Revised: 6 Sept 2024
1. Introduction
At IJOOZ, we are committed to protecting the privacy and security of our users' personal data. This privacy policy outlines how we collect, use, and safeguard the personal information you provide when using our services.
2. Information We Collect
Depending on your use of our platform and/or your interaction with our services, we may collect the following personal data from you:
As used in this Notice: "customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and "personal data" means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
3. Use of Personal Data; Processing of Personal Data
We use your personal data to provide and improve our services, including but not limited to communication, transaction processing, and customer support.
We may process your personal data for various purposes and based on several different legal bases that allow this processing. For example, we process your personal data to upgrade our service offerings to you, to provide you with personalized customer experience, to contact you about your account and our services, to provide customer service, to provide you with personalized advertising and marketing communications, and to detect, prevent, mitigate and investigate fraudulent or illegal activity. We may also share your information with third parties, including service providers acting on our behalf, for these purposes. In addition, we may share your personal data among affiliates and partners in order to fulfill our service to you.
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your "authorized representative") after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
We may collect, use and share aggregated data, such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing the system.
We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/orregulatory authority;
(h) any other purposes for which you have provided the information;
(i) transmitting 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; and
(j) any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
(b) to third party service providers, agents and other organizations we have engaged to perform any of the functions listed in the clause above for us. (For example, NTUC FairPrice Co-operative Ltd and other product vendors.)
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
3.1 Deemed Consent by Notification
We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had been originally collected for.
In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for verification purposes.
Before relying on deemed consent by notification, IJOOZ AI Pte Ltd will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
In line with the legitimate interests' exception, we may collect, use or disclose your personal data for purposes of fraud detection and prevention; and detection and prevention of misuse of services. The aforementioned purposes may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way.
3.2 Withdrawing Your Consent
You may write in to inform us if you wish to opt-out of the collection, use and disclosure of your personal data. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at contact@ijooz.com.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
3.3 Access to And Correction of Personal Data
If you wish to make (a) 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 use or disclose your personal data, or (b) 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 contact@ijooz.sg.
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.
We will respond to your request as soon as reasonably possible. 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 PDPA).
4. Protection of Personal Data
All reasonable efforts are made by IJOOZ to ensure that any personal data held by us is stored securely and safely. We implement industry-standard security measures to protect your personal data from unauthorized access, use, or disclosure.
To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we may introduce appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and we reserve the right to disclose personal data both internally and to our authorized third-party service providers and representatives on a need-to-know basis for technical and cybersecurity enhancement.
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 information and are constantly reviewing and enhancing our information security measures.
5. Confidentiality
5.1 IJOOZ does not sell, rent, or lease its customer lists to third parties.
5.2 Personal data held by IJOOZ will be kept confidential and will only be shared with third parties with your consent or as necessary to provide our services. These third parties include but are not limited to our advertisers, associated companies, trusted contractors, agents, and network operators who perform tasks on our behalf. All third parties are required to maintain the confidentiality of your personal data and are prohibited from using it for any purpose other than providing the requested services.
6. Disclosure of Personal Data
IJOOZ will only disclose your personal data without notice if required to do so by law or in the good faith belief that such action is necessary to: a. Comply with legal obligations; b. Protect and defend the rights or property of IJOOZ; c. Act under exigent circumstances to protect the personal safety of users or the public.
7. Retention of Personal Data
We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
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.
8. Transfers of Personal Data Outside of Singapore
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
9. Non-Personal Data
Any questions, comments, suggestions, or information other than personal data that you provide to IJOOZ through our app or website will be deemed non-confidential and non-proprietary. IJOOZ reserves the right to use, reproduce, disclose, transmit, publish, broadcast, or post such information freely, including sharing it with associated companies for purposes such as product development, marketing, and customer service improvement.
10. Changes to This Policy
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
IJOOZ reserves the right to update this privacy policy as needed. We will notify users of any significant changes by posting the updated policy on our website or through other appropriate communication channels.
11. Contact Us
If you have any questions or concerns about this privacy policy or how your personal data is handled, please contact us at contact@ijooz.com.