Privacy Policy | Treasure Play

Treasure Play – Privacy Policy

Updated September 24, 2024

This Privacy Policy (the “Policy”) outlines how Treasure Play Pte. Ltd. (“Company”, “we”, “us” “our”) collects, uses and discloses your Personal Data (defined below) when using our Platform. This Policy should be read together with, and forms part of, the Terms which are available on our Platform. Unless otherwise defined herein, capitalized terms in this Policy have the meaning given to them in the Terms.

We recognize the importance of protecting Personal Data in accordance with the Singapore Personal Data Protection Act 2012 (2020 Rev. Ed.) (“PDPA”) and are committed to complying with applicable data protection laws. Please read this Policy so that you know and understand the purposes for which we collect, use, store and disclose Personal Data.

By accessing and using the Platform, interacting with us or providing your data to us, and subject to your rights at law, you accept and agree to the terms contained in this Policy. If you do not agree with any aspect of this Policy, you should immediately discontinue access or use of the Platform.

This Policy supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which the Company may have at law to collect, use or disclose your Personal Data.

We may from time to time update this Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time. Please check back regularly for updated information on the handling of your Personal Data.

For purposes of this Policy, “Personal Data” means any information that directly or indirectly identifies a particular individual, including any other information that is subject to applicable data protection laws.

Scope

This Policy applies to our collection, use and disclosure of Personal Data related to the Users of our Platform. This Policy does not apply to job applicants or to Company employees and non-employee contractors, whose Personal Data is subject to different privacy notices.

Collection of Personal Data

The Personal Data we collect varies depending on your use of our Platform.

Types of Personal Data Collected. While the Personal Data we collect varies depending upon the circumstances in which you use the Platform, we generally collect the following categories of Personal Data:

Name, contact information and other personal identifiers: identifiers such as your name, age, sex, location, mobile number and email address.
Customer records: electronic customer records containing Personal Data.
Device information: internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, and mobile advertising identifiers (including your Identifier For Advertisers (IDFA) and Google Advertising ID (GAID) as applicable).
Communications and requests: direct communication, web forms, online polls, or interactions with our Platform. We collect and maintain a record of your contact details, communications and our responses.
User Content: if you post Content on the Platform, if you interact with any other User or if you submit feedback and comments to us, we may maintain a record of your Content, including the location, date and time of submission, as well as any other information contained in that Content.
Transaction information: including records of transactions made using your User Account on the Platform.
User activity: when you use our Platform and any Third-Party Applications, we may track your clicks, swipes, engagements etc. with our Platform and any Third-Party Applications.
Cookie data: as explained in more detail later in this Policy.
Marketing, surveys and events: if you sign up to receive news, updates, offers and other marketing communications from us, we may collect your name, contact information and information about your preferences.
Location data: location information about a particular individual or device, general location information (for example, your IP address may indicate your more general geographic region).
Profiles and inferences: inferences drawn from any of the information identified above to create a profile reflecting your preferences.

Sources of Personal Data.

We may collect Personal Data:

Directly from you: such as when you use our Platform, make a transaction on our Platform (e.g. by spending Platform Rewards), participate in promotions we offer, register to receive marketing and other communications from us or contact us for customer support purposes. If you submit any Personal Data relating to other people to us, you represent that you have the authority to do so and have informed that other person about the contents of this Policy.
From third parties: we may collect information about you relating to your usage of Third-Party Applications from the developers of the Third-Party Applications.
Related to your use of our Platform: including information we collect automatically when you use our Platform or interact with us or information we derive about you and your preferences or interests based on the Personal Data we collect and our interactions with you. This information may be collected via cookies when you use our Platform and you can find more details about our use of cookies later in this Policy.

Use of Personal Data

We, and our authorized third parties, will only process your Personal Data where we have the legal grounds to do so. We may use Personal Data for a variety of purposes, as follows:

Providing the Platform: to provide the Platform (including Consumer Services and Platform Rewards), to fulfill your transactions and requests on the Platform, to provide technical support; and for other customer service and support purposes. Our lawful basis is to fulfill any contractual terms with you.
Analyzing and improving our business: to better understand how Users access and use our Platform, to evaluate and improve our Platform and business operations and to develop new features, offerings and services; to conduct surveys and other evaluations (such as customer satisfaction surveys); to monitor consumer interest in our products and Platform; to troubleshoot problems that may arise on the Platform; to improve the accuracy of our User database; to increase our understanding of our Users; and for other research and analytical purposes. Our lawful basis is our legitimate business interests in understanding and improving our Platform or consent where we use cookies or similar technology that are not strictly necessary.
Personalizing content and experiences: to tailor content we send or display on our Platform and to otherwise personalize your experiences. To assist in these purposes, as well as the other purposes identified in this Policy, at certain times, we may create a profile relating to you in order to show you the content that we think you might be interested in and to display the content according to your preferences. Our lawful basis is our legitimate business interests in offering a more personalized service or consent where we use cookies or similar technology that are not strictly necessary.
Advertising, marketing and promotional purposes: to reach you with more relevant advertising and to evaluate, measure and improve the effectiveness of our ad campaigns; to send you newsletters, offers or other information we think may interest you; to contact you about our Platform or other information we think may interest you; and to identify potential new customers. Our lawful basis is your consent to subscribe to any newsletter or marketing (and you can unsubscribe at any time) and consent where we use cookies or similar technology that are not strictly necessary.
Training of artificial intelligence (AI) models and for analytics: to train and develop our AI models. We may also use AI to analyze Personal Data to identify trends, preferences and patterns etc.
Securing and protecting our business: to protect and secure our business operations, assets and Platform; to investigate, prevent, detect and take action regarding Fraudulent Engagements, unauthorized access, situations involving potential threats to the rights or safety of any person or third-party, or other unauthorized activities or misconduct. Our lawful basis is our legitimate business interests in protecting our business and Platform.
Defending our legal rights: to manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend or protect our rights or interests, including in the context of anticipated or actual litigation with third parties. Our lawful basis is our legitimate business interests in protecting our business or our need to defend ourselves legally.
Auditing, reporting, corporate governance, and internal operations: relating to financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions; and relating to any actual or contemplated merger, acquisition, asset sale or transfer, financing, bankruptcy or restructuring of all or part of our business. Our lawful basis is our legal obligations under relevant legislation such as tax, reporting and/or our legitimate interests in running our compliance programs.
Complying with legal obligations: to comply with the law, our legal obligations and legal process, such as warrants, subpoenas, court orders, and regulatory or law enforcement requests. Our lawful basis is compliance with applicable law.

Where we have indicated above that we rely on legitimate interests for processing of Personal Data, we carry out assessments of likely adverse effects and if required a ‘balancing’ test to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing.

Aggregate and De-identified Data. We may de-identify information and create anonymous and aggregated data sets and reports to assess, improve and develop our Platform, prepare benchmarking reports on our industry and for other research, marketing and analytics purposes. We may also use Personal Data to train our AI models; in the event we use Personal Data for this purpose, we will, to the extent possible, strive to anonymize and de-identify your Personal Data.

Disclosure of Personal Data

We may share or disclose the Personal Data that we collect as follows:

Service providers: We may disclose Personal Data to third-party service providers who may use this information to perform services for us, such as developers, auditors, advisors, consultants, customer service and/or support providers.
Advertising and marketing partners: We may share Personal Data with third parties that provide advertising, campaign measurement, online and/or mobile analytics, and related services. This is subject to any consents you give for direct marketing and cookies.
Developers of Third-Party Applications: We may share Personal Data with developers of Third-Party Applications in the course of providing Business Services to them.
Subsidiaries, Affiliates, and business partners: We may share your Personal Data with our Affiliates and other businesses we have partnered with to offer exclusive content on our Platform; they may use such Personal Data for the purposes set out in this Policy.
Legal compliance: We may be required to share Personal Data in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.
Business transfers: We may disclose and/or transfer Personal Data as part of any actual or contemplated merger, sale, transfer of assets, acquisition, financing and/or restructuring of all or part of our business, bankruptcy or similar event, including related to due diligence conducted prior to such event where permitted by law.
Protect our rights: We may disclose Personal Data where we believe it necessary to respond to claims asserted against us, to enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation and/or to protect the rights, property or safety of the Company or our Affiliates, partners, clients, customers and/or others.

We ensure third parties who receive your Personal Data will handle your Personal Data as required by applicable data protection laws, such by putting in place appropriate contracts with third parties to protect your Personal Data.

Cookies and Analytics

Cookies are small alphanumeric identifiers or small data text files that are sent from a server during a browsing session and are placed on your computer. When we refer to “cookies” we include other technologies with similar purposes, such as pixels, tags and other identifiers.

We use cookies or similar technologies, which may be provided by third parties, on our Platform to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information about our Platform and the emails that we send, and to personalize content and provide more relevant ads and information. We may combine the information we collect via these technologies with other information, including Personal Data. We always ask for your consent on the first time you use our Platform before deploying cookies.

Children's Privacy

Following the Terms, our Platform is restricted for Users under 13 and they are not allowed to use our Platform. The Company does not knowingly collect or maintain Personal Data from children we actually know at the time of collection are under the age of 13. Should we discover that we have collected Personal Data online from a child who is under 13, we will promptly delete that Personal Data. If you have concerns over the collection of children's Personal Data in our Platform, please contact us at the information provided in the Contact Us section below.

Security

The security of your Personal Data is important to us. We have put in place safeguards to protect the Personal Data we collect from unauthorized access, use and disclosure, and we take steps to ensure that all of our employees, agents, contractors and other third parties have similar adequate measures in place. We also have procedures to deal with any suspected Personal Data breach, and we will notify you and any applicable regulator when we are legally required to do so. However, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your Personal Data safe, such as choosing a strong password, enabling two-factor authentication (2FA) and logging out of your User Account and closing your web browser when you have finished using the Platform.

Transfers Outside your Home Country

We may transfer your Personal Data to countries outside of your home country. The privacy laws in countries outside your home country may be different from those in your home country.

For users in Singapore, if we transfer your Personal Data to a country with less stringent data protection standards than that prescribed under the PDPA, we will ensure that there are security measures or other safeguards in place to protect your Personal Data.

If we transfer your Personal Data to countries outside of your home country, we will take steps to comply with the requirements for such transfer in your home country as required by relevant law.

Links to Third-Party Applications

Our Platform provides links to various Third-Party Applications. This Policy does not apply to Third-Party Applications that are accessible through the Platform. When you click on one of these links, you will be transferred out of the Platform and connected to the Third-Party Application. Even if an affiliation exists between our Platform and the Third-Party Application, we exercise no control over and assume no responsibility for linked Third-Party Applications. Each of these linked Third-Party Applications maintains its own independent privacy and data collection policies and procedures. We encourage you to read the privacy policies of those other Third-Party Applications to learn how they collect, use, share, and secure your information before providing any Personal Data.

Retention

Except to the extent prohibited by law, and subject to this Policy, we will retain and use your Personal Data for as long as it is needed to provide you with the Platform, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. As soon as it is reasonable to assume your Personal Data is no longer needed or required, we will cease to retain your Personal Data.

Your Rights

By law, you have a number of rights when it comes to your Personal Data. Further information and advice about your rights can be obtained from the data protection regulator in your country. The rights you have depend on the jurisdiction in which you are based.

You may request for a copy of the Personal Data which we hold about you or information about the ways we use or disclose about your Personal Data. You may also ask us to correct or update your Personal Data, or withdraw your consent and request us to stop using or disclosing your Personal Data for any of the purposes stated in this Policy.

You may do so by submitting your request in writing or via email at the contact details provided in the Contact Us section below.

We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request in some circumstances.

We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

Depending on applicable law, your rights may include the following:

The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data and your rights. This is why we are providing you with the information in this Policy. If you have any additional questions, for example regarding transfers and locations of data or our legitimate interests basis, please contact us.
The right of access. You have the right to obtain access to your Personal Data (if we are processing it), and certain other information (similar to that provided in this Policy) save for any applicable exemptions to do so under the data protection law. This is so you are aware and can check that we are using your Personal Data in accordance with data protection law.
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete.
The right to restrict processing. You have rights to ‘block’ or suppress further use of your Personal Data. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
The right to data portability. You have rights to have your Personal Data transferred to another organization under certain conditions.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing.
The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your Personal Data with your relevant data protection regulator.
The right to withdraw consent. If you have given your consent to anything we do with your Personal Data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your Personal Data for marketing purposes.

Changes to this Policy

This Policy is kept under regular review and may be updated from time to time. When we make changes to this Policy, we will change the "Updated" date above. If a material change is made to this Policy, we may choose to provide notice to you of such change, such as by posting notice of that change on the first page of this Policy or on our homepage, or by emailing your email address of record with us.

Changes to your Information

It is important that the information we hold about you is accurate and current. Please keep us informed as soon as possible if your Personal Data changes or is inaccurate during your relationship with us by using the contact details set out below.

If you have any concern about our privacy practices, please contact us by email at contact@treasureplay.com, or by writing to us at: Treasure Play Pte. Ltd., 68 Circular Road, #02-01, 049422, Singapore.