Last Updated Date: February 2023
“Data Protection Laws” means all applicable laws and regulations in any jurisdictionvwhich relate to the collection, disclosure, use and/or Processing of Personal Data, including without limitation to the PDPA, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
“PDPA” means the Personal Data Protection Act 2012 of Singapore.
"Personal Data" means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which a party has or is likely to have access.
“Process”, in relation to Personal Data, means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation to recording, holding, organising, adapting, altering, modifying, retrieving, combining, transmitting, erasing, or destroying, and “Processing” shall be construed accordingly.
1.2 Any capitalised term not defined herein shall have the meaning ascribed to them in the Agreement.
2. Personal Data we collect about you
2.1 We may collect the following Personal Data about you through the Platform:
(a) Account registration information. This is the Personal Data that is provided by you or collected by us to enable you to create, log into, and access the Platform. We may also use such Personal Data to verify your identity or contact you. This includes your name, email address, phone number, Age, Gender, Location.
(b) Services usage information. This can be Personal Data and other information that is collected about you when you are using the Platform, and this may include:
(i) Information about your interactions with the Platform or Partner Platforms, which includes the date and time of any information you enter into the Platform and/or use the Platform or Partner Platforms. .
(ii) Your interactions with our customer service team.
(iii) Technical data, which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to the Platform, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system.
(c) Your location data. We may collect your location data to provide you with
location-based and traffic-based products and services.
(d) Information from third parties. If you choose to link your account with, or otherwise access the Platform from third party accounts, we may collect your [username and public profile] for that third party account.
3. How we may use your Personal Data
3.1 We may collect, use, disclose and/or Process your Personal Data for any or all of the
(a) To provide you with access to the Platform.
(b) To present offers to you from Advertisers that want to pay full or partially for your access, subscriptions, products, services or wallets.
(c) To Transmit to Advertisers and Partners approved by you on an individual basis per the individual campaign terms and conditions you agree to when accepting each individual offer.
(d) To perform obligations in the course of or in connection with our provision of Platform.
(e) To process, administer, or manage your Account, to verify your identity and to assess your suitability and/or eligibility for the Platform.
(f) To respond to, handle, and process queries, requests, applications, complaints, and feedback from you.
(g) To manage your relationship with us.
(h) To contact you in order to provide you with information or services where required by law or that you request from us.
(i) To analyse and utilise Personal Data in order to present content and information on Platform in the most suitable manner for users and the equipment and devices from which users view the Platform.
(j) To personalise or customise the content and services that we provide to you, including providing you with location-based or traffic-based services.
(k) To process your payments or purchases on the Platform.
(l) To store, host and/or back up Personal Data for disaster recovery purposes, whether within or outside Singapore.
(m) To conduct research, analysis, and development activities (including but not limited to data analytics, surveys and/or profiling) to improve the Platform.
(n) To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims.
(o) To respond to requests for information from public and governmental/regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes.
(p) To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, whether within or outside Singapore.
(q) To transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
(r) To achieve any other incidental business purposes related to or in connection with the above.
3.2 The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
4. With whom we may share your Personal Data
4.1 You acknowledge and agree that Personal Data provided to us by you may be disclosed and/or transferred to the following third parties, and used or Processed by such third parties, whether within or outside Singapore, for the purposes set out above or otherwise permitted/ required by law:
(a) Our Affiliates. We may share your Personal Data with our affiliates that Process Personal Data on our behalf.
(b) Our service providers. We may share your Personal Data with our service providers, including our publishing and advertising partners that have specifically and individually gained your consent at the acceptance of any offer provided on the bounty platform/
(c) Governmental and regulatory authorities. We may share your personal information with third parties, including law enforcement agencies and governmental or regulatory authorities, whether in Singapore or abroad, where required by applicable laws (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with the Platform or where we have another legitimate interest in doing so.
(d) Buyer or successor of our business. We may share your Personal Data with any buyer or successor in the event of a merger, reorganisation, dissolution, or other sale or transfer of title.
(e) Our advisors, including auditors and lawyers. We may share your Personal Data with or disclose your Personal Data to our advisors in the course of seeking professional advice.
4.2 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
5.2 You have the ability to accept or decline cookies by modifying the setting in your browser.
6. Your rights and options regarding your Personal Data
6.1 Withdrawing consent.
(a) You may withdraw your consent and request us to stop collecting, using, disclosing and/or Processing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer firstname.lastname@example.org
(b) Upon receipt of your written request to withdraw your consent, we may require a reasonable period of time to process and respond to your request.
(c) Do note that if you withdraw your consent, we may not be able to provide you with certain services or allow you to continue accessing or using the Platform and or partners platforms as outlined in individual offers
(d) Please note that withdrawing consent does not affect our right to continue to collect, use, disclose or Process your Personal Data where such collection, use, disclosure, and Processing without consent is permitted or required under applicable laws.
6.2 Accessing and Correcting your Personal Data
(a) If you wish to make
(i) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we had used or disclosed your Personal Data in the one (1) year prior to the date of your request, or
(ii) a correction request to correct or update any of your Personal Data which we hold about you,
you may submit your request via email to our Data Protection Officer at this contact email@example.com
(b) Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
(c) We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable laws).
7. Personal Data of Third Party Individuals
7.1 In the event that you provide Personal Data of third party individuals (such as your emergency contacts), you hereby represent and warrant to us that you are validly acting on behalf of such third party individual and that you have obtained their consent to disclose their Personal Data to us for the purposes which we will be collecting and using their Personal Data, as stated under Clause 3 above.
8. Protection of Personal Data
8.1 We will take appropriate administrative, physical, and technical measures to safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which Personal Data is stored.
8.2 You should be aware, however, that no method of transmission over the Internet or
method of electronic storage is completely secure. While security cannot be guaranteed,
we strive to protect the security of your Personal Data, and are constantly reviewing and
enhancing our security measures.
9. Accuracy of Personal Data
9.1 Where you submit Personal Data to us, you should ensure such Personal Data is accurate. You should also review your Personal Data from time to time and let us know if there are changes or updates to your Personal Data so that we do not hold any inaccurate Personal Data about you.
10. How long we retain your Personal Data
10.1 Accepting any Bounty Media or Bountypay offer also creates a BountyID and Bounty user profile for you for the purpose of accepting this and future offers, as detailed in the individual terms and conditions that you consent to when accepting an offer. Your account and user profile will remain open unitl you choose to terminate your profile.
10.2 We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
10.3 We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.