“Sensitive personal data” means special categories of personal data, specifically, information about your race, ethnic origin, political opinions, religious beliefs, any health and genetics, biometrics (where used for ID purposes) and criminal convictions.
“ASPL”, “We”, “we”, “our” or “us” means ActivEdge Solutions Pte Ltd and its affiliates.
We collect and use a range of personal information you provide us when you participate in ActivChallenge or any events, promotions, surveys, competitions or activities associated with ActivChallenge using our Platforms or via third party platforms in order to deliver and improve our services, including:
We collect your personal data directly from you unless it is unreasonable or impractical to do so. We do this in a number of ways including:
We may also collect personal data from third parties including:
We may receive your personal data from you or from third parties which we use:
Applicable data protection laws require that we can use your personal data only where we have a valid purpose to do so and legal basis. In certain circumstances we may ask for your consent to process your data, and at other times, we may be required to process your information to enable us to fulfil our part of the contract we have with you.
Where you have indicated your consent or we have a legal basis, we (and permitted third parties) may contact you for direct marketing purposes via post, telephone, email, SMS/MMS, push notifications, and social media channels such as Facebook, TikTok, Instagram, Twitter and WhatsApp.
This marketing may relate to:
If you are an existing customer and you have not opted out of receiving that marketing by methods provided in this Privacy Notice, we will only contact you by electronic means without seeking your consent in advance (including but not limited to telephone, e-mail, SMS/MMS, push notifications, and social medial channels such as Facebook, Instagram, Twitter and WhatsApp) with information about services similar to those which were the subject of a previous dealing with you.
If you are signing-up to register and participate in any ActivChallenge event, competition or promotion, or requested from us information related to ActivChallenge, and in each case you have not opted out of receiving that marketing by methods provided in this Privacy Notice, we will contact you by electronic means (including but not limited to telephone, e-mail, SMS/MMS, push notifications, and social medial channels such as Facebook, Instagram, Twitter and WhatsApp) to provide you information or notify you on upcoming events, activities, promotions, new products / services or other opportunities as well as those of third parties partners/sponsors in relation to ActivChallenge.
We use Intuit Mailchimp for our marketing emails and newsletters. So when you register or subscribe to our email marketing or newsletter services, the email address and name you submit will be held securely by them and the information also made accessible to us. You can read their full privacy policy here: https://www.intuit.com/privacy/statement/
We may also combine the information you provide us at sign-up on our Platforms with data from other sources to help us improve the relevance of the emails we send you. For example if you sign-up to an ActivChallenge event, we will record that information in your subscriber profile to ensure that the content of our emails reflects that.
Third-party Marketing
We will get your opt-in consent before we share your personal data with any third-parties outside ASPL for their own marketing purposes
You may unsubscribe from marketing email communication sent by our Platforms or third parties at any time by following the unsubscribe link found at the bottom of every email communication you receive or by requesting us to remove you and your personal data collected electronically from our database(s) by emailing admin@activedge.sg. You may also opt-out of any marketing communications you receive from our third-party ASPL partners by using any of the unsubscribe methods that may communicated in their respective privacy notices.
If you unsubscribe, we will retain your email address for the purposes of a suppression list to ensure that no further marketing messages can be sent unless you actively choose to opt-in again.
An IP address is a number that is automatically assigned to your device every time you browse the internet. When you visit our Platforms, the server used by our web host will make a record of your IP address, together with the date and time of your visit, the type of internet browser you use and the URL of any other websites that referred you to our Platforms.
We may also log IP addresses to analyse trends, administer our Platforms, track user movements, and gather broad demographic information.
In some cases, we may also collect your personal data through the use of cookies. When you access our Website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your device. This enables us to recognize your device and customise the online experience. It also helps us keep track of services you view, so that we can send you news about those services. We also use cookies to measure traffic patterns, to determine which areas of our Website have been visited, and to measure transaction patterns in the aggregate.
You may also set your browser to block all cookies, including cookies associated with our website, or to indicate when a cookie is being set by us. However, it’s important to remember that our website may not function properly if your cookies are disabled. For example, we may not remember your language preferences
We are not responsible for the practices employed by websites or services linked to or from our Platforms, including the information or content contained therein or the data collection practices or privacy policies therein. Please remember that when you use a link to go from our Platforms to another website, our Privacy Notice does not apply to third-party websites or services. Your browsing and interaction on any third-party websites or service, including those that have a link or advertisement on our Platforms, are subject to that third party’s own rules and policies. For example, when you sign-up to register and attend any online or offline fitness classes, activities or events in relation to ActivChallenge via a third party link on our Platforms, our Privacy Notice does not apply to your use of such third party site or any personal data you may share with such third party websites. We are not responsible for the privacy practices of such third-party websites and encourage you to read the privacy statements of any such third-party sites.
In addition, you agree that we are not responsible, and we do not have control over any third-parties that you authorize to access your user content. If you are using a third-party website or service (like Facebook, Instagram, Twitter, Instagram, or Google groups etc.) and you allow such a third-party access to your user content you do so at your own risk. This Privacy Notice does not apply to information we collect by other means (including offline) or from other sources other than through our Platforms.
We will share personal data, within ASPL or with third parties we implement robust contractual agreements with third parties to confirm that your personal data will be handled in compliance with relevant data protection laws, such as personal data protection laws applicable in the UAE.
We share your personal data when one of the following circumstances apply:
When we collect and process your personal data, we might also share your personal data with our ASPL affiliates who may sometimes need to access your information to provide services to you on our behalf. Because ASPL is passionate about your privacy, we have made the decision to ensure the same level privacy protection throughout our business.
Legally, other ASPL affiliates will then be acting as ‘data processors’ to process your personal data on our behalf and based on our specific instructions. These processors will also be subject to data protection laws and will only process your personal data in compliance with our Privacy Notice and any other appropriate confidentiality and security measures.
When you register for certain events or promotions in relation to ActivChallenge on our Platforms, your personal data may be shared with our event organisers and partners that are responsible for the organisation or management of that particular event or promotion on our behalf or we collaborate with in order to arrange and deliver programmes, competitions, and other initiatives in relation to ActivChallenge. The data shared will be limited to those strictly necessary for the event or promotion you have registered, and our event partner or organiser will process your data strictly limited to the purpose for which the personal data is collected.
We provide your information to our service providers who may receive or otherwise have access to your personal data or non-personally identifiable information, depending on the nature of their services and purposes in facilitating and enhancing ActivChallenge’s services, and may only use it for such purposes. These include data analytics services (such as Google Analytics), email marketing services (such as Intuit Mailchimp) and other service providers. ASPL as the controller of the information collected from you in connection with the use of our Platforms remains responsible for the any personal data processing done by such service providers on our behalf
We will disclose personal data when required by any applicable law (for example to fulfil national security obligations we may share personal data with national security agencies such as Singapore Police Force and other departments of the Government of SIngapore), or in good faith believe such action is necessary or desirable to comply with the applicable laws, or to protect or defend the rights or property of ASPL, our Platforms, or their users.
We may disclose your personal data to third parties in the following circumstances:
The personal data that we collect from you may be transferred to, stored and otherwise processed on servers located outside the country in which you reside and which may be located in secure data centres worldwide, and personal data may be stored in any one of them.
We will retain your personal data for the period necessary to full the purposes outlined in this Privacy Notice. When assessing these periods, we carefully examine our need to collect personal data at all and if we establish a relevant need we only retain it for the shortest possible period to realise the purpose of collection unless a longer retention period is required by contractual obligation or law.If we no longer need to use or disclose your personal data for the purposes set out in this Privacy Notice and we are not legally required to retain that information, then we will take reasonable steps to destroy your personal data or ensure it is rendered anonymous (i.e. turned into non-personally identifiable information).
Under certain circumstance, you have a number of rights with regard to your personal data that we must comply with. The rights you have are:
You have the right to be informed about the collection and use of your personal data by us or, on our behalf, by a third party.
You have the right to obtain from us confirmation as to whether or not your personal data is being processed and, if so, the right to access that personal data. This right does not apply where it would adversely affect the rights and freedoms of another person.
You have the right to request that we correct any inaccurate personal data and we must comply in a timely manner. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed.
You have the right to request the erasure of your personal data, in our possession, in a timely manner.
You have the right to request the restriction of use of your personal data, where the data is not being used for the purpose it was collected for or if you request that we correct any inaccurate personal data (in this case the processing will be restricted for a certain period).
You have the right to object at any time to our use of your personal data where the processing is carried out for direct marketing purposes including profiling relating to direct marketing.
Where you have provided personal data for us to use with your consent* or as required for us to fulfil our contractual obligations to you and the processing is carried out by automated means, you have the right to receive personal data that you have provided us in a structured, commonly used format in order for you to provide that personal data to another organisation for use as you so wish. This right does not apply where we are using the personal data to carry out a public duty (e.g. security or compliance).
*This includes sensitive personal data such as biometric, health or political or religious beliefs provided with your explicit consent.
You have the right to submit a formal written complaint to a data protection regulator who can resolve any complaints regarding the transfer of personal data that we cannot resolve with you directly.
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significantly affect you.
When we process your personal data based on your consent, you have the right to withdraw it and inform us that you no longer wish us to collect, store, or use your personal data, where there is no other legal basis for us to do so.
ASPL have procedures in place to ensure that it deals with any requests it receives in an efficient manner. You can exercise any of these rights by contacting us at admin@activedge.sg.
We will take all reasonable steps to protect the personal data that we hold from misuse, loss, or unauthorized access, including by means of firewalls, password access and secure servers. In particular, we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems, and restrict access to personal data to our employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet. If you suspect any misuse or loss of, or unauthorized access to, your personal data, please let us know immediately.
We regularly review our compliance with our Privacy Notice. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.
In the future, we may revise or amend this Privacy Notice at any time by amending this page to publish a new version. All changes will be made here so you will always know what information we gather, how we might use that information and whether we will disclose it to anyone. We recommend that you revisit this page from time to time to keep informed of our current privacy practices.
