We, FYA Media Pte. Ltd., care about the privacy of our customers, thus, we provide this privacy notice to inform our customers of our policy in relation to the collection, use and disclosure (collectively "Process", and "Processing" shall be construed accordingly) of personal data ("Data") of individual (“you”) in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”), relevant laws and regulations. This privacy notice informs you of how we collect, use or disclose your personal data, what and why we collect, use or disclose your personal data, how long we hold it, who we disclose it to, your rights, what steps we will take to make sure your personal data stays private and secure, and how you can contact us when you use the services provided by FYA Media ("Services"). This Privacy Policy applies to both the “online” (e.g., web and mobile services) and “offline” (e.g., collection of Data through telephone or in person) activities owned, operated, provided, and/or made available by FYA Media.

This Privacy Policy specifically addresses our obligations in respect of personal data privacy under the Relevant Laws. Where practicable, FYA Media undertakes to also apply the principles and the processes set out in the Relevant Laws to its operations globally. If FYA Media's operations are subject to privacy legislation other than that of the Region, then this Privacy Policy will apply so far as practicable and consistent with such legislation.

‍BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR DATA, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY AND GIVE US YOUR CONSENT TO PROCESS YOUR DATA. We request all persons using the Services to voluntarily provide us with the Data as per the privacy policy set out below. Do not use the Services or give us any of your information if you do not agree to the terms of this Privacy Policy. However, FYA Media will not be able to provide Services to you if you do not provide such Data.

If you wish to revoke your agreement to the terms of this Privacy Policy, please notify us by sending an email to our Data Privacy Officer in accordance with section 11 below or via any other means as prescribed by us from time to time. This Privacy Policy is an integral part of our Terms and Conditions. We may update or change this Privacy Policy from time to time to reflect our latest privacy policies and practices as it deem fit. Any changes will be effective immediately upon posting of the revised Privacy Policy. If FYA Media makes material changes, we will notify you by means of a notice on the Platform. We recommend that you review our Privacy Policy regularly for information about our latest privacy policies and practices. Your continued access or use of the Services after such updates, changes, or notice, as applicable, constitutes your consent to be bound by the then-current Privacy Policy.

‍1. What Data we collect, use or disclose
‍The type of personal data, namely personal data and sensitive personal data, which we collect, use or disclose, varies on the scope of products and/or services that you may have used or had an interest in. The type of personal data shall include but not limited to: your name, your email, your telephone number, and/or other contact details, employment details such as your job title and employer, market research, marketing and sales information such as communication preferences and content of yoru communications with us, geographic information and information about your device and your software such as IP address, device ID and type, your usage details, cookies information and other information such as records of correspondence and other communications between you and us, in whatever manner and form, including but not limited to phone, email, live chat, instant messages and social media communications.
You understand and acknowledge that this Privacy Policy may not apply to any unsolicited information you provide to us through the Services or through any other means in certain regions where FYA Media operates. Where applicable, all unsolicited information shall be deemed to be non-confidential and FYA Media shall be free to Process, reproduce, disclose and distribute such unsolicited information to others without limitation or attribution.

‍2. How we use your Data
The purposes for our Processing of Data on the Services (“Purposes”) include the following:
a) To verify your identity;
b) to provide the Services to you, including processing any quotations or invoices;
c) to operate, protect, improve and optimize the Services;
d) to notify you about changes to the Services or respond to any communication and/or request from you;
e) to monitor the use of the Services;
f) to investigate any reported incidents, complaints, or potential breaches of the Services;
g) where applicable and subject to compliance of the Relevant Laws, to provide you with marketing and promotional materials and messages;
h) to identify whether you have enjoyed promotional benefits by receiving and using marketing and promotional materials;
i) to compile aggregate statistics about you and to analyze the Services usage
j) where applicable and subject to compliance of the Relevant Laws, to match the Data with other Data collected for other purposes and from other sources including third parties in relation to the provision of Services to you;
k) to facilitate our Processing of the Data for purposes relating to the provision of Services offered by us and marketing services, special events, and/or promotions of us and/or our clients.
l) to comply with our obligations under the applicable laws and regulations;
m) to disclose to and/or assist relevant authorities where we suspect you have committed an offense, where we suspect existence of fraud or when required by the relevant laws or court orders, or as requested by relevant public and law enforcement authorities.
We will seek your express consent to change how we Process the Data if required by the Relevant Laws, but otherwise use of the Services following such changes constitutes your acceptance of the revised statement then in effect.

‍3. How we share your Data
We may disclose your personal data to the following parties under the provisions of the PDPA:
a) Our business partners, target companies and/or other persons that we have the legal relationship, including our directors, executives, employees, staffs, contractors, representatives, advisors and/or such persons’ directors, executives, employees, staffs, contractors, representatives, advisors;
b) governmental authorities and/or supervisory or regulatory authorities;
c) suppliers, agents and other entities (e.g. professional associations to which we are member, external auditors, depositories, document warehouses where the disclosure of your personal data has a specific purpose and under lawful basis);
d) any relevant persons as a result of activities relating to selling rights of claims and/or assets, restructuring or acquisition of any of our entities, where we may transfer their rights to; any persons with whom we are required to share data for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business;
e) third parties providing services to us (e.g. IT service providers, market analysis and benchmarking);
f) social media service providers (in a secure format) or other third-party advertisers so they can display relevant messages to you and others on our behalf about our products and/or services. Third-party advertisers may also use information about your previous online activities to tailor adverts to you;
g) other persons that provide you with benefits or services associated with your products or services;
h) our corporate customers as you are director, promoter, authorised person, attorney, representative or contact person; and/or authorized power.

‍4. Sources of your Data
Normally, we will collect your personal data directly from you (e.g. through our web applications, your emails to us and customer support), but sometimes we may get it indirectly from other sources (e.g. social media, third party’s online platforms, and other publicly available sources) and through FYA Media, our affiliates, service providers, business partners, counterparties, target companies, official authorities, or third parties (e.g. your representative, employer, sponsor and third parties that have roles in delivering services to you or someone acting on their behalf may provide us with information about you), and from our corporate customers as you are director, promoters, authorised person, attorney, representative or contact person; in such case we will ensure the compliance with the PDPA.‍

‍5. Your Rights
The PDPA aims to give you more control of your personal data. You can exercise your rights under the PDPA upon the effectiveness if the provisions in relation to rights of data subjects, details are as follows:
4.1 Right to access and obtain copy
You have the right to access and obtain copy of your Data holding by us, unless we are entitled to reject your request under the laws or court orders, or if such request will adversely affect the rights and freedoms of other individuals.
4.2 Right to rectification
You have the right to rectify your inaccurate Data and to update your incomplete Data.
4.3 Right to erasure
You have the right to request us to delete, destroy or anonymise your Data, unless there are certain circumstances where we have the legal grounds to reject your request.
4.4 Right to restrict
You have the right to request us to restrict the use of your Data under certain circumstances (e.g. when we are pending examination process in accordance with your request to rectify your Data or to object the collection, use or disclosure of your personal data, or you request to restrict the use of Data instead of the deletion or destruction of personal data which is no longer necessary but you ask us to restrict it instead as you have necessity to retain it for the purposes of establishment, compliance, exercise or defense of legal claims).
4.5 Right to object
You have the right to object the collection, use or disclosure of your Data in case we proceed with legitimate interests basis or for the purpose of direct marketing, or for the purpose of scientific, historical or statistic research, unless we have legitimate grounds to reject your request (e.g. we have compelling legitimate ground to collect, use or disclose your Data, or the collection, use or disclosure of your Data is carried out for the establishment, compliance, or exercise legal claims, or for the reason of our public interests).
4.6 Right to data portability
You have the right to receive your Data in case we can arrange such Data to be in the format which is readable or commonly used by ways of automatic tools or equipment, and can be used or disclosed by automated means. Also, you have the right to request us to send or transfer your Data to third party, or to receive your personal data which we sent or transferred to third party, unless it is impossible to do so because of the technical circumstances, or we are entitled to legally reject your request.
4.7 Right to withdraw consent
You have the right to withdraw your consent that has been given to us at any time pursuant to the methods and means prescribed by us, unless the nature of consent does not allow such withdrawal. The withdrawal of consent will not affect the lawfulness of the collection, use, and disclosure of your personal data based on your consent before it was withdrawn.
4.8 Right to lodge a complaint
You have the right to make a complaint with the Personal Data Protection Commission or their office in the event that we do not comply with the PDPA.

‍6. How do we protect the Data?
We have adequate measures to protect the Data from unauthorized access, accidental loss, or destruction. Where we have given you (or you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.Unfortunately, the transmission of Data via the Internet is not completely secure. While we endeavor to protect your Data, we cannot guarantee the security of Data transmitted to the Services; any transmission is at your own risk. Once we have received the Data, we will use strict procedures and security features to try to prevent unauthorized access. In case of cybersecurity risks, we may issue warnings and provide instructions to you in accordance with the Relevant Laws.

‍7. Use of Cookies
We may collect and use cookies and similar technologies when you use our products and/or services. This includes when you use our websites and application.The collection of such cookies and similar technologies helps us recognise you, remember your preferences and customise how we provide our products and/or services to you. We may use cookies for a number of purposes (e.g. enabling and operating basic functions, helping us understand how you interact with our websites or emails, or enabling us to improve your online experiences or our communications with you, particularly, to ensure that online adverts displayed to you will be more relevant to you and of your interests).
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‍8. Retention of Data
Once we have obtained the Data, it will be maintained securely in our system; and subject to legal requirements and our internal policy, may be retained by us after deactivation of the relevant Services where such Data is still required for the purpose for which it was Processed.

‍9. Links to third-party websites
Subject to this Privacy Policy, at our discretion, we may include or offer third-party products or services on the Platform. You understand and acknowledge that the fact that we may include or offer third-party products or services on the Platform does not mean that we endorse or authorize the collection of Data by such third parties, nor does it constitute a representation of any affiliation between us and such third parties. You understand and acknowledge that:Once you click on a link to third-party websites, applications, or advertisements, you will access third-party websites, applications, and advertisements which may collect Data.Such third-party websites, applications, and advertisements follow separate and independent privacy policies regarding the Processing of the Data you submit to them.Hence, we have no responsibility or liability for the content and activities of these linked websites, applications, and advertisements (including any Processing of the Data by such third parties). Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these sites.

‍10. Data of minors and/or other individuals
In some circumstances, you may have provided Data relating to minors and/or other individuals and in such circumstances, you represent and warrant that you are authorized to provide the Data to us and you have obtained their consent for the Data to be Processed in the manner as set forth in this Privacy Policy.Where applicable, as a parent or legal guardian, please do not allow the minor(s) under your care to submit the Data to us. In the event that such Data is provided to us, you hereby consent to the Processing of the minor’s Data and personally accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

‍11. Data Privacy Officer contact details
Your requests shall be sent to the Data Privacy Officer by email. Please send your requests to: contact@fyamedia.com.