1. Definition
1.1. “ZPL” means Zavior Pte Ltd.
1.2. “Personal Data” has the meaning under the Act and includes information such as your name, identification number, personal email address(es), personal phone number, that have been and may be collected, compiled, processed and maintained with ZPL from time to time.
2. Provision of Personal Data
2.1. ZPL will obtain your Personal Data when you provide your Personal Data to ZPL in any way or manner including pursuant to any inquiries made with ZPL. ZPL will also receive and store your Personal Data when you enter ZPL’s website.
2.2. ZPL may also receive, store and process your Personal Data which are provided or made available by any third parties for reasons including delivery of ZPL’s services, performance of conditions of agreements and/or to comply with ZPL’s legal and regulatory obligations.
3. Purposes of Processing
3.1 ZPL may use your Personal Data for the following purposes, namely:
(a) To respond and process your enquiries
(b) To communicate with you via SMS, phone call, email, and/or any other appropriate communication channels
(c) To provide the services that you may have requested
(d) For administrative purposes, including administering sponsorships and donations
(e) For mailing list subscriptions
(f) For ZPL to discharge obligations and compliance required under the law
3.2 Provision of your Personal Data for the purposes listed in Section 3.1 above is voluntary and optional. However, failure to provide the requested Personal Data or any limitation against ZPL to process your Personal Data may result in ZPL being unable:
(a) to process the relevant enquiries
(b) to provide all or part(s) of the services as described above or any other services that ZPL is providing to you in a continuous manner
(c) to provide services to the extent as stated in the marketing materials of ZPL and/or
(d) to provide any of the new services that may be offered by ZPL from time to time.
3.3 Your Personal Data may be transferred to, stored in, and processed in a jurisdiction other than Singapore. You understand and consent that your Personal Data may be transferred outside of Singapore to those third parties with whom ZPL share it as described in this Privacy Policy.
4. Disclosure to Third Parties
4.1 For purposes as described herein and to facilitate the provision of the various services offered to you or other transaction with you, ZPL may share with and/or transfer your Personal Data to:
(a) the other entities within ZPL
(b) ZPL’s third-party service providers
(c) any person under a duty of confidentiality to ZPL
(d) any actual or proposed assignee, transferee, participant or sub-participant of ZPL’s rights or business
4.2 ZPL may also share your Personal Data where required by law or where disclosure is necessary to comply with applicable laws, legal processes or queries from the relevant authorities.
5. Rights to Limit Processing
5.1 If you:
(a) wish for ZPL to stop processing your Personal Data for marketing purposes or any direct marketing purposes or
(b) wish to change the manner in which ZPL is permitted to process your Personal Data as described under Section 3 above, you may submit a request in writing to the address stated in Section 7 below.
5.2 When you visit ZPL’s website, there is an automatic collection of some information about your computer such as IP address, web browser software, and referring website. Such information is only used for the purpose of creating a better user experience and to identify areas for improvement on ZPL’s website.
6. Access and Correction of Personal Data
6.1 You may request to access to and/or to make any correction to your Personal Data by submitting a request in writing to ZPL to the address stated in Section 7 below.
6.2 In respect of your right to access and/or correct your Personal Data, ZPL has the right to:
(a) refuse your request to access and/or make any correction to your Personal Data in the manner provided in the Act, such as where the expense of providing access to you is disproportionate to the risks to your privacy, or where the rights of others may also be violated, amongst other reasons
(b) refuse your request to access and/or make any correction to your Personal Data as permitted under the Act, including where your Personal Data is being processed by ZPL in order to discharge regulatory functions and providing you access and/or the right to make any correction to your Personal Data is likely to prejudice proper discharge of those functions by ZPL and
(c) charge a fee as may be allowed under the Act for processing of your request to access your Personal Data.
6.3 notwithstanding that access is granted to you or any correction/updating of your Personal Data is performed, this Privacy Policy shall remain valid and effective at all times.
7. Your Choices and Rights
ZPL respond to all requests that we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. ZPL may ask you to verify your identity in order to help us respond to your request securely and efficiently. Even where not legally required, ZPL will use reasonable efforts to complete requests to access or delete your personal information. You may access your information by contacting ZPL as provided in the Contact Us section. To request permanent deletion of your personal information, please contact us as described in the Contact Us section. ZPL will consider your request in accordance with applicable laws.
8. Data Security
ZPL use reasonable and appropriate measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal information.
9. Updates to this Privacy Policy
ZPL may revise this Privacy Policy from time to time. The most current version of our Privacy Policy will govern our use of information about you. If we make material changes to our Privacy Policy, we will notify you by email or by posting a notice on ZPL Platform. By continuing to access or use ZPL Platform after those changes become effective, you are subject to the revised Privacy Policy.
10. Enquiries and Contact
You may request for access and/or request for correction of your Personal Data or make any inquiries or feedbacks in relation to the processing of your Personal Data by contacting us via email at: dpo@zavior.app
Notes: ZPL reserves the right to revise this Privacy Policy from time to time due to changes in applicable laws and regulations and you shall be deemed to have agreed to such revision(s) if you continue your relationship with ZPL without any objection.
