1. GENERAL
a. Xora Innovation Pte. Ltd. ("XORA") is committed to protecting and respecting your privacy.
b. This Privacy Policy (together with our Terms of Use and any other documents referred to in it) sets out (i) the basis on which we will collect, use, disclose and process any personal data we collect from you, or that you provide to us; and (ii) information on our use of cookies. Please read the following carefully to understand our views and practices regarding cookies, your personal data, and how we will treat such information.
c. By visiting browsing, accessing and/or using our website at www.xora.vc ("Website") and/or providing us with your personal data, you hereby expressly consent to our collection, use, disclosure and processing of your personal data in accordance with this Privacy Policy. If you do not agree to our Privacy Policy, please DO NOT provide any personal data to us.
d. This Privacy Policy supplements but does not supersede or replace any other consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.
2. COLLECTION AND PROCESSING OF PERSONAL DATA
a. You may use and browse our Website and its contents without having to disclose your personal data to us, except as may be necessary to allow us to respond to your requests and/or applications or in cases where you contact us directly.
b. We collect personal data (which may include sensitive personal data), among others, when (a) you provide it to us, through registrations, applications, completion and submission of forms, emails, enquiries and requests, (b) when you use our services or enter into transactions with us (or express an interest in doing so), (c) when you communicate with us by telephone, email, via our Website or through other communication channels, and (d) similar situations in which you have chosen to provide your personal data to us. The information you provide to us may include, but is not limited to, your name, address and email. If you choose not to provide such information to us, it may not be possible for us to provide you with certain products or services, or respond to your request or enquiry. Depending on your relationship with us, we may also collect your personal data from third party sources.
c. If you provide or disclose to us the personal data of anyone other than yourself, you are responsible for informing him/her of the specific purposes for which we are collecting his/her personal data and to ensure that he/she has provided valid consent for your provision of his/her personal data to us. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.
d. We will retain control of, and responsibility for, the use of any personal data you disclose to us. Such data shall remain in our possession, or that of data intermediaries acting on our behalf.
e. You are responsible for ensuring that all personal data that you provide is true, accurate and complete, and to inform us of any changes to your personal data.
f. If you are below 18 years of age, please obtain consent from your parent or guardian before you submit any personal data to us. If you are a parent or guardian of a minor and you have reason to believe your child or ward has provided us with their personal data without your prior consent, please contact us to request for erasure of their personal data.
3. PURPOSES
a. Personal data and other information may be collected, used, disclosed and/or processed by XORA individually or collectively and may be combined with other information for the following purposes:
i. Carrying out such transactions or taking steps as may be directed by you;
ii. Verifying your identity or your compliance with any of our contractual terms with you;
iii. Responding to your enquiries or requests pursuant to your emails, telephone calls, faxes and/or submission of application(s) or form(s);
iv. Responding to your job/internship application(s) or your recruitment queries;
v. Responding to and taking follow-up actions on your complaints;
vi. Performing office and operational administrative matters following your request;
vii. Seeking feedback and comments on XORA's business and operational matters;
viii. Managing your relationship with us; or
ix. Any other purposes that are reasonably related to or in connection with the abovementioned purposes.
b. If you have provided us with your consent, we may send you marketing communications on XORA related activities based on your communication preferences, including but not limited to events, publications, and more. You may opt out at any time by (a) following the instructions for opt-out in the relevant marketing communication(s) or (b) by contacting us at the details provided at paragraph 13 below. We may also share personal data with third parties that help us with our marketing and promotional projects or sending marketing communications.
c. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where required or permitted by applicable laws.
4. IP ADDRESSES
a. When you use our Website, we may collect and store information about your computer (including your IP address, operating system and browser type) for system administration. This is statistical data about our users' browsing actions and patterns. This data could possibly lead to your identification, but we, and our data intermediaries, do not use it to do so unless required or permitted by applicable laws.
5. COOKIES - What is a cookie?
a. Cookies are small files which are placed on your computer when you access a website or app - amongst other things; they help the website user to navigate efficiently between pages and the website operator to track usage of the site.
b. You can find out more about cookies at www.allaboutcookies.org.
Why we use cookies
i. Our Website may use cookies to distinguish you from other users of our Website by storing, generally non-personally identifiable, information (e.g. session information such as the number of times you visit our Website and the location from which you are accessing the Website). Note that some limited information is personally identifiable for the purposes of:
1. Managing and customizing your experience on the Website;
2. Analysing trends and improving our site for our users; and
3. Delivering content tailored to your interests and the manner in which you browse our Websites.
ii. Any other information is anonymized and/or aggregated and may be used to produce statistical reports that enable us to evaluate the use of our Website; the web traffic on our Website; and to make improvements to, and increase efficiency when you browse our Website.
What do we use cookies for?
i. We may use cookies: (i) to track your activities on our Website; (ii) the page visits and web traffic on our Website; and (ii) the purposes described in this Privacy Policy (see paragraph 3 above), but they will not generally allow us to obtain information of a personal nature such as your name and address. We will only be aware of such information if you provide the information to us or you have set the preferences in your browser to provide this information automatically.
ii. We may use the information collected to analyse trends (such as user page visits) and improve our Website for our users.
What cookies do we use?
i. We may use the following cookies:
1. Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
2. Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region or currency).
3. Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We may use this information to make our Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
ii. Third party cookies. When you use our Website, third parties may also send you cookies. These third parties may include, for example, advertising networks and providers of external services like web traffic analysis services (e.g. Google Analytics). These third party cookies are likely to be analytical cookies or performance cookies or targeting cookies. We have no control over third party cookies. Please refer to the third party's privacy policy for information on the information they collect and how the information is used.
Can I disable cookies?
i. Yes, your browser will enable you to disable, control or delete cookies if you wish. Further information can be found in the "Help" section of your browser or at www.allaboutcookies.org. However, you should note that if you choose to do this, it may have an impact on the quality of your browsing experience on our Website.
ii. Please note that changing these settings may limit the functionality of our Website or prevent it from loading properly. Additionally, the major browsers have attempted to implement the draft "Do Not Track" (“DNT”) standard of the World Wide Web Consortium in their latest releases. As this standard has not been finalized, this Website may not be compatible with DNT and may not process DNT messages.
iii. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
6. THIRD PARTY WEBSITES
a. Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites may have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check the relevant privacy policies of such third party websites before you submit any personal data to these websites.
b. Third parties (including, for example, advertising networks and providers of external services like Google Analytics) may use cookies which are downloaded when you visit our site. These cookies are likely to be analytical, performance or targeting cookies.
7. DISCLOSURE OF YOUR PERSONAL DATA
a. To achieve the purposes as set out in the section entitled "Purposes" above, including to respond to or process your requests to XORA, we may disclose your personal data to our affiliates, any member of our group, third parties such as our service providers, data processors (providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, marketing, human resources, and professional services) and professional advisors. You hereby authorize and consent to us transferring your personal data to such third parties, who will process your personal data in accordance with this Privacy Policy. Your personal data will not be disclosed to any further third parties, unless we have obtained your consent or are legally required to do so.
b. We may also disclose your personal data as required or permitted by law, including to regulatory authorities, statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives.
8. WHERE WE STORE YOUR PERSONAL DATA
a. The data that we collect from you may be transferred to, and stored at, a destination which may be within or outside Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our service providers.
b. By submitting your personal data, you agree to such transfers, storage and processing of your personal data. XORA will take appropriate steps to ensure that your data is treated securely and in accordance with this Privacy Policy.
9. SECURITY
a. We use technical and organizational security precautions to protect your data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risk. Our security procedures are continuously revised based on new technological developments. Notwithstanding the foregoing, while precautions will be taken to ensure that the personal data you provide is protected against unauthorized or unintended access and/or disclosure, we cannot be held responsible for unauthorized or unintended access and/or disclosure that is beyond our control.
10. DATA RETENTION
a. We retain your personal data for as long as necessary for the fulfilment of the purposes for which it was collected or to which you have given your consent, except where otherwise provided for by law.
11. DATA SUBJECT RIGHTS
a. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain data subject rights under applicable law in relation to our collection, use, disclosure and/or processing of your personal data. Such rights may include: withdrawal of consent, access request, and correction request.
b. If you wish to exercise any of your data subject rights, please contact our Data Protection Officer in accordance with paragraph 13 below. We may require that you submit certain forms or provide certain information to process your request(s). Where permitted by law, we may also charge you a fee to process your request(s).
12. CHANGES TO OUR PRIVACY POLICY
a. This Privacy Policy may be amended, supplemented, modified and updated from time to time. Please check back regularly for any updates.
13. CONTACT
b. Questions, comments, complaints and requests regarding our collection, use, disclosure and/or processing of your personal data or this Privacy Policy should be addressed to our Data Protection Officer at legal@xora.vc.