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PRIVACY POLICY

 

AUNTY PTE. LTD. (“Company”, “we”, “us” or “our”) respects your privacy. This privacy policy (“Privacy Policy”),
which is incorporated into our Terms by reference, describes how Data
(as defined below) provided by you through the Mobile App and Services
is collected, used, disclosed or otherwise processed by us in accordance
with the Personal Data Protection Act 2012 of Singapore (“PDPA”).
It is important that you read this Privacy Policy and our Terms so that
you are fully aware of your rights and our responsibilities in relation
to your data. Except where the context requires otherwise, terms used
in this Privacy Policy shall have the same meanings as those defined in
our Terms.

 

This Privacy Policy applies to all data in our
possession or under our control, including data in the possession of
third parties which we have engaged to collect, use, disclose or process
data for the purposes set out in the Privacy Policy.  

 

This
Privacy Policy applies in conjunction with any other notices,
contractual clauses and consent clauses that apply in relation to the
collection, use and disclosure of your data by us. 

 

1. Acceptance of Privacy Policy

 

1.1
By using or accessing the Mobile App, you acknowledge that you have
read and understood this Privacy Policy, agree to be bound by this
Privacy Policy and conclude a legally binding contract with us, and give
your consent for the collection, use and disclosure of data for the
Purposes (as defined below). If you do not agree to this Privacy Policy,
please do not use or access the Mobile App and/or Services.

 

1.2
We reserve the right, at our sole discretion, to modify or update this
Privacy Policy at any time without notice and all changes will become
immediately effective upon posting on the Mobile App. Your continued use
or access of the Mobile App after such changes have been made
constitutes your acknowledgement and acceptance of, and consent to, such
changes and the amended Privacy Policy. It is your sole responsibility
to check this Privacy Policy regularly for changes. You may determine if
any such revision has taken place by referring to the date on which
this Privacy Policy was last updated. If you do not agree to the amended
Privacy Policy, please do not continue to use or access the Mobile App.

 

1.3
The consent that you provide for the collection, use and disclosure of
your personal data will remain valid until such time it is withdrawn by
you in accordance with this section. You may withdraw consent and
request us to stop using or disclosing your personal data for any or all
of the purposes listed below by submitting your request via email to
our Data Protection Officer, or any of our representative and/or
employee, at the contact details provided below.

 

1.4 Upon
receipt of your request via email to withdraw your consent, we may
require reasonable time (depending on the complexity of the request and
its impact on the provision of our Mobile App and/or Services to you) to
process your request and to notify you of the consequences of us
acceding to your request, including any legal consequences which may
affect your rights and liabilities to us. In general, we shall seek to
process your request within ten (10) business days of receiving it.

 

1.5
Whilst we respect your decision to withdraw your consent, please note
that depending on the nature and scope of your request, we may not be
able to continue providing our Mobile App and/or Services to you and we
shall, in such circumstances, notify you before completing the
processing of your request.

 

1.6 Should you decide to
cancel your withdrawal of consent, please inform our Data Protection
Officer via email at the contact details provided below.

 

1.7
Please note that withdrawing consent does not affect (a) the lawfulness
of any collection, use, disclosure or processing of your personal data
prior to your withdrawal; (b) our right to continue to collect, use and
disclose personal data where such collection, use and disclose without
consent is permitted or required under applicable laws; or (c) the
lawfulness of any collection, use, disclosure or processing of any Data
that is not personal data at any time. 

 

2. Collection of Data

 

2.1 We only collect, store or use information that we consider reasonably necessary for the purposes of providing the Services.

 

2.2
Depending on the nature of your interaction with us, we may collect the
following data provided by you through the Mobile App and/or Services,
which may constitute personal data, including:

 

(a)
Technical data, which includes the URL from which you came to our Mobile
App and/or Services, your internet protocol (IP) address, your login
data, browser type and version, time zone setting and location, browser
plug-in types and versions, operating system and platform, and other
technology on the devices you use to access our Mobile App and/or
Services;

 

(b) Identity data, which includes your first and last name, username or similar identifiers;

 

(c) Verification data, which includes your mobile phone number and/or email address;

 

(d)
Profile data, which includes without limitation your username and
password, full name, address, property type, gender, date of birth,
number of children, children’s gender, email address, occupation,
relevant parties’ information, mobile number, credit card details,
feedback and survey responses, work experiences, work preferences,
specific skills, relevant accreditation, interests, and results from
personality tests, and any other items of information that you provide
to us for the purposes of using or participating in our Mobile App
and/or Services; 

 

(e) Appointment data, which includes
information relating to your appointment for Service Request Jobs and
any other information in relation to the Service Request Job that you
choose to provide;

 

(f) Usage data, which includes information about how you use our Mobile App and Services;

 

(g)
Marketing and communications data, which include your preferences in
receiving marketing materials from us and third parties, and your
communication preferences; and

 

(h) Communications data,
which include your communications, audio and video files and the
information provided therein to Registered Users through our messaging
system on our Mobile App.

 

2.3 You shall take note that your data may be stored and used pursuant to the PDPA.

 

2.4
We will only retain your personal data for as long as necessary to
fulfil the purposes for which it was collected, or as required or
permitted by applicable laws. including satisfying any legal,
accounting, or reporting requirements.

 

2.5 We will cease
to retain your personal data, or remove the means by which the data can
be associated with you, as soon as it is reasonable to assume that such
retention no longer serves the purpose for which the personal data was
collected, and is no longer necessary for legal or business purposes.

 

Cookies

2.6
We use cookies on our Mobile App. Cookies are small files containing a
text-only string of information that our Mobile App transfers to your
device’s hard disk or hard drive. We may use both persistent cookies as
well as session cookies. Session cookies are deleted after you close
your Mobile App. These cookies may be used to store information for
enabling certain functions pertaining to our Services, such as
completing forms, facilitating website navigation, video playback,
authentication, recognising your device when you return to our Mobile
App, and allowing us to compile aggregated statistics that help us
improve the structure and performance of our Mobile App. You may accept
or decline cookies by modifying the settings of your browser. Please be
aware that without cookies, our Mobile App may have limited
functionality or may not work at all. 

 

Registration as a Registered User

 

2.7
If you wish to register with us as a Registered User, you agree to
provide us with, inter alia, the following data about you, which may
constitute personal data, in our registration form for an account on the
Mobile App, and/or with any of our Services:

(a) Full name;

(b) Date of birth;

(c) Gender; 

(d) Address and property type;

(e) Occupation; 

(f) Mobile number; 

(g) Credit card details; 

(h)
Relevant accreditations, qualifications and skills/work experience/work
preferences/personal profile write-ups (for Sitters);

(i) Children’s gender and age (for Parents);

(j) Email address; and

(k) Your password.

 

2.8 You will be required to consent to this Policy in the registration form. 

 

Third Party Websites

 

2.9 Our Mobile App may include links to third party websites, plug-ins and applications (“Third Party Websites”).
Clicking on those links or enabling those connections may allow third
parties to collect or share data about you. We do not control Third
Party Websites and are not responsible for the information they collect
or for their privacy or data protection policies, and will not be
responsible or liable to you for the same. Your use or access of such
third party links is at your own risk and it shall be your sole
responsibility to read the privacy policy of such third parties before
providing your personal data to them.

 

3. Use of data

 

3.1 We may collect and use any data for any or all of the following purposes in connection with the Mobile App and/or Services (“Purposes”),
which in any event shall not extend beyond what is reasonable for us to
provide you with our Mobile App and/or Services including, but not
limited to:

 

(a) to process your registration for the Mobile App and/or Services;

(b) to register you as a Registered User;

(c) to process payment transactions made by you through the Mobile App;

(d)
to provide details of a Service Request Job including but not limited,
to your name, address, mobile phone number and/or email address, upon a
successful matching and valid acceptance of a Service Request Job;

(e)
to contact you in order to respond to your enquiries or requests or to
send you information, notices or updates relating to the Mobile App
and/or Services;

(f) to promote, market or advertise the Mobile
App and/or Services including making marketing calls or sending
marketing messages to your email address or Singapore telephone number
provided by you through the Mobile App and/or Services;

(g) to provide customer service and support;

(h) to customise and personalise your experience on the Mobile App;

(i) to help us provide, maintain, develop, test, improve and enhance the Mobile App and/or Services;

(j)
to administer and protect our business and Mobile App and/or Services
(including troubleshooting, data analysis, testing, system maintenance
and support, reporting and hosting of data);

(k) to detect or investigate any prohibited, illegal, unauthorised or fraudulent activities;

(l) to monitor and analyse user activities and demographic data including trends and usage of the Mobile App and/or Services;

(m) to measure consumer interest in the Mobile App and/or Services;

(n)
to generate and/or track anonymous analytics data, which would not
constitute personal data within the meaning of the PDPA although it may
be derived from your personal data;

(o) to back up our systems and allow for disaster recovery;

(p)
to comply with any applicable laws, regulations, codes of practice,
guidelines, rules, court order or other legal compulsion, or to assist
in law enforcement and investigations conducted by any governmental or
regulatory authority;

(q) to protect the rights, property or personal safety of our staff or the public;

(r) for any other purposes for which you have provided the information;

(s) for any other purposes related to or in connection with above; and 

(t)
to transmit to any unaffiliated third parties including our Third Party
Service Providers and agents, or relevant governmental and/or
regulatory authorities, whether in Singapore or abroad, for the
aforementioned purposes. 

 

3.2 The Purposes listed above
may continue to apply even in situations where your relationship with us
(for example, pursuant to a contract) has been terminated or altered in
any way, for a reasonable period thereafter (including, where
applicable, a period to enable us to enforce our rights under any
contract with you).

 

3.3 We will secure your explicit
consent to share your data with any other organisations explicitly in
each instance except when we are compelled to make a disclosure by due
legal process applicable in your jurisdiction in which case we shall use
best endeavours to notify you that the disclosure is being made and
what aspects of your data are being disclosed.

 

3.4 We may
also collect, use and share aggregated data such as statistical or
demographic data for any purpose. For example, we may use such
aggregated data for data analytics purposes to improve our Website,
Services, marketing, customer and User relationships and experiences.
Such aggregated data may be derived from your personal data but is not
considered personal data in law as this data does not directly or
indirectly reveal your identity. In the event such aggregated data is
combined with or connected to your personal data such that it can
directly or indirectly identify you, we will treat such combined data as
personal data, which will be used in accordance with this Policy.

 

4. Disclosure of data

 

4.1 We will only disclose data to parties including, but not limited to, in the following circumstances:

(a)
To our Third Party Service Providers including our advisers and
consultants, our agents, our advertisers, our vendors, our
subcontractors and out payment gateway, credit or debit card companies,
banks and other entities processing payment transactions made by you
through the Services;

(b) To Third Party Service Providers, agents
and other organisations we have engaged to perform any of the functions
listed in Clause 3.1 above for us; 

(c) To third parties that
require relevant data in connection with a corporate merger,
consolidation, the sale of substantially all assets or other fundamental
corporate change of us; 

(d) To other Registered Users contacted and/or engaged by yourself through a Service Request Job;

(e) Government or regulatory authorities; and/or

(f)
To any other party where such disclosure is required for performing our
obligations in the course of or in connection with the provision of our
Mobile App and/or Services,

to the extent required in the normal course and scope of our business in the provision of the Mobile App and/or Services.

 

4.2
We do not control and shall not be responsible or liable in any way for
the collection, use or disclosure of data by the parties to whom we
disclose such data.

 

4.3 We may, from time to time,
collect, use or disclose data as a data intermediary on behalf on an
event organiser. In such event, our only obligation is to ensure that,
as a data intermediary, we comply with the obligations under the
Personal Data Protection Act (No. 26 of 2012) (the “PDPA”) which are
applicable to a data intermediary.

 

4.4 By using our Mobile
App and/or Services, you expressly acknowledge and consent to the
disclosure of your personal data to the parties listed in Clause 4.1. 

 

5. Security

 

5.1
We maintain safeguards and put in place security measures which we deem
to be reasonably appropriate to ensure the security and privacy of data
collected by us.

 

5.2 We also limit the disclosure of
personal data both internally and to our agents, contractors, Third
Party Service Providers and other third parties to a need-to-know basis.
We require all third parties to respect the security of your personal
data and to treat it in accordance with the law and in accordance with
their own privacy policies.

 

5.3 Notwithstanding the
foregoing, while we strive to protect your data, we cannot guarantee the
security or privacy of such data or that such data will not be subject
to any loss, theft or unauthorised access, collections, use disclosure,
alteration or disposal, and subject to any applicable law, we hereby
disclaim any responsibility or liability directly or indirectly arising
out of or in connection with the same.

 

5.4 It shall be
your sole responsibility for safeguarding and maintaining the
confidentiality of your data and checking your privacy settings
regularly to ensure the security and privacy of your data. You should be
aware that no method of transmission over the Internet or method of
electronic storage is completely secure. 

 

6. Transfer of personal data overseas

 

Data
collected by us will be stored on our servers, which may be located in
Singapore or overseas If we need to transfer data outside Singapore, we
will put in place measures to provide a standard of protection in such
territory outside Singapore that is comparable to the protection under
the PDPA. By using our Mobile App, registering as a Registered User, or
using our Services, you consent to the transfer of your personal data to
countries outside of Singapore.

 

7. Retention of your personal data

 

7.1
We will only retain your personal data for as long as necessary to
fulfil the purposes for which it was collected, or as required or
permitted by applicable laws. including satisfying any legal,
accounting, or reporting requirements.

 

7.2 We will cease
to retain your personal data, or remove the means by which the data can
be associated with you, as soon as it is reasonable to assume that such
retention no longer serves the purpose for which the personal data was
collected, and is no longer necessary for legal or business purposes.

 

8. Access and correction of your personal data

 

8.1
Subject to the exceptions referred to in section 21 of the PDPA, you
have the right to request access to a copy of your personal data which
we hold about you or information about the ways in which we use or
disclose your personal data.

 

8.2 You also have the right
to request for the correction or update of any personal data of yours
which we hold. We generally rely on personal data provided by you. We
want to ensure that your personal data is current, complete and
accurate. Please update us if there are changes to your personal data.

 

8.3
If you wish to make (a) an access request, or (b) a correction request,
you may submit your request in writing of via email to our Data
Protection Officer at the contact details provided below. 

 

8.4
We will respond to your request as soon as reasonably possible or
practicable. Should we not be able to respond to your request within
thirty (30) days after receiving your request, we will inform you in
writing within thirty (30) days of receiving your request. If we are
unable to provide you with any personal data or to make a correction
requested by you, we shall generally inform you of the reasons why we
are unable to do so (except where we are not required to do so under the
PDPA).

 

8.5 We may need to request specific information
from you to help us confirm your identity. This is a security measure to
ensure that personal data is not disclosed to any person who has no
right to receive it. We may also need to verify the accuracy of any new
data you provide us.

 

8.6 You will not have to pay a fee to
access your personal data (or to exercise any of the other
rights). However, we may charge a reasonable fee if (a) your request
unreasonably interferes with our operations due to its repetitious or
systematic nature; (b) the burden or expense of providing access would
be unreasonable to us or disproportionate to your interests; (c) the
information is does not exist, cannot be found, or is trivial; or (d)
your request is otherwise frivolous or vexatious. Alternatively, we may
refuse your request in these circumstances.

 

9. Visiting the Mobile App from outside Singapore

 

9.1
The Mobile App is operated and hosted in Singapore. If you are visiting
the Mobile App from outside Singapore, please be aware that your data
may be transferred to, stored and processed in Singapore where our
servers are located. By using and accessing the Mobile App, you hereby
consent to the transfer of your data to Singapore and its collection,
use and disclosure as set out in this Privacy Policy. You further agree
that all payment transactions made by you through the Mobile App shall
be deemed to have occurred in Singapore.

 

9.2 You also
acknowledge that your use or access of the Mobile App may be subject to
local laws applicable in such territory outside Singapore from where you
are visiting the Mobile App. It shall be your sole responsibility to
ensure that you use and access the Mobile App only in compliance with
such applicable local laws.

 

10. Contact details

 

You
may contact our Data Protection Officer, or any of our representatives
and/or employees, if you have any enquiries or feedback on this Policy,
our personal data protection policies and procedures, or if you wish to
make any request, at hello@aunty.sg.

 

11. Definitions

 

“Company”, “we”, “us” or “our”
means Aunty Pte. Ltd. (a company incorporated under the laws of the
Republic of Singapore and holding registered company number:
202117870K), with registered office at 10 Anson Road, #10-11, including
where the context so allows, its shareholders, employees and affiliates;

 

“Mobile App” means the Aunty mobile application;

 

“Parent” means the caregiver or legal guardian of a child, and “Parents” shall be construed accordingly;

 

“PDPA” means the Personal Data Protection Act 2012 of Singapore;

 

“personal data” means
data, whether true or not, about an individual who can be identified:
(a) from that data; or (b) from that data and other information to which
we have or are likely to have access, which is provided to us or any
other User in relation to or in connection with any Service including
information provided during registration, Service Request Job listings,
the rating of Nannies and Parents and any other communication processes
arising as a result of your use of the Mobile App and/or Services;

 

“Privacy Policy” means our privacy policy, as amended by us from time to time, found at [https://www.aunty.sg/];

 

“Purposes” has the meaning given to the word in Clause 3.1;

 

“Registered User” means, collectively, any Parent and/or Sitter that has registered with the Company, and “Registered Users” shall be construed accordingly;

 

“Services” means the services, information and resources provided by the Company to Registered Users through our Mobile App;

 

“Service Request Job” or “Job” means work carried by any Sitter, for or on behalf of any Parent;

 

“Sitter”, “Nanny” “Aunty”, “Babysitter” or “Childcarer” means a caregiver for children, and “Sitters”, “Nanny”, “Aunties”, “Babysitters” or “Childcarers” shall be construed accordingly;

 

“Terms”
means the Terms of Service of Aunty Pte. Ltd. for its Mobile App, as
amended by us from time to time, found at [https://www.aunty.sg/];

 

“Third Party Service Provider”
means external service providers who have entered into service
agreements with us to assist us in (a) operating our Mobile App; (b)
providing our Services to you; or (c) conducting our business
generally; 

 

“Third Party Websites” means websites which are not owned or controlled by the Company; and 

 

“User” or “You” means any user of or an individual who accesses the Mobile App or Services.

instance
except when we are compelled to make a disclosure by due legal process
applicable in your jurisdiction in which case we shall use best
endeavours to notify you that the disclosure is being made and what
aspects of your data are being disclosed.