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Fresh Online Privacy Policy
for SPOTEE.io

Fresh Online Pte Ltd (Singapore) are the owners and operators of SPOTTE.io and the RabbitSpeaks mobile apps. This document declares the undertakings by Fresh Online in relation to its handling of your personal information.

Data Collection
Fresh Online undertakes to collect your personal information by means that are: fair, legal; and transparent.

If you visit SPOTTE.io, your web-browser automatically discloses, and our web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.

Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.

Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (ie, SPOTTE.io). This data may or may not be sufficient to identify you.

If you disclose personal data on SPOTTE.io in conjunction with an identifier such as your name or your credit-card details, we will collect your personal information. Moreover, any data that becomes available to us through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become your personal information.

Subject to the qualifications immediately below, we undertake to collect your personal information from you and not from other parties. This undertaking is qualified as follows:

  • where we reasonably consider that the protection of our financial interests requires that we gather your personal information from other sources, or from additional sources. This applies in particular where we are seeking information about your creditworthiness;
  • where we reasonably consider that our capability to deliver quality services to you will be materially enhanced by gathering your personal information from other sources. This applies in particular to consumer profile data.

When we collect your personal information from sources other than you, we undertake:

  • to do so only by legal means;
  • to declare to you what sources it uses, and under what circumstances.

We also undertake to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.

Data Security
We undertake to store your personal information in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

We undertake to store your personal information only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.

We undertake to transmit your personal information in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.

We undertake to implement appropriate measures to ensure security of your personal information against inappropriate behaviour by our staff-members and contractors. These include:

  • training for staff in relation to privacy;
  • access control, to limit access to your personal information to those staff and contractors who have legitimate reasons to access it;
  • particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
  • reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
  • declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
  • clear communication of policies and sanctions; and processes to audit, to investigate and to impose sanctions.

Data Use
Use refers to the application of your personal information by any part of Fresh Online, or any staff-member or contractor of Fresh Online in the course of their work.

We undertake to use your personal information only for:

  • the purposes for which it was collected;
  • such other purposes as are subsequently agreed between Fresh Online and You;
  • such additional purposes as may be required by law. In these circumstances, Fresh Online will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law;
  • such additional purposes as are authorised by law (in particular to protect Fresh Online's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Fresh Online or have committed a breach of the criminal law).;
  • marketing, sales, service and support purposes; and
  • improving the quality of our web site and services.

Comments or materials sent to us, including feedback data, such as suggestions, questions, comments, and any other responses are deemed to be non-confidential. Fresh Online has no obligation with respect to such responses, and we shall be free to use, distribute, reproduce, and publicly display such comments and materials without reference to you personally. We are also free to use any ideas, concepts, know-how or techniques contained in such responses for any purpose whatsoever to better your overall experience.

We undertake to use your personal information only if it has demonstrable relevance to the particular use to which it is being put.

We also undertake to use your personal information in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.

Data Disclosure
Disclosure refers to making your personal information available to any party other than Fresh Online and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.

Fresh Online undertakes to disclose your personal information only under the following circumstances:

  • in the course of business being conducted between You and Fresh Online, where disclosure to a third party is necessary, such as a supplier of third party products to our site. Where your personal information is disclosed in this way, Fresh Online undertakes to exercise control over Fresh Online's suppliers and contractors to ensure that their actions are compliant with these Terms;
  • in other circumstances that are directly implied by the purpose agreed between You and Fresh Online at the time of data collection or subsequently. Where your personal information is disclosed in this way, Fresh Online undertakes to exercise control over Fresh Online's contractors to ensure that their actions are compliant with these Terms;
  • with your consent, or at your request;
  • where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, Fresh Online will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
  • where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Fresh Online believes on reasonable grounds that the disclosure of your personal information will materially assist in the protection of the life of health of some person), provided that Fresh Online will apply due diligence to ensure that the exercise of the permission is justifiable.

In all cases, we undertake to disclose only such of your personal information as is necessary in the particular circumstances.

Data Retention and Destruction
Subject to the qualifications immediately below, Fresh Online undertakes:

  • to retain your personal information only as long as is consistent with its purpose; and
  • to destroy your personal information when its purpose has expired, and to do so in such a manner that your personal information is not subsequently capable of being recovered.

This undertaking is qualified as follows:

  • your personal information may be retained in Fresh Online's logs, backups and audit trails within short-term retention cycles that are devised to protect the company's operations. In such cases, your personal information will be destroyed in accordance with those cycles;
  • your personal information may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena, or a warning by a law enforcement agency that delivery of a court order is imminent.

In these circumstances, Fresh Online:

  • will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and
  • will only retain your personal information while that provision is current, and will then destroy your personal information;
  • your personal information may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect Fresh Online's interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Fresh Online or have committed a breach of the criminal law). In these circumstances, Fresh Online will only retain your personal information while that situation is current, and will then destroy your personal information.

Access by You to Your Personal Data
Fresh Online undertakes to provide you with access to your personal information, subject to only such conditions and processes as are reasonable in the circumstances. In particular, we undertake to enable access:

  • conveniently;
  • without unreasonable delay; and
  • without cost.

We also undertake to establish and operate identity authentication protections for access to your personal information that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Fresh Online (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.

In the event that you dispute some aspect of your personal information, we undertake to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.

You undertake:

  • not to seek access for frivolous purposes, or unreasonably frequently;
  • to accept that deletion of some data may not be consistent with the provision of particular services by Fresh Online to you.

Information about Data-Handling Practices
Fresh Online undertakes to make information available to you about the manner in which we handle your data:

  • in general terms, in a readily accessible manner; and
  • in more specific terms, on request.

Where your personal information is disclosed to a contractor, we undertake to make information available to you on request about the manner in which our contractors handle your data. We also undertake to ensure that the information provided is meaningful, and addresses your concerns.

You undertake:
Not to seek such information for frivolous purposes, or unreasonably frequently;

and

to accept that the disclosure of excessive detail may harm the security of your personal information and Fresh Online's business processes and commercial interests.

Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about Fresh Online's behaviour in relation to these Terms, you undertake to communicate them in the first instance:

  • to Fresh Online Pte Ltd (Singapore) only;
  • in sufficient detail;
  • through a channel made available by Fresh Online for that purpose.

Fresh Online undertakes:

  • to provide one or more channels for communications to Fresh Online, which are convenient to users;
  • to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and Fresh Online's reference-code for the communication;
  • to promptly provide a response to the communication, in an appropriate and meaningful manner.

You further undertake to not pursue Fresh Online through any Regulator or the media:

  • until and unless Fresh Online has had a reasonable opportunity to respond to the initial communication; and
  • while Fresh Online and you remain are conducting a meaningful dialogue about the matter.

Enforcement
Fresh Online declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under appropriate laws in appropriate jurisdictions. These include laws relating to data protection, privacy, fair trading, corporations and criminal laws.

You undertake to seek enforcement only in a jurisdiction that is relevant to the transactions that have taken place between You and Fresh Online, in particular the jurisdiction in which you live or in which you performed the relevant acts, and the jurisdiction in which Fresh Online is domiciled or performed the relevant acts.

Changes to These Privacy Undertakings

Fresh Online undertakes:

  • not to materially change these Terms in a manner that reduces the protections for your personal information;
  • to take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to your personal information in a manner that reduces the protections for your personal information;
  • where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organisations;
  • where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
  • to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.

Other definitions
Your Personal Information means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name, customer number, phone number, email address, postal address and MAC address. In particular, it encompasses all data that Fresh Online is capable of correlating with you, using such means as server-logs and cookie-contents.

Your personal information does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation.

Consent means your concurrence with an action to be taken by Fresh Online. Consent may be express or implicit, but in either case must be informed and freely-given.

How to contact us
If you have any queries or complaints in regard to our collection, use or management of your personal information, please contact us at:

By Mail
Privacy Officer
Fresh Online Pte Ltd
30 Cecil Street #19-08
Prudential Tower
Singapore 049712

By Email:
privacy@freshonline.sg





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