Effective Date: January 1, 2020
Last Updated: 1st August, 2020
All capitalized terms have their definition in INKR Terms of Service located at: https://inkr.com/terms , unless otherwise noted here.
What is personal data?
Under Singapore's Personal Data Protection Act 2012 (the " PDPA"), " Personal Data" refers to all 'data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access.' This applies regardless of whether such data is in electronic or other form, and regardless of the degree of sensitivity. However, the PDPA expressly excludes the following categories of personal data from its application:
a) 'business contact information,' which is defined as 'an individual's name, position name or title, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes;'
b) personal data that is contained in a record that has been in existence for at least 100 years; and
c) personal data about a deceased individual who has been dead for more than 10 years.
What information do we collect?
INKR may collect the following information from or about you, including Personal Data, from the following sources:
2.1. Information you provide to us: We collect information you provide to us. When you use our Services including creation of your own account, you must provide a username and password, content you submit including your posts and comments, through our Site or participate in the ad revenue sharing program or subscription revenue sharing program, your information including Personal Data such as your name, email address, credit card or other payment method information, address, ZIP code, characteristics such as your age (birth date) and gender etc may be collected by us through your voluntary submission.
2.2. Information we collect automatically: When you interact with us through our Site, we may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to this Site, the number of visitors to each page of this Site, the domain names of our visitors' Internet service providers, and how our users use and interact with our Services. Also, in an ongoing effort to better understand and serve the users of our Services, we often conduct research on our customer demographics, interests and behaviour based on Personal Data and other information provided to us. This research may be compiled and analysed on an aggregate basis. We may share such non-identifiable and aggregate data with our affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes. However, if we combine or connect such non-identifiable or aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy.
2.3. Account and profile data from third party services: If you choose to log-in, access or otherwise connect to our Services, or contact us through a third-party service, we may, for example, collect identifiers including your user ID and user name associated with that service, as well as any information you make public using that service. We may also collect information you have authorized the service to share with us (such as your user ID, billing information, public profile information, email address, birthday, pages you have "liked" and other account and profile data).
2.4. Information from third party sources: We may also collect certain of your Personal Data from third party sources, including our affiliates, marketing partners, analytics providers such as Google Analytics, advertisers, payment processors to evaluate use of the Services or help administer the Services. The information we collect from these third party sources may include information (whether identifiable, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behaviour, and your activities online (such as websites visited and advertisements viewed), payment processing and other billing-related matters.
We collect only relevant and minimal Personal Data limited to what is necessary in relation to the purposes for which they are collected and processed. In this regard, you agree to provide only true, accurate, current and complete information about yourself.
How do we use your information?
3.1. Use in General: We use the information we collect from or about you for the following purposes:
providing of Services, based on your contractual relations with us;
contacting and communicating with you, including for promotions, updates, and notifications;
customizing the Content and advertising you view and evaluating how well the Content and advertising perform;
identifying Content you share;
administering surveys, contests, and other promotional activities or events;
Send you information and prizes for campaigns and events;
customizing recommendations based on your most visited webpages and additional content tailored to your interests;
operating and optimizing the our Services, such as by conducting analytics and research;
protecting your and our rights and complying with legal obligations;
other uses in accordance with our Terms of Service; and
any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.
3.2. Use of payment information: We use payment information, such as credit card numbers and billing ZIP code, and commercial information, when a user purchases a product or uses a Service which is not free. For example, we use payment information to process payments from a subscriber (we use a third-party payment processor to do this), to retrieve account information for a subscriber, to understand how you use the Service and create better revenue sharing programs, to conduct research and development to improve revenue sharing programs, to detect abuse of the Services and to prevent fraud and abuse of our revenue sharing program.
3.3. Use of precise location data: In order to access certain Services from your computer or mobile device, you may be required to share your device's precise location data (e.g., latitude and longitude) with us. This data may also be used to tailor advertising to you based on your location.
How we share the information we collect with third parties?
We disclose personal information about you through the Services as described in the following:
4.1. Service Providers: We may share information with vendors, consultants, and other service providers (including advertisers) who need access to such information to carry out work for us. The service provider's use of personal data will be subject to appropriate confidentiality and security measures. INKR participates in the Digital Advertising Alliance's (DAA) Self-Regulatory Program for Online Behavioural Advertising. For more information please visit http://www.aboutads.info . If you would like more information about this practice and to know your choices about not having this information used by these companies for interest based advertising, please visit http://www.aboutads.info/choices/ .
4.2. To comply with the law: We may share information in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process or governmental request, including, but not limited to, meeting national security or law enforcement requirements. To the extent the law allows it, we will attempt to provide you with prior notice before disclosing your information in response to such a request.
4.3. In an emergency: We may share information if we believe it's necessary to prevent imminent and serious bodily harm to a person.
4.4. _ With our affiliates: _ We may share information between and among INKR, and any of our parents, affiliates, subsidiaries, and other companies under common control and ownership.
4.6. To enforce our policies and rights: We may share information if we believe your actions are inconsistent with our user agreements, rules, or other INKR policies, or to protect the rights, property, and safety of ourselves and others.
4.7. Other parties in connection with transactions: We may disclose your information to a third party as part of an actual or planned merger or transfer, acquisition or sale, or in the event of a bankruptcy.
4.8. With linked services: The Service may provide the ability to connect to other websites, devices, apps and other features, which may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked website, device, app or other feature is not owned or controlled by us, we are not responsible for its content, use or privacy practices.
4.9. Aggregated or de-identified information: We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you.
We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
What are your rights?
We are based in Singapore, however we may process and store information on servers located in Singapore and/or on servers and equipment located in other countries depending on a variety of factors, including the locations of our users and service providers. By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to Singapore and other countries.
To this end and in compliance with the obligations set out in various regulations, your rights in relation to your information will include the following:
6.1. Rights which may be available to you as per Data Protection Act (PDPA) if you are domiciled in Singapore and otherwise (except EU region and California).
a) Right to withdraw consent: You may tell us to stop collecting, using or disclosing your personal data. The organisation should inform you of the likely consequences of your withdrawal before processing the request. However, the organisation is not required to delete or destroy your personal data and may retain it for as long as there are business or legal needs.
b) Request access to your Personal Data: You may request to see the Personal Data that we hold about you. You can also check how your Personal Data has or may have been used or disclosed in the past year. Do note that we may levy an administrative fee for each access request or reject the request if it is considered frivolous. We also cannot grant access if giving you the Personal Data could:
Cause immediate or serious harm to your safety or physical/mental health;
Threaten the safety or physical/mental health of someone else;
Reveal someone else's personal data;
Reveal the identity of the person who provided your personal data; or
Be contrary to the national interest.
c) Request correction of the Personal Data that we hold about you: You may request to correct an error or omission in your personal data that we hold about you. Unless we have a valid reason not to make the correction, we will correct the data and send it to organisations which have received it in the past year; or if you agree, only to specific organisations to which the Personal Data was disclosed.
d) Right to opt-out: You can opt-out of the collection and/or handling of your Personal Data for purposes such as receiving marketing and promotional material from INKR. You can do so at any time by choosing to unsubscribe from electronically-received publications or by contacting INKR via email to [email protected] . If you opt out as mentioned above, you will no longer receive any communications from us in relation to these marketing and promotional offers but you will continue to receive communications from us relating to your membership obligations and rights.
Additional Privacy Notices:
6.2. Rights / additional rights which may be available to you as per The General Data Protection Regulation (GDPR) if you are domiciled in the EU region.
a) Right to withdraw consent (Article 7 GDPR): This right provides you with the ability to withdraw a previously given consent for processing of your personal data for a purpose. The request would then require us to stop the processing of the said personal data that was based on the consent provided earlier.
b) Right to information (Article 13 GDPR): This right provides you with the ability to ask us for information about what Personal Data about you is being processed and the rationale for such processing.
c) Right to access (Article 15 GDPR): You can ask us for confirmation that Personal Data concerning you is or is not processed. You can, if it is processed, ask for access to the said personal data information as well as ask for information related to the treatment, the recipients, the period of conservation.
d) Right to rectification (Article 16 GDPR): This right provides you with the ability to ask for modifications to your personal data in case you believe that your Personal Data is not up to date or accurate.
e) Right to be forgotten (Article 17 GDPR): Also known as right to erasure, this right provides you with the ability to ask for the deletion of your data. It is important to note that this is not an absolute right, and depends on your retention schedule and retention period in line with other applicable laws.
f) Right to object (Article 18 GDPR): This right provides you with the ability to object to the processing of your personal data. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when you ask that your personal data should not be processed for certain purposes while a legal dispute is ongoing in court.
g) Right for data portability (Article 20 GDPR): This right provides you with the ability to ask for transfer of your personal data. As part of such request, you may ask for your personal data to be provided back (to you) or transferred to another controller. When doing so, the personal data can be provided or transferred in a machine-readable electronic format.
h) Right to object to automated processing (Article 21 GDPR): This right provides you with the ability to object to a decision based on automated processing. Using this right, you may ask for your specific request to be reviewed manually, because you believe that automated processing of your data may not consider your unique situation.
6.3. Rights / additional rights which may be available to you in regard to your personal information as per The California Consumer Privacy Act (CCPA) if you are domiciled in California.
a) Right to request information (Article 1798.100 and 1798.115 CCPA): This right provides you with the ability to request for the categories of your personal information and the specific pieces of your personal information that we may have collected.
b) Right of deletion (Article 1798.105 CCPA): This right provides you with the ability to request us to delete any personal information related to you.
c) Facilitation of rights request (Article 1798.130 CCPA): This right provides you with the ability to request a copy of the specific personal information collected about you during the past 12 months.
d) Right to equal services and prices (Article 1798.125 CCPA): We will not discriminate against you for the exercise of these rights.
Period of retention
Personal Data provided by you will be retained and stored as long as the purpose for which the data was required continues, unless you request that we remove your Personal Data in exercise of your rights. Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests. We will however periodically review the data we hold, and erase or anonymise it when we no longer need it.
Privacy of children
If you are an individual who is less than 16 years old (" Child" or " Children"), please do not send us any information or your personal data / information. We do not knowingly collect nor do we wish to collect and personally identifiable information or other user information from Children. In the event that we learn we have collected any personal information from a Child, we will delete the information from our database and terminate the corresponding account, if any.
Governing law and dispute resolution