Castlery Privacy Policy

Last updated on October 20, 2024

Castlery Pte Ltd (Singapore Registered Company (UEN) 201327477H) is committed to protecting your personal data.

This policy sets out the basis on which any personal data we collect from or about you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Information collection

In order to provide a better service to you, we may collect and process the following data about you:

• Information that you provide us, for example, on our website https://www.castlery.com/sg, or social media channels ("our Sites"). This includes information provided at the time of registering to use our Sites, subscribing to our service, posting material or requesting further services. We may also ask you for information at other times, for example in connection with a promotion or when you report a problem with our Sites;

• Contact information, such as name, address, contact number, and email address;

• Housing information such as household size and type of home;

• Billing information such as billing address and credit card information;

• Date of birth and details of any membership you may have with us;

• If you contact or correspond with us e.g., on email, SMS or instant messaging apps such as WhatsApp, we may keep a record of that correspondence;

• We may also ask you to complete surveys that we use for research purposes, or to improve our services, Sites, and overall customer experience, although participation is voluntary and you do not have to respond to them;

• Details of transactions you carry out through our Sites and of the fulfilment of your orders or requests;

• Details of your visits to our Sites and the resources that you access, such as contact and demographic information, behaviour, location data and transaction history.

• Information that you may post in a public space on our Sites, social media pages, including when you create a public profile, give us a rating or review, or communicate with an influencer who then shares that information with us.

We do not seek to collect your sensitive personal data such as your national identification number or details about your private life, but if and when we do we will always be in compliance with applicable laws, including obtaining your consent and notifying you about the purposes of our collection and use.

We only retain personal data for so long as it is necessary. Data may be kept as long as the purpose for which the data was used still exists or where we have a legal or business need for doing so.

Uses made of the information

The purposes for which information may be used by us include:

• Communicating with you;

• Verifying your identity;

• Processing and providing products and services to you;

• Carrying out our obligations arising from any contracts entered into between you and us;

• Processing payments (including refunds) relating to our products or services;

• Responding to your requests, enquiries or complaints;

• Ensuring that content from our Sites is presented in the most effective manner for you and for your device(s);

• Providing you with alerts, newsletter, education materials or information that you requested or signed up to;

• Allowing you to participate in interactive features of our service, when you choose to do so;

• Designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;

• Resolving any issues or disputes in which we are involved;

• For audit, risk management and security purposes;

• For detecting, investigating and preventing fraud or illegal activities;

• For enabling us to perform our legal obligations or enforce our legal rights;

• For legal proceedings, including collecting overdue amounts and seeking professional advice;

• Researching, designing and launching services or products including seminars/events/forums;

• Promoting and marketing services and products subject to any applicable opt-outs;

• To send invitations to and organise events, promotions and product launches; purposes directly related or incidental to the above.

• We may with your consent conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. The following classes of services, products and subjects may be marketed to you:

• Services and products related to our Sites and/or our affiliates (including marketing affiliates programs we are a part of);

• Reward, loyalty or privileges programmes, promotional offers and related services;

• Invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.

You may opt out of direct marketing by notifying us that you wish to withdraw your consent to such use of your personal data for these purposes. Please utilise the opt-out function in any direct marketing or send your requests, questions or complaints to us on our Contact Us page.

Disclosure of your information

We may provide personal data we hold or collect about you to:

• Our personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;

• Our offices, affiliates, business partners and counterparts (if any);

• Persons under a duty of confidentiality to us;

• Government regulators or authorities;

• Employment agencies or other persons in connection with your application for employment with us.

Where any of these recipients are overseas, we will comply with applicable laws with respect to such disclosures or transfers.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Our Sites and third parties that we authorize use cookies and other tracking technologies (such as pixels, web beacons, tags, session replay tools, embedded scripts, and SDKs) to collect Personal Data from you, as described in the “Personal Data We Collect” section above. We use this information to analyze how you use the Sites, personalize and improve your experience on our Sites, provide you with advertising, and measure and improve the effectiveness of our advertising campaigns.

By continuing to browse the Sites, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies.  These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control and which are governed by these third parties’ privacy policies. These cookies are likely to be analytical/performance cookies or targeting cookies.

We may use the following third party web analytic services on the website. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse how visitors use the website. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. These analytic services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

• Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google's ability to use and share information collected by Google Analytics is in accordance with their policies: http://www.google.com/policies/privacy/partners/

You can prevent Google's collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Sites.

Security

All information you provide to us is stored on our servers which we have put in place security for. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data transfers

We may hold your data on servers in the United States, Australia, Singapore and any other territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any people listed under ‘Disclosure of Your Information’, who may be located in or outside of Singapore, including the United States and Australia.

Your consent and rights

By transacting or communicating with us, using our service, making an application or visiting our website, you consent to the processing of your personal data or other information you provide us as outlined in this policy.

Under and subject to applicable data protection laws, you may have the right to:

• Check whether we hold personal data about you and how we are using it, and to access such data;

• Update or correct such data where this is inaccurate;

• Withdraw your consent to the use of your personal data for marketing purposes.

In accordance with applicable data protection laws, we may have the right to and may charge a reasonable fee for processing any data access request.

To request for withdrawal of consent or to request for deletion of your personal data, please contact us through the Contact Us link below.

You understand that your withdrawal of consent may result in certain consequences; for instance, we may no longer be able to provide you with our products or services that you have requested or to continue with your existing relationship with us. Further, you understand that notwithstanding your withdrawal of consent, we will still be entitled to process your personal data if we are required or authorised to do so under any applicable law.

EVENT PHOTOGRAPHY AND RECORDING

You may be photographed, audio-recorded and video-recorded at any event organised by or in which Castlery is participating. By participating the event, you consent to interview(s), photography, audio recording, video recording and its/their release, publication, exhibition, or reproduction to be used for news, web casts, promotional purposes, telecasts, advertising, inclusion on web Sites, or for any other purpose(s) that Castlery, its vendors, partners, affiliates and/or representatives may indicate to you in a notice.

Minors

Our Sites are intended for adult users over the age of 18. If you are under 18, you should stop using our Sites unless you have the express permission and consent of your parent or legal guardian. Our Sites are not designed to attract child users and we do not knowingly collect personal data directly from child users. If we discover that an under-14 user has provided their personal data on our Sites without parental consent, we will take all reasonable measures to delete the information as soon as possible and to not use such information for any purpose, except where necessary to protect the safety of the child or others as required or allowed by law.

DATA PROTECTION OFFICER

If you have any questions or concerns about how we are handling personal data, please contact our Data Protection Officer at dpo@castlery.com.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page.