For the purposes of this the Policy, please note that:
a. “Serl.io” refers to Serl.io Pte Ltd and its related corporations
b. “We / Our / Ours / Us” refers to Serl.io and its respective officers, servants or agents whether situated in or outside of Singapore
c. “Services” refers to the Serl.io products and services you have applied for or are using, including but not limited to Mixed Reality services, software, products and support provided by Serl.io
Personal Data in this Policy includes any data about an individual who can be identified from that data such as the individual’s name, email, phone number, address, and other information obtained or received
How We Use Your Personal Data
1. We may collect, use and disclose Personal Data for one or more of the following purposes:
a. to establish your identity and background to prevent fraud
b. processing an application for any products or services offered or distributed by us (including but not limited to third party products)
c. providing products and services requested by you
d. generating marketing, regulatory, management, statistical or other related reports and performing analytics
e. meeting or complying with our (or our affiliated third party organisation’s) internal policies and procedures and any applicable laws or court orders
f. legal purposes
g. handling complaints or feedback
h. facilitating proposed or actual assignment, transfer, participation or sub-participation in an of our rights or obligations in respect of your relationship with us
i. for any insurance claim or proposal that requires disclosure of your personal information
j. (with your consent) for our direct marketing and business development to you (including but not limited to third party products). You may withdraw your consent to this at any time
k. to process transactions and payments
l. to allow us to improve our services to you, enhance the user experience and functionality of our products
m. conducting market research, surveys and data analysis relating to any service or product provided by us (whether or not conducted jointly with another party) which may be relevant to you
n. other purposes which are reasonably related to the purposes above.
2. Where you apply for or hold a product or service which is jointly offered by Serl.io and a co-brand partner, Serl.io may also collect, use and disclose your Personal Data for the purpose of sharing it with the co-brand partner to legitimately provide the services in conjunction with the purposes outlined in Clause 1 above.
Disclosure of Your Personal Data
3. We may disclose Personal Data to:
a. Co-branded partners of Serl.io and related or trusted third parties
b. Our insurers
c. Employees, officers and agents of Serl.io located within and outside Singapore to assist us in providing the Services
4. We will otherwise treat such Personal Data as private and confidential and apart from the parties stated above, we will not disclose such data to any other party except:
a. where permission has been given by the individual
b. where we are required or permitted to do so by law
c. where required or authorised by any court order
d. where we are required to meet our obligations to any relevant regulatory authority
Security of Personal Data
5. Serl.io takes breaches of privacy very seriously. Our employees and contractors are trained to handle the personal data securely and with utmost respect and confidentiality, failing which they may be subject to disciplinary action. Employees and contractors of Serl.io located outside Singapore are contractually obligated to keep secure any personal data they may handle.
6. We store Personal Data in secure computer storage facilities and paper-based files and other records and take reasonable steps in the circumstances to protect the personal information we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will delete all details that identify the individual and/or destroy all records of such Personal Data.
Accuracy of Personal Data
7. We take reasonable steps to ensure that all Personal Data is up-to-date and accurate and recognise that contact details and other data may change frequently. Please keep us advised of any changes in information.
8. If you wish to delete their Personal Data held with us, please contact our Data Protection Officer. Serl.io may retain certain information about individuals where required to do so by law.
Rights to Access and Correct Personal Data
9. We can assist you to access and correct Personal Data held by us.
10. To make a request to access Personal Data, or where you are of the opinion that such Personal Data held by us is inaccurate, incomplete or misleading, the individual to which that data relates will need to complete an application form which sets out what Personal Data is required and verifying their identity. Please contact us for the application form or further information about how to access your Personal Data.
11. Please note that we may have to withhold access to Personal Data in certain situations, for example when we are unable to confirm the identity of the person requesting the data.
12. An individual may request that we correct the Personal Data we hold about them if they deem it to be inaccurate, incomplete, out-of-date, irrelevant or misleading. We will take reasonable steps to correct the information as soon as practicable and send the corrected personal information to other organisations in accordance with the Personal Data Protection Act 2012
13. If you do not agree with this Policy, please DO NOT continue to use or access the Services.
14. By disclosing Personal Data to us or continuing to utilise the Services you are deemed to:
a. agree with this Policy and consent to the purposes above for which we collect and use your Personal Data; and
b. have provided your clear and unambiguous consent to being contacted by us or our affiliates on your telephone number in relation to marketing or other purposes, notwithstanding any listing on the Do Not Call Registry.
15. You may withdraw your consent at any time by providing us with a notice in writing.
16. At any point whilst Serl.io is in possession of or processing your Personal Data, you have following rights:
a. Right of access – you have the right to request a copy of the information that we hold about you.
b. Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
c. Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
d. Right to restriction of processing – where certain conditions apply you have a right to restrict the processing of your Personal Data
e. Right of portability – you have the right to have the data we hold about you transferred to another organisation.
f. Right to object – you have the right to object to certain types of processing such as direct marketing.
g. Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling. Serl.io at your request in writing can confirm what information it holds about you and how it is processed.
17. You can request the following information
a. The purpose of your data processing as well as the legal basis for the processing.
b. If the data processing is based on the legitimate interests of Serl.io or a third party, information about those interests.
c. The categories of Personal Data collected, stored and processed.
d Recipient(s) or categories of recipients that the data is/will be disclosed to.
e. How long your Personal Data will be stored.
f. Details of your rights to correct, erase, restrict or object to such processing.
g. Information about your right to withdraw consent at any time.
h. How to lodge a complaint
i. Whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
j. Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing
Data Protection Breach
18. Should there be a data breach; Serl.io will inform the relevant governing authority within 72 hours. The information provided will include:
a. What has happened
b. When and how we found out about the breach;
c. The people that have been or may be affected by the breach;
d. What we are doing as a result of the breach
a. to improve the user experience on the website;
b. to assist us in monitoring the performance of the website;
c. to remember your preferences;
d. to monitor traffic on the website;
e. to assist the website in functioning properly.
21. You can disable or enable cookies through your web browser settings. If you disable or block the cookies on our website, you may not be able to access the entire scope of functions ordinarily performed by our website.
22. Personal Data that we collect from you through our cookies may be passed onto third party service providers (whether within or outside Singapore), for managing or improving our website, for data hosting or backup or for one or more of the purposes set out in paragraph 20 above.
Enquiries, Requests and Complaints
24. For enquiries, requests and complaints regarding Personal Data, please contact us at [email protected]. Alternatively you may contact us through the Contact Us Form on our website.