XYCO STUDIO Protection Policy
1. Your Personal Data
1.1 your name, Singapore National Identification Registration Card number, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of our interaction with you;
1.2 information about your use of XYCO Studio’s Site and services, including cookies, IP address, subscription account details and membership details, but only to the extent that XYCO Studio may identify you from such information;
1.3 your payment-related information, such as your bank account information, credit card information, or your credit history; and
1.4 information about your usage of and interaction with our Site and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from Our Site.
2. Collection of Personal Data
2.1 Generally, XYCO Studio collects your Personal Data in the following ways:
(a) when you submit forms relating to any of our products or services;
(b) when you register for or use any of our services the Site or when you register as a member of the Site;
(c) when you interact with our customer service officers;
(d) when you use our services;
(e) when you establish any online accounts with us;
(f) when you request that we contact you;
(g) when you are contacted by, and respond to, our marketing representatives and agents;
(h) when you respond to our request for additional Personal Data;
(i) when you ask to be included in an email or other mailing list;
(j) when you respond to our promotions and other initiatives;
(k) when we receive references from business partners and third parties, for example, where you have been referred by them;
(l) when you submit your Personal Data to us for any other reason.
2.2 When you browse our Site, you generally do so anonymously but please see the section below on cookies.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, XYCO Studio collects, uses and discloses your Personal Data for the following purposes:
(a) responding to your queries, requests or complaints;
(b) verifying your identity, such as know-your client checks and credit-worthiness checks;
(c) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing other commercial risks;
(d) protecting and enforcing our contractual and legal rights and obligations;
(e) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(f) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out closed-circuit television (“CCTV”) surveillance and conducting security clearances);
(g) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(h) any other purpose relating to any of the above.
3.2 In addition, XYCO Studio may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) if you have a subscription or membership account with us:
(i) processing your application for an account to use our Site;
(ii) maintaining your account with us;
(iii) verifying and processing your personal particulars and payments in relation to provision of such subscription services to you;
(iv) providing you with the goods and services which you have signed up for;
(v) communicating with you to inform you of changes and development to XYCO Studio policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) processing your Personal Data in relation to any of the purposes stated above;
(b) if you submit an application to us as a candidate for employment or an internship:
(i) processing your application including pre-recruitment checks;
(ii) providing or obtaining employee references or other references where relevant for background screening/vetting;
(iii) collecting information about your suitability for the position applied for;
(iv) organising training and staff development programs;
(v) assessing your performance;
(vi) administrating benefits and payroll processing;
(vii) providing you with tools to facilitate or as required for you to do your job;
(viii) communicating with you as required by XYCO Studio to comply with its policies and processes, including for business continuity purposes; and
(viii) any other purposes relating to the aforesaid.
3.3 In addition, where permitted by the applicable personal data protection laws, XYCO Studio may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
(a)providing services, products and benefits to you, including promotions, loyalty and reward programmes;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by XYCO Studio or other third parties;
(c) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;
(d) sending you details of products, services, special offers and rewards which may be of interest to you; and
(e) conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.
3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, XYCO Studio may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).
3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
XYCO Studio will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, wherever they may be located:
(a) XYCO Studio affiliates;
(b) agents, contractors or third party service providers who provide operational services to XYCO Studio, such as telecommunications, information technology, payment, payroll, processing, training, market research, vendor services, delivery services, storage, archival or other services to XYCO Studio;
(c) vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on our Site, whether in conjunction with us or not;
(d) external business and charity partners in relation to corporate promotional events;
(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
(g) insurance agencies or reinsurance agencies;
(h) anyone to whom we transfer or may transfer our rights and duties;
(i) banks, credit card companies and their respective service providers;
(j) our professional advisors such as our auditors and lawyers;
(k) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
(l) any other party to whom you authorise us to disclose your Personal Data.
5.1 When you interact with us on our Site, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our Site and common entry and exit points into our Site.
5.2 XYCO Studio uses “cookies“, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our Site. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
5.3 XYCO Studio may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across our Site. XYCO Studio uses the Third Party Market Research Company’s services to collect the following core information on the usage of our Site, including:
(a) the number of page views (or page impressions) that occur on our Site;
(b) the number of unique visitors to our Site;
(c) how long these unique visitors (on average) spend on our Site when they do visit; and
(d) common entry and exit points into our Site.
5.4 This information is aggregated by the Third Party Market Research Company and provided to XYCO Studio to assist in analysing the usage of our Site. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
5.5 Pages on our Site may be coded with software which enables the Third Party Market Research Company to track visitors to our Site.
5.6 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our Site.
6. Third-Party Sites
Our Site may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Site. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our Site, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
7. Withdrawal, Access and Correction of your Personal Data
7.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer (“DPO”).
7.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to XYCO Studio on your behalf.
7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, XYCO Studio may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with XYCO Studio and your being in breach of your contractual obligations or undertakings, and XYCO Studio’s legal rights and remedies in such event are expressly reserved.
7.4 Our Data Protection Officer may be contacted via email at firstname.lastname@example.org.
8. Governing Law