Privacy Policy
- 1. Introduction
- 2. Collection, Use and Disclosure of Personal Data
- 3. Confidentiality
- 4. Changing or Deleting Your Information
- 5. Protecting Your Personal Data
- 6. Cookies
- 7. Special Information for EU Users
- 8. Third-Party Sites
- 9. Security Measures
- 10. Changes to Privacy Policy
- 11. Contacts
- 12. General
1. Introduction
- 1.1. This Privacy Policy governs our Website (such as https://chatq.sg) and any associated software, including all modifications, enhancements or updates thereto (the “Website”) as operated by ChatQ Pte Ltd. (“ChatQ”, “We”, “Our” or “Us”). Terms used herein shall unless otherwise defined bear the same meanings as in our Terms and Conditions.
- 1.2. Your privacy is very important to us and we are committed to maintaining your trust. Accordingly, we have developed this Privacy Policy in order for you to understand how we collect, use, communicate, disclose and make use of your personal data. For the avoidance of doubt, we will not share your personally identifiable information except as provided herein.
- 1.3. By accessing or using our Services, you shall be deemed to have accepted to be legally bound by the terms of this Privacy Policy. Your continued use of our Website after any changes to this Privacy Policy, whether or not reviewed by you, shall constitute your consent and acceptance of the revised terms. If you do not agree to the terms of this Privacy Policy, please do not access or use our Website.
2. Collection, Use and Disclosure of Personal Data
- 1.1. We may collect the following personal data from you:
- Device and Connection Information. We collect device-specific information when you access or use our Website. This includes information such as the hardware model, operating system information, browser information, IP address, country, and location;
- Usage and Log Information. We collect service-related, diagnostic, and performance information when you use our Website. This includes information about your activity (such as how you use our Website, how you interact with other ChatQ users using our Website, etc), log files, and diagnostic, crash and performance logs and reports;
- Account Information. When you create a ChatQ account, we collect the personal information you provide to us, such as your name, email address, and picture.
- Voluntarily Provided Information. We collect voluntarily provided information to us, such as when you fill our onboarding questionnaire. This information may include your name, email address, job title, company and how you found out about ChatQ;
- Customer Support and Feedback. We collect copies of your messages, questions, comments, suggestions, ideas, feedback, or other information regarding the Website from you.
- Payment Information. If you pay for our Services, we use a third-party service such as Chargebee to process your payments. These third-party services will collect your information including your name, email address, mailing address, payment card information, and other billing information. We may receive information and confirmations, such as payment receipts from third-party services.
- Cookies. We may use cookies to operate and provide our Website, including to provide third-party services that are web-based, improve your experiences, understand how our Services are being used, and customise our Website. We may also use cookies to show you relevant content related to our Website. Additionally, we may use cookies to remember your choices, such as your language preferences, and otherwise to customise our Website for you;
- Third-Party Providers. We work with third-party providers to help us operate, provide, improve, understand, customise, support and market our Website. These providers may provide us information about you in certain circumstances;
- Third-Party Services. We allow you to use our Services in connection with third-party services. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services. We may also collect information about you and your trades from Trade Execution Providers whom you have identified and permitted.
- 1.2. We may collect, use and/or disclose your personal data for the following purposes:
- setting up your registered user account and profile on the Website;
- to provide and improve our Website, including informing you of any change or updates in our Website;
- to organise the data to allow you to view, manage, or to help you visualise your data;
- for targeted online marketing;
- for accounting, billing and verification purposes;
- to contact you regarding any complaints, feedback, queries, requests, claims or disputes;
- to facilitate investigations into or to take action regarding any suspicious or illegal activity on the Website;
- for internal administrative and management purposes;
- where required by any act, statute, law, or regulation, rules, directives, or by the order of a government authority or a court or tribunal of competent jurisdiction;
- such other purposes as consented to by you;
- any other purpose reasonably related to the aforesaid.
- 1.3. We may disclose your personal data to our partners, service providers, contractors, select vendors and affiliates whom we have engaged to provide our Services (including Trade Execution Providers), to maintain this Website or to protect the security or integrity of this Website and our databases.
- 1.4. We may also share your personal data with other third parties in our partner network. If we do so, this will be strictly on an anonymised or aggregated basis, whereby all identifying information has been removed, such that the remaining data does not identify any particular persons.
3. Confidentiality
Save where expressly provided herein, we will not reveal to any person or company any which may come to our knowledge hereunder and shall keep with complete secrecy the personal data provided by you and shall not use or attempt to use any such personal data in any manner without your permission. These restrictions shall cease to apply to information or knowledge which may come into the public domain other than as a result of any act or breach of this Privacy Policy by us.4. Changing or Deleting Your Information
- 4.1. You may review and change your personal data in your account settings. We will not be responsible for any modification of your personal data specified in your account.
- 4.2. We will only retain your personal data as long as necessary for the fulfilment of the purposes stated in this Privacy Policy and any applicable terms and conditions.
- 4.3.You have a limited right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal data, please send an email to [email protected]. There may be a small charge for this service.
- 4.4.We want to ensure that your personal data is accurate and up to date. If any of the information that you have provided to ChatQ changes, for example, if you change your email address or payment details, please let us know the correct details by sending an email to [email protected]. You may ask us, or we may ask you, to correct the information that you or we think is inaccurate, and you may also ask us to remove information that is inaccurate.
5. Protecting Your Personal Data
- 5.1. Your account information is protected by a password chosen by you. It is important that you protect against unauthorised access of your account and information by choosing your password carefully and keeping your password and computer or mobile device secure by signing out after using our Website.
- 5.2. You should also take appropriate measures to keep your information, software and equipment secure. This includes clearing your browser cookies and cache before and after using any services on the Website.
- 5.3. Where appropriate, we will take reasonable security safeguards to protect your personal data against loss or theft, as well as unauthorised access, disclosure, copying, use or modification. Please be aware that the sending of information via the internet is not completely secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically, and you send such information at your own risk. We do not accept liability for the security, authenticity, integrity or confidentiality of any transaction and other communications made through the Website.
- 5.4. Internet communications may be susceptible to interference or interception by third parties. Despite our best efforts, we make no warranties that the Website is free of viruses or other unauthorised software.
6. Cookies
When you access third-party services or webpages through the Website, such third parties may use cookies in connection with their operations or your use of their services. Cookies may transmit information about you, such as your IP address, data relating to advertisements that have been displayed to you and the date and time of your use. Cookies may be persistent or stored only during an individual session. Please refer to the privacy policies of such third parties to learn how they use cookies. Third parties may be able to associate the information they collect with other information they have about you from other sources. We do not necessarily have access to or control over the Cookies that they use.7. Special Information for EU Users
- 7.1.The processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”). This section summarises our grounds for processing personal information under the GDPR and the rights of EU users as relates to our handling of personal information. If you are a user in the EU, you have the following rights with respect to our handling of your personal information. To exercise these rights, please see below. Users outside the EU may also request for access, correction, deletion or copies of their personal data.
- 7.1.1. You have the right to request for access to the information that we have about you and how we use that information.
- 7.1.2. You also have the right to receive a copy of the information that we collect about you if collected on the basis of consent or because we require the information to provide the services that you request.
- 7.1.3. If we have information about you that you believe is inaccurate, you have the right to request for your information to be corrected.
- 7.1.4. You may also request that we:
- Provide a detailed explanation regarding the information we have collected about you and how we use that information;
- Provide a copy of the information that we have collected about you; and
- Correct any inaccurate information that we have about you. Please contact us at [email protected]
- 7.1.5. Account deletion.
- We retain user profile and other information for as long as you maintain your account. We retain transaction, location, usage and other information for 7 years in connection with regulatory, tax, insurance or other requirements in the places which we operate. We take steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.
- You may request deletion of your account at any time. We may retain certain information about you as required by law and for legitimate business purposes permitted by law. In certain circumstances, we may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete your account as described above.
- We may also retain certain information if necessary, for legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if we shut down a user’s account because of unsafe behaviour or security incidents, we may retain certain information about that account to prevent that user from opening a new account in the future.
- 7.1.6. You have the right to object to our processing of personal data, including for marketing purposes based on profiling and/or automated decision making. We may continue to process your information notwithstanding the objection to the extent permitted under the GDPR.
- 7.1.7. Users in the EU also have the right to file a complaint relating to our handling of your personal information. You may submit your questions, comments or complaints to our Data Protection Officer. Please contact [email protected].
- 7.2. The GDPR requires that companies processing the personal data of EU users do so on the basis of specific legal grounds. As described below, we process the information of EU users based on one or more of the grounds specified under the GDPR:
- 7.2.1. If the processing is necessary to provide the services and features you request, we must collect and use certain information to provide our services. This includes (a) user profile information that is necessary to establish and maintain your account, including to verify your identity, orders and accounts and to enable you to make payments, (b) transaction information, which is necessary to generate and maintain in connection with your use of our Services and (c) usage information, which is necessary to maintain, optimise and enhance our Services.
- 7.2.2. We may process your personal information, including disclosing data with law enforcement authorities in case of threats to the safety of users or of others.
- 7.2.3. We collect and use personal information to the extent necessary for our legitimate interests which include collecting and using information:
- To maintain and enhance our user’s safety and security. For example, we may collect background check information (where permitted by law) to prevent unsafe users from providing services through our apps. We also use personal information to prevent use of our services by users who have engaged in inappropriate or dangerous behaviour, such as by retaining information of banned users to prevent their use of our Services.
- To prevent, detect and combat fraud in connection with the use of our Services. For example, we use user profile, location, device and usage information, to identify and prevent circumstances when users attempt to defraud us or other users.
- To inform law enforcement officials regarding criminal acts or threats to public safety.
- To provide customer support.
- To optimise our Services and develop new services.
- For research and analytical purposes. This includes analysing usage trends to improve the user experience and enhance the safety and security of our Website.
- For direct marketing purposes. This includes analysing data to identify trends and tailor marketing messages to user needs.
- To enforce our End User License Agreement.
- 7.2.4. We collect and use personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. We may also process personal information when necessary in regards to a substantial public interest, on the basis of applicable laws.
- 7.2.5. We are subject to the legal requirements in the jurisdictions in which we operate that require us to collect, process, disclose and retain your personal data. We use your information to comply with such laws to the extent they apply to your use of the Website.
- 7.2.6. We may share your information with law enforcement, or requests by third parties pursuant to legal processes.
- 7.2.5. We may collect and use information on the basis of your consent. You may revoke your consent at any time. If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.
- 7.2.7. We rely on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you.
8. Third-Party Sites
Our Services may contain links to sites operated by third parties, such as our business partners. We are not responsible for the privacy practices of sites operated by third parties that are linked to our Website. We encourage you to learn about the privacy policies of such third-party sites. You should check the applicable terms, conditions and policies of the third-party sites to determine how they will handle any Personal Data they collect from you.9. Security Measures
The security and confidentiality of your Personal Data is extremely important to us. We have implemented technical, administrative and physical security measures to protect user information from unauthorised access and improper use. From time to time, we review our security procedures in order to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect and impenetrable, and no data transmissions over the web can be guaranteed to be fully secure. We cannot ensure or warrant the security of any information you transmit to us and do so at your own risk.10. Changes to Privacy Policy
The terms of this Privacy Policy may be revised, changed and updated from time to time without notice to you. All changes will be posted within the Website, and your continued access or use of the Website after such changes have been posted will constitute your agreement to the modified Privacy Policy and all of the changes. We therefore encourage you to read this Privacy Policy each time you access this Website.11. Contacts
If you wish to revoke your consent to the collection, use and disclosure of your personal data, or if you have any comments, concerns or questions about this Privacy Policy, our policies and practices, please contact [email protected]