We are committed to protecting and respecting your privacy. In addition to the information and documentation you provide to us as part of the registration and due diligence process, we may collect information, which may include personal data, information and documentation, about you through various means, including without limitation:-
- during your creation of an account with the Platform, such as your name, gender, date of birth and contact details;
- your use of the Service, including your address and location information, and other necessary information to facilitate your request(s) and/or the Service;
- your feedback and comments;
- your billing information;
- your use of our Platform and/or Services, including support services through our preferred independent service providers, Gembridge Couriers, our Gembridge Hubs, AEG or Ingenique;
- through the Cookies we use for the Platform;
- through your IP address, web browser type and version and/or operating system (automatically collected) and through your activity on the Website and site you exit to (automatically collected); and
- through any other data and information you provide us with by whatever means of communication, through the Platform or otherwise.
Information shall include personal information (meaning information that, on its own or in combination with other information, can be used to identify you) and also anonymous information (meaning information that does not directly or indirectly identify and cannot reasonably be used to identify you).
We may anonymise the data and information we collect for the purposes of internal statistics (i.e. reports on product and/or market research to help us improve our Services and Platform). All information disclosed in these reports shall only include anonymised data which does not directly or indirectly identify you. We may in turn disclose such reports to third parties.
All personal data, information and documentation containing personal data shall only be used for the purposes of our compliance with due diligence, antimoney laundering and counter financing of terrorism requirements pursuant to our licence, for Gembridge’s internal records, and for the provision of the Services to the relevant Customer where relevant. All other information shall may be used for the following purposes:-
- to provide you with the products or Services that you request from us;
- to provide you with information about other products and services that may be of interest to you and about offers and promotions, such as newsletters and mass emails, where you have opted in to receive such information. If you do not want us to send you e-mail about our products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of each e-mail;
- where you have given us your consent, to disclose your personal information to carefully chosen third parties so that they may provide you with information about products and services that may be of interest to you;
- to monitor, improve, or modify the Services and our operations, such as highlighting popular trends, activities and transactions, and suggesting listings based on your prior activities;
- to detect, investigate and prevent activities that may be illegal, or that may violate these Terms and Conditions.
The receipt, use and retention of your personal data shall be subject to the
Personal Data Protection Act of Singapore.
If you should consent, from time to time you may receive from us a variety of communications, including but not limited to newsletters, emails and text messages (the “Marketing Communications”), that will include service updates, product advertising and offers related to our Services which we believe you may be interested in.
At any time, you may change your Marketing Communications preferences, either by:
- electing to opt out from the Marketing Communications sent to you by following the ‘unsubscribe’ link which can be found at the bottom of the emails; or
- contacting our team directly using the ‘Contact Us’ option, found either in the email we sent or on the Website.
Aside from Marketing Communications, please note that from time to time, you may receive some important service information that we believe is critical to the use of our Services. In these exceptional circumstances, such information will be sent to you regardless of your Marketing Communications preferences.
If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
You are advised that if they wish to deny the use and saving of Cookies from this Platform on to their computers and/or other electronic devices, they should take the necessary steps within their internet browsers’ security settings to block all Cookies from this Platform.
You can choose to delete the Cookies at any time. However, you may lose any information that enables you to access the Platform more quickly and efficiently including but not limited to personalisation settings.
For the avoidance of doubt, “Cookies” are small files saved to the User’s computer hard drive that track, save and store information about the User’s interactions and usage of the Platform. This allows the Platform, through its server to provide the users with a tailored experience within this Platform. Cookies may or may not involve the collection of personal information.
Disclosure and Sharing
We will not share your personal information with anyone else unless you have consented to this, other than in limited circumstances including the following:
- where third companies perform services, such as email delivery, hosting and payment processing, for the purpose of providing you with products and services that you request from us. However, these companies will only be entitled to use your personal information in order to provide the services requested by us or as may be required by law;
- to the extent that we are required to do so by applicable law, by a governmental body or by a law enforcement agency, or for crime prevention purposes;
- if we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of those business or assets in accordance with applicable data protection laws, or if a third party acquires all (or substantially all) of our business and/or assets, in which case we may disclose your personal data to that third party in connection with the acquisition;
- where necessary to enforce these Terms and Conditions, to protect the safety of our users and third parties, to protect our rights and property and the rights and property of other users and third parties, or in other cases if we believe in good faith that disclosure is required by law;
- we may share anonymous information and aggregated information (meaning information about groups and categories of users, including statistics and behaviour, but which does not identify and that cannot reasonably be used to identify any individual user) with our advertising partners. We may also allow our advertisers to collect anonymous information and aggregated information within the Services and they may then share that information with us. Our advertisers may collect this information through the use of tracking technologies like Cookies and web beacons. This enables our advertisers to develop and deliver targeted advertising in the Services and on the websites of third parties, so that they can try to serve you with advertisements for products and services that are most likely to be of interest to you. Advertisers will also use this information to monitor, improve, or modify their operations.
We take reasonable precautions to prevent the loss, misuse or alteration of your personal information. Our employees, contractors and agents may be given access to your personal information which we collect, but their use shall be limited to the performance of their duties in relation to facilitating your use of the Platform and/or Service. Our employees, contractors and agents who have access to your personal information are required to keep that information confidential and are not permitted to use it for any purposes other than those listed above or to deal with requests which you submit to us.
We have implemented all reasonable technical, administrative and physical security measures to protect the security of your information. However, although we will do our best to protect your information from unauthorised access, disclosure and modification, no security measures are perfect and we cannot guarantee the security of your information nor can any transmission over the Internet can ever be guaranteed to be totally secure and therefore we cannot ensure or warrant the security of any personal information that you transfer over the Internet to us.
Third party sites
Subject to applicable law, you may exercise the following choices:
- you may ask us to provide you with copies of the personal information that we hold about you at any time, subject to a reasonable administrative fee for the handling and processing of your request. For the avoidance of doubt, such reasonable administrative fee will be disclosed to you upon your request to access your personal information;
- you may ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge;
- if you have opted to receive information about other products and services and about offers and promotions, then you may opt out from receiving any further information.
If you wish to exercise any of these choices, then please contact us at email@example.com. If you ask us to delete personal information about you then we may retain an archived copy of this information if required to do so by
Changes to this Term
We may change this Term from time to time for various reasons such as changes to reflect in law and regulation, changes in industry practices and technological developments. The latest version of this Term will always be available on the Sites. Subject to applicable law, any new version of this Term shall take effect (i) immediately upon the date of posting on the Platform where the changes to this Term relate to non-material changes which do not reduce your rights; or (ii) no less than thirty (30) days after the date of posting on the Platform where the changes to this Policy potentially reduce your rights. Please make sure you check for updates to this Term each time you use the Platform and/or Service.
If you wish to create an account on the Platform and/or use the Service, you will need to accept our Terms of Conditions, including this Term 16. If you do not want us to collect, store or use your personal information or do not wish to accept these Terms for any other reason, then please do not use the Platform or create an account.
We are committed to ensuring that the information we collect is secure. In order to prevent unauthorised access or disclosure of your information, we have implemented suitable physical, electronic and managerial procedures to safeguard and secure your information. We follow generally accepted industry standards to protect your information, both during transmission and storage. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. In light of the aforementioned security safeguards and procedures which we have implemented, you acknowledge and agree that we have taken all reasonable efforts to ensure the security of your information. Accordingly, you agree not to hold us liable for any failure, losses or damages which may arise due to matters beyond its reasonable control. (i.e. a compromise in Gembridge’s security safeguards by unauthorised parties, hacker attacks, unscheduled downtimes, database failure, or other failures or malfunctions which cannot be attributable to us).