen.com/digitalprivacy.