# Singdata Privacy Policy

--: Version 【2024】【08】

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This Privacy Policy applies to the access and use of the SingdataCloud Website currently located at [www.singdata.com](http://www.singdata.com), and theuse by registered users of the Singdata Lakehouse of Singdata Cloud productsand services (the “**Cloud Services**”) provided by the Singdata Cloudentity listed in Clause 2 of the *Terms of Use* (referred to as “**we**”, “**our**” or “**SingdataCloud**” hereinafter). Terms not defined in this Privacy Policy shall havethe same meaning as in the Terms of Use of the Singdata Lakehouse.

This Privacy Policy sets out howwe collect, use, transfer, retain, secure and disclose your personal dataand/or personal data about your customers or end users that you provide to uspursuant to your use of the Singdata Lakehouse and/or our Cloud Services, aswell as other terms relating to data location. It also describes your choicesregarding use, access and correction of your personal data.

Many of our Cloud Services offeredthrough the Singdata Lakehouse are intended for use by business organisations.If you use your organisation’s email address to register an account andpurchase or use our Cloud Services, the owner of the domain associated withyour organisation’s email address, and/or your organisation, may monitor orcontrol your account with the Singdata Lakehouse and access, process, and/orcontrol your personal data, as well as the contents of your communications andfiles. Your organisation’s use of our Cloud Services may be subject to yourorganisation’s own rules or policies, and you shall direct all privacyenquiries relating to such rules or policies to your organisation’sadministrators. We are not responsible for the privacy or security practices ofyour organisation.

Cloud Services may be used by ourcustomers (i.e. registered users of Singdata Cloud) to develop or host theirown services and products for the customer’s end users. Any informationcollected or handled by Singdata Cloud in such circumstances is processed onbehalf of our customer who controls the collection and use of such information.We do not have a direct relationship with the end users of our customers. Wherethis is the case, end users should direct all privacy enquiries, such as anyrequests to access, correct, amend or delete personal data, to the SingdataCloud customer providing their services or products. We are not responsible forthe privacy or security practices of our customers.

**A. COLLECTION OF PERSONAL DATA**

1\. If you are (i) an individual or(ii) a representative of a business organisation at the time you register tobecome a user of the Singdata Lakehouse and/or purchase Cloud Services, you maybe asked to complete registration forms which require you to provideinformation such as your email address, mobile number, country, preferredlanguage, name, contact address, and screen nickname. You may also provide tous additional optional contact information in your account profile, such asemail address for sub-accounts, and additional contact phone numbers.

2\. We record details of youractivities (including any purchase or use of our product offerings andservices) when you use the Singdata Lakehouse and/or certain Cloud Services forlegal and/or business purposes. If you make purchases or otherwise transactonline through the Singdata Lakehouse, we also collect information related tosuch transactions including, but not limited to, the types and specificationsof the Cloud Services, pricing information, and any trade dispute/complaintrecords.

3\. When you contact our customersupport, sales or other departments, we may record the communications forsecurity and customer services purposes and collect additional information toverify your identity.

4\. If you make online purchasesfor our Cloud Services through the Singdata Lakehouse, you may be required toprovide information related to your payment instrument (such as credit cards),including information about your payment instrument organisation, your paymentinstrument number, the security code, and the expiration date of your paymentinstrument, directly to our payment service provider.

5\. Please note that certaincategories of data are necessary for us to provide the Cloud Services, such asuser name, address, phone number, and email address. These categories will bespecified at the time of collection. In the event that you do not provide anyor sufficient data marked as mandatory, we may not be able to complete theregistration process or provide you with our Cloud Services.

6\. We also record records ofusers’ buying and browsing activities on the Singdata Lakehouse, including butnot limited to Internet Protocol (“IP”) addresses, browsing patterns andpurchasing patterns. In addition, we automatically gather statisticalinformation about our Singdata Lakehouse and visitors to our Singdata Lakehouseincluding, but not limited to, IP addresses, browser software, operatingsystem, software and hardware attributes, pages viewed, number of sessions andunique visitors.

7\. We may from time to timecollect additional information from you (such as copies of identificationdocuments) and obtain information about you from third parties in order tocarry out risk control, fraud prevention and compliance procedures. For example,we may collect payment-related information from third parties and combine itwith information we collect about you for the purpose of fraud prevention andrisk control.

**B. PURPOSES FOR THE COLLECTION,RETENTION, USE, DISCLOSURE AND TRANSFER OF PERSONAL DATA**

We collect, retain, use anddisclose personal data for the following purposes:

1\. processing your registration asa user, providing you with a user ID for our Singdata Lakehouse and maintainingand managing your registration;

2\. providing you with customerservice and responding to your queries, feedback, claims or disputes;

3\. providing the Cloud Services toyou and/or your end users;

4\. processing your purchasesand/or subscriptions on the Singdata Lakehouse;

5\. personalizing our communicationwith you based on your order history, and performing research or statisticalanalysis in order to improve our product offerings and services;

6\. publishing any information youvoluntarily submit (which may include, but is not limited to, a photograph orother personal data you provide) to our Singdata Lakehouse to be published onour Singdata Lakehouse through the publishing tools (such as our discussionforums);

7\. to comply with applicable law,legal process or lawful government request, or in respect of any claims orpotential claims brought against us or our parent companies, shareholders,subsidiaries and affiliates;

8\. performing risk control, legalcompliance and sanctions screening; and

9\. performing screening and checksfor unlawful, fraudulent, deceptive or malicious activities.

Subject to obtaining your specificconsent (or where otherwise permitted by applicable law in your jurisdiction),we may use your name, phone number, residential address, email address and faxnumber (which may incorporate personal data) to provide notices, surveys,product alerts, related communications and other marketing and promotionalmaterials to you relating to goods and services offered by us on our SingdataLakehouse.

**C. DISCLOSURE OF PERSONAL DATA**

1\. We may disclose your personaldata to third party service providers engaged by us to assist with providingyou with our services (including partners providing customer services to you,contacting you regarding promotions products and services, performing riskcontrol, fraud prevention and legal compliance procedures, and conductingpayment processing services) (the “Third Party Service Providers”). These ThirdParty Service Providers may be located in Singapore or outside of Singapore,and are engaged under terms compliant with applicable data protection lawsand/or appropriate duties of confidentiality to us and are only permitted touse your personal data in connection with the purposes specified in Section Babove, and not for their own purposes. These Third-Party Service Providers mayfurther contract some components of the services they provide to us to otherservice providers. These other service providers may also be located inSingapore or outside of Singapore, and are under a duty of confidentiality toour Third Party Service Providers and are only permitted to use your personaldata in connection with the purposes specified in Section B above, and not fortheir own purposes.​

2\. We may provide aggregated oranonymized data to third parties, but when we do so, the information we shareis in a de-identified format that does not personally identify you.

3\. We have established and willestablish relationships with other parties and websites to offer you thebenefit of their products and services. We offer you access to these otherparties and their websites either through the use of hyperlinks to these sitesfrom our Singdata Lakehouse or through offering “co-branded” sites in whichboth we and other parties share the same uniform resource locator, domain nameor pages within a domain name on the Internet. In some cases you may berequired to submit personal data to register or apply for products or servicesprovided by such third parties or co-branded partners. This Privacy Policy doesnot apply to these third party sites or co-branded sites. The privacy policiesof those other parties may differ from ours, and we have no control over theinformation that you submit to those third parties. You should read therelevant privacy policy for those third party sites and co-branded sites beforeresponding to any offers, products or services advertised by those parties.

4\. Our website offers publiclyaccessible community forums. Any information you provide in these areas may beaccessed, read, collected, and used by others anywhere in the world. To requestremoval of your personal data from our community forums, contact us at <service@singdata.com>.

**D. TRANSFER OF PERSONAL DATA**

Your personal data is primarilystored in our secure servers located in Singapore. As part of providing youwith the Cloud Services, we may need to transfer your personal data from yourjurisdiction to other jurisdictions where our service providers operate.Recipients of the data in these jurisdictions may be subject to data privacylaws different from those in your own jurisdiction. Such overseas transfer orprocessing of your personal data may be necessary to process and administeryour customer account and to provide the Cloud Services effectively.

 

**E. SECURITY MEASURES**

We use commercially reasonableendeavors to protect the personal data that you provide to us. We also employseveral security techniques, including but not limited to the use ofindustry-standard Secure Socket Layer (SSL) encryption for transmission of personaldata in registration information and payment information and the adoption ofidentity, credential and access management measures for transmission of suchpersonal data to prevent security breaches and unauthorized access of personaldata. We limit access to your personal data and other data to people who needaccess to such data for their work.

Nevertheless, no data transmissionover the internet or any wireless network can be guaranteed to be perfectlysecure. As a result, while we try to protect your personal data, we cannotguarantee the security of any personal data you transmit to us and you do so atyour own risk. We cannot and do not guarantee security in connection with youruse of the Singdata Lakehouse and our Cloud Services.

We retain your personal data aslong as you have an account with us, as needed to provide services or productsto you, to resolve disputes, to serve the purpose of research and statisticalanalysis or as required or permitted by applicable laws, such as tax andaccounting laws.

**F. PERIOD OF RETENTION ANDPROCESSING OF PERSONAL DATA**

We retain your personal data forthe purposes described in this Privacy Policy where we have an ongoinglegitimate business need to do so (for example, to provide you with a serviceyou have requested or to comply with applicable legal, tax or accountingrequirements). In certain circumstances, we will need to keep your personaldata for legal reasons after our relationship has ended. The specific retentionperiods depend on the nature of the personal data and why it is collected andprocessed, and the nature of the legal requirement.

When we have no ongoing legitimatebusiness need or legal reason to process your personal data, we will eitherdelete or anonymize it or, if this is not possible, then we will securely storeyour personal data and isolate it from any further processing until deletion ispossible.​

**G. PROCESS AND METHOD OFDESTRUCTION OF PERSONAL DATA**

Singdata Cloud will delete your personal data asdescribed in Section F of this Privacy Policy. When deleting personal data, wewill take standard commercially reasonable measures to make the personal datapractically irrecoverable or irreproducible. The specific manner of deletionwill depend on the data being deleted, how the data was collected and stored,and your interactions with us. Electronic documents or files containingpersonal data will be deleted using a technical method that makes recovery or retrievalof such information practically impossible or renders the data no longerpersonally identifiable. Non-electronic documents or files containing personaldata will be shredded, incinerated, or both.**​**

**H. RIGHT TO ACCESS/CORRECTPERSONAL DATA; CONTACTING US**

You have the right to request access to your personaldata held by us (or on our behalf) and to request correction or deletion ofsuch personal data. Additionally, upon request, we will provide you withinformation about whether we hold your personal data. You may contact us at <service@singdata.com> torequest access, correction or deletion of your personal data. We will respondto your request within a reasonable timeframe. You may also have supplementalrights under applicable law in relation to your personal data. For example, ifyou are an EEA or UK user, you have the right to object to or request therestriction of processing of your personal data, and to request portability ofyour data by contacting us at <service@singdata.com>.

In cases where we act as aprocessor, we have no direct relationship with the individuals whose personaldata we process. An individual who seeks access, or who seeks to correct,amend, or delete inaccurate data should direct their query to Singdata Cloud’sclient (the data controller).

You may receive e-newsletters fromus. If you would like to discontinue receiving this information, you may updateyour email preferences by using the “Unsubscribe” link found in emails we sendto you or at your member profile.

We do not knowingly collectpersonal data of minors (persons under the age of 18). If a minor has providedus with personal data, the parent or guardian may contact us on the minor’sbehalf to request that we cease any further collection, use and/or disclosureof the personal data and delete the personal data we may hold relating to therelevant minor.

**I. COOKIES**

We and our partners use “cookies”and/or similar technologies, such as web beacons and javascript, to storespecific information about you and track your visits to our Singdata Lakehouse.We may also use “cookies” to store specific information about your use ofcertain Cloud Services as part of its features and to facilitate or enhanceyour user experience of the relevant service. A “cookie” is a small amount ofdata that is sent to your browser and stored on your device. A cookie can besent to your device only if you access our Singdata Lakehouse using a device.If you do not de-activate or erase the cookie, each time you use the samedevice to access our Singdata Lakehouse, our web servers will be notified ofyour visit to our Singdata Lakehouse and in turn we may have knowledge of yourvisit and the pattern of your usage.

Generally, we use cookies to identify you and enable usto i) access your registration information so you do not have to re-enter it;ii) gather statistical information about usage by users; iii) research visitingpatterns and help target advertisements based on user interests; iv) assist ourpartners to track user visits to the Singdata Lakehouse and process orders; v)track progress and participation in promotions; and vi) facilitate your use ofany relevant Cloud Services which may involve the use of cookies. We partnerwith third parties to manage our advertising on other sites. Our third partypartners may use cookies and/or similar technologies in order to provide youadvertising based upon your browsing activities and interests.

You can determine if and how acookie will be accepted by configuring the browser which is installed in thecomputer you are using to access the Singdata Lakehouse. If you choose, you canchange those configurations. You may be able to change your browser preferencesor settings to reject all cookies, or choose to consent each time a cookie issent. If you reject all cookies by choosing the cookie-disabling function inyour browser, you may be required to re-enter information on our SingdataLakehouse more often and certain features of our Singdata Lakehouse may beunavailable.

By accessing and using our Singdata Lakehouse and/orCloud Services, and by accepting the cookies, you consent to the storage ofcookies on your devices. You also consent to the access of such cookies by usand by our partners mentioned above.**​**

**J. CHANGES TO THIS PRIVACY POLICY**

Any changes to this Privacy Policy will becommunicated by us posting an amended Privacy Policy on our Singdata Lakehouse.The new Privacy Policy will become immediately effective once posted on the SingdataLakehouse or at a date specified by Singdata Cloud. We may also in ourdiscretion provide notice to you of any changes to the Privacy Policy. If wemake any material changes we will notify you by email (sent to the e-mailaddress specified in your account) or by means of a notice on this websiteprior to the change becoming effective. Any information and/or personal data wehold about you (as described in this Privacy Policy and whether or notcollected prior to or after the amended and restated Policy comes into effect)will be governed by the latest version of our Privacy Policy. We stronglyencourage you to visit the Singdata Lakehouse from time to time to review thePrivacy Policy. Your continued use of the Singdata Lakehouse and/or the CloudServices signifies your acceptance of the changes to the Privacy Policy.

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