Privacy Policy

Effective Date: June 1, 2022
Thank you for using our APP! Please carefully read this privacy policy (“Privacy Policy” ) when you use DIGITAL CONCH PTE. LTD. ’s services. This Privacy Policy will come into effect for all existing users on June 1, 2022. Your use of the service from that day will be subject to this Privacy Policy.
The Data Controller under this Privacy Policy is DIGITAL CONCH PTE. LTD. ( “we”, “us”, “our”, “DigitalConch” ).
We are dedicated to protecting users’ privacy rights. This Privacy Policy has been crafted to inform users as to how we collect, store, use, manage, process, transfer, and implement any other possible operation to the personally identifiable information (“Data” ) that users provide during the use of our services.
If you do not agree to the processing of your Data in the way that this privacy policy describes, please do not provide your information (when we request) and stop using the APP or any services associated with the APP (“Services” ). By using the Service, users are explicitly and specifically agreeing to the collection, use and any other ways of operation of their Data as outlined in this Privacy Policy. We may amend the Privacy Policy from time to time according to the relevant laws, users can find the updated Privacy Policy on the website of DigitalConch as well as on the APP. We will notify users if we make any material changes to the Privacy Policy. Unless specifically notified to us, users are deemed as agreeing to any amendment made by us.

CONTACT INFORMATION

DIGITAL CONCH PTE. LTD.
133 New Bridge Road, Chinatown Point #08-03, Singapore
If you have any questions about how we use your personal data, please contact privacy@digitalconch.com .

TABLE OF CONTENTS

1. Data and How we Collect them
2. How We Use and Share Data
3. Your Rights and Options
4. How We Protect Data
5. Children
6. Updates to Our Privacy Policy
7. How to Contact Us
8. How to Contact the appropriate Authority

1. Data and How we Collect them

We collect or receive Data in three ways:
(1) you directly provide Data to us, such as by creating an account or signing up for email alerts.
(2)we collect Data on an ongoing basis, such as through cookies and related technologies.
(3) we receive Data from third party with your consent, such as social media platforms.

1.1 Data You Provide to Us

You may provide your Data to us when you choose to use our Service. As we change our offerings and features from time to time, the Data we collect from you may vary depending on the services you are using. If you provide the Data to us, it will be construed as your acceptance to use our Service and consent for providing the Data. However, you do not have to provide Data when we ask you for it, but if you decline you might not to be able to access or enjoy Services or certain services, offering or features.
In general, we collect Data and other information as set forth in the table below for specific purposes:
(1)
Registration information, such as your user identifier, nickname, password, gender, date of birth, phone number (or email, if applicable),and language;
(2)
Profile information, such as your alias, profile images, hometown, self-introduction, social media information, education, and career;
(3)
User-generated contents (“UGC”), such as comments, texts, messages, pictures, images, videos, sounds, code or other data or materials that you upload, distribute or stream on the App when you use DigitalConch Services;
(4)
Facial data, if you utilize Real-Person Profile Picture Authentication, we collect your profile picture and facial-recognition video for Real-Person Profile Picture Authentication on the premise of your approval by comparing your profile picture with face-recognition video. This authentication can protect you from impersonators and fake accounts, or develop the authenticity of DigitalConch Services. We will not use it for other purposes unless we have obtained your explicit consent or turn this into de-identified data.
(5)
Payment information, such as bank account number, Paypal or other payment information where required for payment;
(6)
Transaction information,such as the transaction serial number and transaction historical records after you purchased Paid Services;
(7)
Your Global Positioning System (GPS) information, after you permit us to do so but you may change the access to your GPS information via the settings on your mobile device;
(8)
Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints; and
(9)
Information you provide when participating in in-app surveys and activities.

1.2 Data We Collect On an Ongoing Basis

We may also collect Data and other information through technologies, from you when you use our Services. We use these Data and information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics and it is necessary for provision of Service. The type of information that we collect may vary, but generally includes:

1.3 Data Received by Us through Third Party

We may also collect your Data through third parties. Such as:
With regard to clause 1.3 above, please bear in mind that a third party controls your Data and you may vary your authorization and revoke consent through privacy settings on such Third party’s platform.

2.How We Use and Share Data

2.1 Using Your Data

We collect, use, store, and process your Data based on:

We collect, use, store, and process your Data to operate our business and to enhance and personalize your social experience, such as:

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.

To provide you support, including to:

Note that we may process your Personal Information for more than one lawful ground depending on the specific purpose for which we use your Personal Information.

2.2 Sharing Your Data

2.3 Data transfers

Our Service is global by nature and your Data can therefore be transferred to third parties or service providers or business partners located within or outside your jurisdiction. You hereby unconditionally agree and permit that we may transfer, share, disclose all or any of your Data to third parties or service providers or other entities where necessary in relation to the purposes identified in this Privacy Policy. In accordance with applicable data protection and privacy laws and regulations, we will implement appropriate measures to ensure that your personal information remains protected and secure when it is transferred outside of your country to a jurisdiction that has a less adequate level of protection of personal data. These measures include (where applicable) transferring pursuant to data transfer agreements implementing standard data protection clauses, such as our partners may use include standard contractual clauses approved by EU Commission or other jurisdictions.
We may also transfer your personal information outside of your country as permitted by applicable data protection and privacy laws and regulations. Examples include where we need to transfer your personal information: (a) to perform a contract with you (or to take steps before the contract at your request); (b) perform a contract in your interests; or (c) in relation to legal claims.

2.4 Data Security

We take appropriate administrative, technical and physical security measures to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of certain your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of your Personal Information. You should use caution whenever submitting information through DigitalConch Services and take special care in deciding which information you provide us with.
You are responsible for maintaining the secrecy of your password and account information at all times.

3.Your Rights and Options

You may exercise any of the rights described in this section by using any functionality available while using the Service and/or sending an email viaprivacy@digitalconch.com and we will respond within 30 days. Please note that we may ask you to verify your identity before taking further action on your request.

3.1 Managing Your Data

You may access and update some of your Data through your Account settings. If you have chosen to connect your Account to a third-party application, such as Facebook, you can do so within the APP. You are responsible for keeping your Data accurate and up-to-date.
We securely stores your data by using the Storage service provided by Amazon Web Services(referred to AWS)( https://aws.amazon.com/ ) and Appsflyer (https://www.appsflyer.com/ ). You can find more information regarding Amazon Web Services’ Security, Identity, & Compliance at https://docs.aws.amazon.com, Appsflyer’s Data Security and Privacy Principles for Services at: https://www.appsflyer.com/product/security-and-privacy/ .

3.2 Rectification of Inaccurate or Incomplete Data

You have the right to review your Data provided to us, ask us to correct any inaccurate or incomplete personal Data concerning you. Should you have such requirement, please contact us in accordance with clause 7 of this Privacy Policy.

3.3 Data Access

In some jurisdictions, applicable law may entitle you to request copies of your Data held by us. You may also be entitled to request copies of Data that you have provided to us in a structured, commonly used, and machine-readable format, should you have such requirement, please contact us in accordance with clause 7. For providing such copies, we may charge a reasonable fee based on administrative costs incurred thereupon and your requests to such copies shall not adversely affect the rights and freedoms of others.

3.4 Withdrawing Consent and Restriction of Processing

Where you have provided your consent to the processing of your Data by us, you can always withdraw your consent at any time. For example:
Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Additionally, in some jurisdictions, you have the right to object and/or limit the ways in which we use your Data, in particular where:
(i)you contest the accuracy of your Data;
(ii)the processing is unlawful and you oppose the erasure of your Data;
(iii)we no longer need your Data for the purposes of the processing, but you require the Data for the establishment, exercise or defense of legal claims.
Should you have any above requirements, please contact us in accordance with clause 7.

3.5 Data Retention and Erasure.

We generally retain your Data for as long as is necessary for the performance of our service and to comply with our legal obligations and then it is deleted or erased based on our internal protocols.
If you no longer want us to use your Data to provide our Service to you, you can request that we erase your Data and close your Account.
In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information: If you ask us to remove or delete your Data, we may retain your Data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an Account for fraud or safety reasons, we may retain certain Data or information from that Account to prevent that member from opening a new account in the future.
We may retain and use your personal information or Data to the extent necessary to comply with our legal obligations. For example, we or third parties engaged by us may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others may continue to be publicly visible in the APP, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Data protection and information security is important for us. While providing services to you and other users, we operate and maintain the Services or APP so as to protect Data and our systems from accidental or malicious loss and destruction. Therefore, as part of provision of Service and on account of overall safety of Data of all users, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

3.6 Objection to Processing

In some jurisdictions, applicable law may entitle you to require us not to process your Data or personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes in accordance with clause 7.

4.How We Protect Personal Data

4.1 Security Safeguards

We have implemented reasonable security practices and standards and documented information security policies comprising of all relevant security control measures that are commensurate for protection of the information assets (including your data). We shall also comply with audit requirements as may be required under applicable law. The company’s service provider responsible for hosting of Data has implemented ISO/IEC 27001:2013 standards for its management system and we work with our service providers to ensure that adequate security measures are taken to afford protection to your Data.
Security of our users' Data is a priority at us, and we are continuously implementing and updating administrative, technical, and physical security measures such as access control, compressed encryption to help protect your Data against unauthorized access, loss, destruction, or alteration. However, in a digital world, you will appreciate that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. This means we cannot guarantee the security of your Data and do not assume any responsibility for the unauthorized use or access to your Data under our control.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. If there is a security breach occurs, we may also post a notice on the Website. We will send an emergency report to authorities in case that the security breach is serious and assist authorities to take steps to prevent further harm.
If you know or have reason to believe that your Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your DigitalConch Account, please contact us in accordance with clause 7, and we will proceed with it within 30 days and respond to you as soon as possible when we have any update.
Please keep in mind that whenever you voluntarily disclose Data online through certain channel (for example on message boards, through email, or in chat areas), that Data can be collected and used by others. We will take no responsibility whatsoever caused by reasons said above. Since disclosure of personal Data through certain channel may lead to disclosure of your personal Data, we remind you to use caution before sharing or making such disclosures. Ultimately, you are solely responsible for maintaining the secrecy of your passwords or any account Data. Please be careful and responsible whenever you are online.

5.Children

Our Service is not intended for children. Children must not use the Service for any purpose. By children, we mean users located in this country and who are below the minimum age, are required to obtain parental/guardian consent prior to the using the APPs. If you are under the minimum age, you are not permitted to access the websites or APPs unless your parent or guardian has provided express consent and accepts this Policy prior to the using the APPs.
We do not knowingly collect or maintain personal information from persons under 18 years-of-age（namely, children）. If we learn that Personal Information of persons under 18 has been collected on or through the DigitalConch Services, we will take appropriate steps to delete this information.
If you believe that we have inappropriately collected Personal Information from children, please contact us in accordance with clause 7.

6.Updates to Our Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in technology, law, our operations, or any other reason we determine is necessary or appropriate, so please review it frequently. We will indicate on the cover page of this Privacy Policy to indicate the recent most date on which the policy was last updated. Please review this Privacy Policy every time you access or use Service to make sure that you have reviewed the most recent version. We will notify you if there is any substantial change occurs.

7.How to Contact us

If you have any questions about this Privacy Policy or grievances with respect to processing of your information, or you would like to exercise any of your data protection rights, please do not hesitate to reach out to us via privacy@digitalconch.com.
We will redress the grievances on an expeditious basis within 30 days of receipt of grievance.

8.How to Contact the appropriate Authority

Should you wish to report a complaint or if you feel that we are not addressed your concern in a satisfactory manner, you may contact your local Data Protection Authorities at: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm or any other authorities in your jurisdiction.