Our Privacy Policy

RDC Group Privacy Policy (Australia, New Zealand & Singapore)

This Privacy Policy (Policy) applies to Rich Data Corporation Solutions Pte Ltd and its subsidiaries (RDC, we, us or our) and describes how RDC collects, handles and protects the privacy of your personal information in Singapore, Australia and New Zealand.

We are committed to safeguarding your privacy. This Policy outlines the types of personal information that we usually collect, tells you how we collect and process your personal information, what we use it for, and with whom we share it. This Policy also explains particular rights you have in relation to your personal information.

We will handle your personal information in accordance with this Policy and applicable laws, including: the Privacy Act 1988 (Cth) of Australia (Australian Privacy Act), the Privacy Act 2020 (NZ) (NZ Privacy Act), and the Personal Data Protection Act (2020 Revised Edition) of Singapore (PDPA).

In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.

If you have any questions or comments about this Policy or our procedures, or if you wish to exercise the rights you have under applicable privacy laws (which are explained further below) please contact us using the methods set out in section 11.

We may update this Policy from time to time by publishing changes on our website.

You can navigate separate sections of this Policy through the links below.

• Personal information we collect
• Sources of personal information
• How we use and process the personal information we collect about you
• Sharing your information
• Sharing, Storing and Transfer of personal information overseas
• Your rights
• How do you make a complaint?
• Contacting us

1. Personal information we collect

1.1 The types of personal information we collect about you depends on the dealings you have with us, and may include:

(a) Identity information including first name, last name, title, date of birth;
(b) Contact information including billing address, postal address, email address and telephone numbers (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company for whom you work);
(c) Profile information including information you give us or that we obtain when you use our website, obtain our services, supply us with goods or services, enquire about a service or product, place a service request, contact us to report a problem, or do any of these things on behalf of the organisation for whom you work;
(d) Marketing and communications information including your preferences in receiving marketing from us; and
(e) Technical information including the Internet protocol (IP) address associated with the computer you are contacting us from, and browser plug-in types and versions.

1.2 Where we receive any information about our clients’ customers through the provision of our products and services to our clients, we treat this information in accordance with this Privacy Policy.

2. Sources of personal information

2.1 We may collect personal information from or about you in different ways, including:

(a) from our clients, such as financial institutions;
(b) from you directly when you interact with us, e.g. in person, by phone, by email;
(c) when you apply for a position with us as an employee or as a contractor; and
(d) from publicly available information, such as from public registers.

3. How we use and process the personal information we collect about you

3.1 Depending on your interactions with us, we may use and process your personal information for the purposes set out in the table below.

Type of data	Purpose for collection, use and disclosure of data
Identity information Contact information	To deliver our products and services.
Identity information Contact information Profile information Marketing and communications information	To manage our relationship with you.
Identity information Contact information Technical information	To administer and protect our business and our website.
Identity information Contact information Profile information Marketing and communications information Technical information	To deliver relevant website content and marketing to you and measure or understand the effectiveness of the marketing we serve to you.
Technical information	To undertake data analytics activities to improve our website, products, marketing, customer relationships and experiences.
Identity information Contact information Profile information Marketing and communications information	To provide you with the information and direct marketing communications which are of interest to you. If you have provided your consent to receive direct marketing, you can withdraw it at any time by contacting us using the details in section 11 below.

4. Our use of cookies

When you visit our website, we may also use ‘cookies’ or other similar tracking technologies that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device.

We use cookies to:

• recognise your computer or internet enabled device;
• keep track of services you view;
• measure traffic and engagement patterns, to evaluate our website visitor’s habits; and
• continually improve our website and product offering.

You can disable cookies through your internet browser but our website may not work as intended for you, if you do so.

Whilst we do not use browsing information to identify you personally, we may record certain information about your session, use of our website such as pages visited, the time and date of the visit, search engine referrals and the internet protocol address assigned to your computer.

Our web pages may contain electronic images, known as web beacons. These electronic images enable us to count users who have visited certain pages on our website. Web beacons are not used by us to access your personal information, they are simply a tool we use to analyse which web pages are viewed, in an aggregate number.

5. What happens if you don’t provide your information to us?

Our collection of your personal information is undertaken for our business purposes only and is not required by law in Singapore, Australia, or New Zealand. If you do not provide your information to us, we may not be able to:

(a) provide you with our products and services;
(b) respond to your requests;
(c) personalise your experience with us; or
(d) let you know about other products or services that might better meet your needs.

6. Sharing your information

RDC may share your information with other organisations consistent with the purposes for which we use and process your information as described above, in accordance with this Policy. This includes with:

(a) suppliers and contractors: we may share personal information with the suppliers and contractors we use in order to provide our platform to you. Examples of such suppliers and subcontractors are software and data storage providers, business consultants, and media organisations who assist us to communicate with you including for direct marketing purposes with your consent, including media or social networking sites;
(b) the RDC group: we may share your personal information to our related bodies corporate to assist us in delivering our products and services, or for administrative and payment processing purposes;
(c) to third parties at your request: at your request, we will share your personal information with your representative or any person acting on your behalf (for example, financial advisers, lawyers, settlement agents, accountants, executors, administrators, trustees, guardians, brokers or auditors) and your referee (such as your employer) to confirm details about you; and
(d) authorities: we may share necessary information to authorities such as the police, tax agencies or other authorities if we are required or permitted to do so by law, or under some circumstances if you have requested us to do so.

7. Sharing, storing and transfer of personal information overseas

7.1 We run our business in Australia, Singapore and overseas. We may need to share some of the information we collect about you with organisations, including those within the RDC group, both inside and outside Australia. The countries in which we are likely to disclose your personal information include New Zealand and the United States.

7.2 We may store your information in cloud or other types of networked or electronic storage. As electronic or networked storage can be accessed from various countries via an internet connection, it is not always practicable to know in which country your information may be accessed or held.

7.3 If we, or our service providers, transfer any of your personal information we collect from you out of Australia, it will only be done with relevant protections in place. We will take steps to ensure that your personal information will be afforded the level of protection required of us under and in accordance with applicable data protection laws.

8. What happens when we no longer need your information?

8.1 We will only keep your information for as long as we have a relationship with you and for 7 years or otherwise as required for our business operations or by applicable laws.

8.2 We may need to retain certain personal information after we cease providing you with products or services to enforce our terms, for fraud prevention, to identify, issue or resolve legal claims and for proper record keeping.

8.3 We may also retain a record of any stated objection by you to receiving marketing for the purpose of ensuring we can continue to respect your wishes and not contact you further.

9. Your rights

How to access your information

9.1 Subject to applicable laws, you may request access to your personal information. We will need to verify your identity before we can give you access. We will acknowledge receipt, and we will endeavour to deal with and respond to your request within a reasonable time.

9.2 In certain circumstances, we are permitted by law to refuse access to your personal information. In such cases, we will give you a written explanation for our decision (including, where applicable, an alternative means of access to the information, such as supervised inspection), and how you can complain if you are not satisfied with our decision.

9.3 You will not be charged for making a request for your personal information. However, we may charge a fee to provide your information to cover administrative costs (including for supervised inspection). We will inform you of any fee at the time your request is made.

9.4 We will give you access to your information in the form you want it where it is reasonable and practical.

9.5 If you would like to request access to your personal information, contact us using the details in section 11 below.

How to correct your personal information

9.6 If you think that any personal information we hold about you is inaccurate, you may ask us to correct it. We will take reasonable steps to correct it unless we disagree with your reasons. If we refuse to correct your personal information, we will give you a written explanation why.

9.7 If you would like to request correction of your personal information, contact us using the details in section 11 below.

Additional rights and choices

9.8 In certain circumstances, you can:

(a) obtain information about the processing of your personal information;
(b) ask us to erase your personal information, such as if you withdraw your consent and we are not otherwise legally entitled to retain it;
(c) object to, and ask us to restrict, our processing of your personal information, although we may continue to process your personal information while we verify your assertion your information is inaccurate or if we are processing your information for our legitimate interests;
(d) receive some personal information you have given us in a structured, commonly used and machine-readable format or ask us to transmit it to someone else if technically possible feasible; and
(e) withdraw your consent (but we may be able to continue processing without your consent if there is another legitimate reason to do so). The withdrawal of your consent will not affect the processing of your information to which you had consented.

10. How do you make a complaint?

10.1 If you believe that we have not handled your personal information consistently with this Policy and our privacy obligations, please contact us using the contact details set out in section 11 below. We will investigate any complaint, and notify you of our decision in relation to the complaint, as soon as practicable after it is received.

10.2 If you still feel your issue or request has not been resolved to your satisfaction, then you have the right to make a complaint to the relevant data protection authority (for example in the place you reside or where you believe we breached your rights). We can, on request, tell you the relevant authority for the processing of your personal information.

10.3 In Australia, the relevant authority is the Office of the Australian Information Commissioner, who can be contacted online at: www.oaic.gov.au/privacy.

11. Contacting us

Please contact us if you have any questions or comments about this Policy or if you wish to exercise your rights you have under applicable privacy laws using the following details:

Data Protection / Privacy Officer
Email: privacy@richdataco.com

Last updated: 2/04/2024

 

 

U.S. Privacy Policy

Effective date: 5 April 2024

To download and/or print this Privacy Policy (“Privacy Policy”) click here.

Privacy Policy Scope

Welcome! An overview of this Rich Data Corporation Solutions Pte Ltd (“Rich Data Co”) Privacy Policy is provided below. To see the full text, click on the links. This Privacy Policy applies to your use of any online services (e.g., website, software, or mobile app, and certain e-mails we send) that posts a link to this Privacy Policy, regardless of how you access or use it from the United States.

Your California and Nevada Privacy Rights

California and Nevada residents have certain privacy rights detailed in Section 12 of this policy. To the extent that there is a conflict between this Privacy Policy and the State Privacy Notice, the State Privacy Notice will control.

We have summarized some (but not all) of the main topics of this Privacy Policy below. The complete provisions, and not the headings or summaries govern.

• Your Choices and Your California Nevada Privacy Rights
  You have certain choices regarding information collection and communications options explained in Section 11, including:
  — California residents have certain privacy rights detailed in Section 12.B.
  — Nevada residents have certain privacy rights detailed in Section 12.A.
  — Although Rich Data Co does not look for or respond to “do not track” signals, you can find information on tracking technologies in Section 1.B.
  — About Ads and Tracking: Learn about certain choice options regarding Tracking Technologies, including certain sharing of activities, location and/or cross-device usage for interest-based advertising in Section 11.
  — Your options regarding accessing and changing certain of your Personally Identifiable Information are available in Section 10.
  — Your options regarding promotional communications are explained in Section 11; and
  — Children’s and minors’ privacy rights, and notice to parents of these rights, are explained in Section 9.
• Collection of Information
  — Rich Data Co may ask you to provide Personally Identifiable Information (e.g., name, address, e-mail, phone number, etc.), as well as other information (e.g., gender, interests, etc.), which may be required to access certain content, features, and functionality. Refer to Section 1.A.
  — Rich Data Co and third parties may collect information from you automatically as you access the Service (e.g., information about the devices you use to access the Service and your usage activities). Refer to Section 1.B.
  –This may include use of cookies and other technologies to keep track of your interactions with the Service, to serve you with ads on other online services, and to offer you a more personalized and relevant experience. Refer to Section 1.B.
  –The information Rich Data Co receives via the Service may be combined with information Rich Data Co receives from third parties and sources outside of the Service. Refer to Section 1.C.
  — Rich Data Co’s policies and practices regarding Personally Identifiable Information collected from children are explained here. Refer to Section 9.
  — Rich Data Co obtains your consent (e.g., opt-in, opt-out), however, before knowingly sharing Personally Identifiable Information with third parties (other than Rich Data Co Affiliates) for their own direct marketing purposes.
  — Rich Data Co may share your non-Personally Identifiable Information, aggregate and/or de-identified information about you except as prohibited by applicable law.
• Questions and How to Contact Us
  For more information about Rich Data Co’s privacy practices regarding the Service, read the full Privacy Policy. You can also contact Rich Data Co here if you have questions or concerns.
• Full Privacy Policy
  To see and print our full Privacy Policy, click here. You can also request a copy, including in Braille, or otherwise obtain disability access assistance by emailing us at privacy@richdataco.com.

FULL RICH DATA CO PRIVACY POLICY

Thank you for visiting an online service (e.g., website or mobile app) that posts a link to this Privacy Policy (“Service”) owned or operated by Rich Data Corporation Solutions Pte Ltd (“Rich Data Co,” “we,” “us” or “our”). This Privacy Policy will provide you with information as to how Rich Data Co collects, uses, and shares information about you, including the choices Rich Data Co offers with respect to that information, and applies to your use of any Service in the United States, regardless of how you access or use it. It does not apply to Rich Data Co’s data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you. If you are visiting the Service from another country, this Privacy Policy does not apply.

By visiting or otherwise using the Service, you acknowledge Rich Data Co’s data collection, use, and disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service, and uninstall Service downloads and applications.

1. INFORMATION WE COLLECT

A. Information about You that You Provide

Rich Data Co, and/or its Service Providers (defined below), may collect information you provide directly to Rich Data Co and/or its Service Providers via the Service. For example, Rich Data Co collects information when you use or register for the Service, subscribe to notifications, participate in promotional activities, or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices, refer to Section 6 For more information on Service Provider data collection and practices, refer to Section 3.

Information Rich Data Co, its Service Providers and/or Third-Party Services may collect may include: (1) personally identifiable information, which is information that identifies you personally, such as your first and last name, e-mail address, phone number, address, and full payment account number (“Personally Identifiable Information” or “PII”); and (2) demographic information, such as your gender, age, zip code, interests, and recent and upcoming purchases (“Demographic Information”). Except to the extent required by applicable law, Demographic Information is “non-Personally Identifiable Information” or “non-PII” (i.e., data that is not Personally Identifiable Information under this Privacy Policy). In addition, Personally Identifiable Information, including, without limitation, Rich Data Co-Collected PII (defined below), once “De-identified” (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) including through anonymization, pseudonymization, and/or hashing) is also non-Personally Identifiable Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personally Identifiable Information, or PII collected outside of the Service, is combined by or on behalf of Rich Data Co with Personally Identifiable Information Rich Data Co itself collects directly from you on the Service (“Rich Data Co-Collected PII”), Rich Data Co will treat the combined data as Rich Data Co-Collected PII under this Privacy Policy. The definition of “personal information” under certain state laws differs from the definition of PII used in this Privacy Policy. California and Nevada residents can learn more about their privacy rights here. [Link to State Privacy Notice]

B. Information Collected Automatically

Rich Data Co, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service, and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Rich Data Co with Rich Data Co-Collected PII, we do not consider Usage Information (including, without limitation, unique device identifiers) to be Personally Identifiable Information or Rich Data Co-Collected PII. For more information on Third-Party Services’ data collection and practices, refer to Section 6. For more information on Service Provider data collection and practices, refer to Section 3. For information on choices some of these third parties may offer you regarding automated data collection, refer to Section 11.

The methods that may be used on the Service to collect Usage Information include:

• Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
• Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as “tracking pixels”), embedded scripts, location-identifying technologies, device recognition technologies, in-app tracking methods and other tracking technologies now and hereafter developed (“Tracking Technologies”) may be used to collect information about interactions with the Service or e-mails, including information about your browsing and purchasing behavior.
• Cookies
  A cookie is a small text file that is stored on a user’s device, which may be session ID cookies or tracking cookies. Session cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the Service may not work. To identify certain types of local shared objects on your device and adjust your settings, please visit Macromedia. The Service may associate some or all of these types of cookies with your devices.
• Web Beacons (“Tracking Pixels”)
  Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
• Embedded Scripts
  An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from Rich Data Co’s web server, or from a third party with which Rich Data Co works and is active only while you are connected to the Service and deleted or deactivated thereafter.
• Location-identifying Technologies
  GPS (global positioning systems) software, geo-filtering and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content, including third party ads, based on your location. If you have enabled GPS or use other location-based features on the Service, your device location may be tracked by us and third parties. Our Service content may be personalized based on various information we may have about you to try to provide you with more location-relevant content.
• Device Recognition Technologies
  Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Meta/Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
• In-App Tracking Methods
  There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs,” or may use “SDKs,” to associate app user activity to a particular app and to track user activity across apps and/or devices. SDKs are blocks of code that may be installed in our mobile application by third party companies with which we work. SDKs help us understand how you interact with our mobile application and collect certain information about the device and network you use to access our application, such as the advertising identifier associated with your device and information about how you interact with our application.

Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by Rich Data Co and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services. See Section 11 regarding certain choices regarding these activities.

Rich Data Co is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.

C. Information Rich Data Co Collects From Other Sources.

Rich Data Co may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Rich Data Co-Collected PII. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of Rich Data Co with Rich Data Co-Collected PII, this Privacy Policy is not intended to limit Rich Data Co’s activities regarding such third-party-sourced, or non-Service-sourced, information (including Personally Identifiable Information), and such data will only be treated as Rich Data Co-Collected PII to the extend it is combined with Rich Data Co-collected PII. Rich Data Co is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.

2. HOW WE USE THE INFORMATION WE OBTAIN

Rich Data Co may use information about you, including Rich Data Co-Collected PII and other Personally Identifiable Information, for any purposes not inconsistent with Rich Data Co’s statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

• Allow you to participate in the features we offer on the Service;
• Facilitate, manage, personalize, and improve your online experience;
• Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
• Rich Data Co Affiliates’ marketing and other purposes;
• Improve the Service and for any other business purposes;
• Tailor our content, advertisements, and offers;
• Fulfill other purposes disclosed at the time you provide Personally Identifiable Information or otherwise where we are legally permitted or are required to do so;
• Determine your location and manage digital content rights (e.g., territory restrictions); and
• Prevent and address fraud, breach of policies or terms, and threats or harm.

3. INFORMATION WE SHARE WITH THIRD PARTIES

Except as restricted by applicable law, this Privacy Policy, or any other representation Rich Data Co makes to you, Rich Data Co may share non-Personally Identifiable Information, and Personally Identifiable Information that is not deemed Rich Data Co-Collected PII hereunder (provided that Rich Data Co is aware of no restrictions of Rich Data Co’s use, if any), with third parties or Rich Data Co companies and their affiliates (“Rich Data Co Affiliates”) for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personally Identifiable Information, including Rich Data Co-Collected PII, to non-Personally Identifiable Information, including without limitation through hashing it or substituting a unique identifier for the Personally Identifiable Information and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. Rich Data Co’s sharing of Rich Data Co-Collected PII is, however, subject to the following:

• Marketing: Subject to your communications choices explained in Section 11.D, and the rights of California residents explained in Section 12, we may use your Personally Identifiable Information to send you marketing communications. Absent your consent (which may be by means of opt-in, your election not to opt-out, or a third party interaction described in the next bullet point), however, Rich Data Co will not share your Rich Data Co-Collected PII with third parties, other than Rich Data Co Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
• Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the Service may, by their nature, result in the sharing of your Rich Data Co-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Rich Data Co.

Rich Data Co may also share any information about you (including, without limitation, Rich Data Co-Collected PII) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:

• Rich Data Co’s agents, vendors, consultants, and other service providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, Personally Identifiable Information, Demographic Information, and Usage Information, in connection with their work on Rich Data Co’s behalf, provided however, Rich Data Co does not authorize its Service Providers to use Rich Data Co-Collected PII provided by Rich Data Co to the Service Providers to send you direct marketing messages other than related to Rich Data Co and Rich Data Co Affiliates absent your consent. For more information on choices Service Providers may offer you refer to Section 11.
• To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
• If Rich Data Co believes your actions are inconsistent with Rich Data Co’s terms of use, user agreements, applicable terms or policies, or to protect the rights, property, life, health, security and safety of Rich Data Co, the Service or its users, or any third party.

In addition, Rich Data Co may share your Rich Data Co-Collected Personally Identifiable Information (as well as your other Personally Identifiable Information and your non-Personally Identifiable Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of Rich Data Co assets, or transfer of all or a portion of Rich Data Co’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).

4. SWEEPSTAKES, CONTESTS, AND PROMOTIONS

Rich Data Co may offer sweepstakes, contests, and other promotions (each, a “Promotion”), including Promotions jointly sponsored or offered by third parties, which may require submitting Personally Identifiable Information. If you voluntarily choose to enter a Promotion, your information, including Personally Identifiable Information, may be disclosed to Rich Data Co, co-sponsors, Service Providers, and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.

5. INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS

The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data, or other content, including Personally Identifiable Information. If you choose to submit UGC to any public area of the Service, your UGC will be considered “public” and will be accessible by anyone, including Rich Data Co. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personally Identifiable Information included in UGC is not subject to Rich Data Co’s usage or sharing limitations, or other obligations, regarding Rich Data Co-Collected PII or other Personally Identifiable Information under this Privacy Policy or otherwise, and may be used and shared by Rich Data Co and third parties to the fullest extent not prohibited by applicable law. Rich Data Co encourages you to exercise caution when making decisions about what you disclose in such public areas. California minors should see Section 9 regarding potential removal of certain UGC they have posted on the Service.

Additionally, the Service may offer you the option to send a communication to a friend or other contact. If so, Rich Data Co relies on you to only send to people that have given you permission to do so. The recipient’s Personally Identifiable Information you provide (e.g., name, e-mail address) will be used to facilitate the communication, but not used by Rich Data Co for any other marketing purpose unless Rich Data Co obtains consent from that person. Your contact information and message may be included in the communication.

6. THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS

The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)) or other services (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personally Identifiable Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third party social networks (“Social Features”). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; “liking” or “sharing” Rich Data Co’s content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service (see Section 5) or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with Rich Data Co or other Rich Data Co Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Rich Data Co and Rich Data Co Affiliates. Also, both Rich Data Co and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.

Rich Data Co may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”). We may use Microsoft and Google for advertising services. See Section 11 for more information on your choices regarding certain personalized advertising.

Rich Data Co may use Google Analytics, Adobe Analytics or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Rich Data Co analyze Service users and how they use the Service. Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service’s activity, and providing other services relating to Service activity and other Internet usage. See Section 11 for more information on your choices regarding these services.

Rich Data Co is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use. See Section 11 for more on certain choices offered by some third parties regarding their data collection and use, including regarding Interest-based Advertising and analytics.

7. DATA SECURITY AND MONITORING

Rich Data Co takes reasonable measures to protect Rich Data Co-Collected PII (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Rich Data Co does not guarantee the security of your information collected through the Service.

To help protect you and others, Rich Data Co and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Rich Data Co-Collected PII and other Personally Identifiable Information for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences, and to protect the rights and property of Rich Data Co Rich Data Co Affiliates, third parties, and other users. Monitoring may result in the collection, recording, and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.

8. INTERNATIONAL TRANSFER

The Service is targeted towards users located in the U.S. and the information Rich Data Co and its Service Providers collect is governed by U.S. law. If you are located in the European Union (EU), European Economic Area (EEA), United Kingdom, and/or Switzerland, please note that Rich Data Co does not intend to offer goods and services (including the Services) to EU, EEA, UK, or Swiss individuals. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Privacy Policy.

9. CHILDREN’S PRIVACY

The Service is intended for a general audience and not directed to children less than 13 years of age. Rich Data Co does not intend to collect personal information as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personal Information”) in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children’s Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.

Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Rich Data Co, detailing where the content or information is posted and attesting that you posted it. Rich Data Co will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished or archived content by search engines and others that Rich Data Co does not control.

10. ACCESSING AND CHANGING INFORMATION

Rich Data Co may provide web pages or other mechanisms allowing you to delete, correct, or update some of the Rich Data Co-Collected PII, and potentially certain other information about you (e.g., profile and account information). Rich Data Co will make good faith efforts to make requested changes in Rich Data Co’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Rich Data Co’s databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

11. CHOICES: TRACKING AND COMMUNICATIONS OPTIONS

A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects) , HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Some App-related Tracking Technologies in connection with non-browser usage (e.g., most functionality of a mobile app) can only be disabled by uninstalling the app. To uninstall an app, follow the instructions from your operating system or handset manufacturer. Apple and Google mobile device settings have settings to limit ad tracking, and other tracking, but these may not be completely effective.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, Rich Data Co currently does not alter Rich Data Co’s practices when Rich Data Co receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but Rich Data Co is not responsible for the completeness or accuracy of this third party information. Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on our web site is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the web sites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. Rich Data Co is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Services, but such tools rely on third parties and third party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective. For instance, here is where you can find cookie controls for popular browsers:

• Google Chrome
• Firefox
• Internet Explorer
• Edge
• Safari

We do not represent that these third-party tools, programs or statements are complete or accurate. You will need to do this on each browser that you use to access our Services, and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

B. Analytics and Advertising Tracking Technologies

You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on. You may exercise choices regarding the use of cookies from Adobe Analytics by going to http://www.adobe.com/privacy/opt-out.html under the section labeled “Tell our customers not to measure your use of their web sites or tailor their online ads for you.”

You may choose whether to receive some Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. Rich Data Co supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Rich Data Co directly engages to serve you Interest-based Advertising will do so as well, though Rich Data Co cannot guaranty their compliance.

We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-based Advertising, please visit here. We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.

In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one of more of our data bases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our data bases and the data bases of the other online services. For instance, we may use such ad services offered by Meta or X and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Meta to serve Matched List Ads on Meta services, you should be able to hover over the box in the right corner of such a Meta ad, or go to your account settings, and find out what options Meta offers you to control such ads. If we use X Matched List Ads, you should be able to review your ad options in account settings on X. We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.

Rich Data Co is not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

C. Mobile Apps

With respect to Rich Data Co’s mobile apps (“apps”), you can stop all collection of data generated by use of the app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., tracking across apps and websites owned by other online services, location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. For example, to limit receiving Interest-based Advertising on your mobile device, for iOS 14, go to “Settings,” select “Privacy,” select “Tracking,” and then toggle off “Allow Apps to Request to Track.” For earlier versions of iOS dating back to iOS 6, go to “Settings,” select “Privacy,” select “Advertising,” and toggle on “Limit Ad Tracking.” For Android, go to “Settings,” select “Privacy,” select “Ads,” and then toggle on “Opt out of Ads Personalization.” Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:

Android:
For Android 6.0 and above: https://support.google.com/googleplay/answer/6270602?hl=en
For earlier versions of Android:
https://support.google.com/googleplay/answer/6014972

iOS: https://support.apple.com/en-us/HT207056

D. Communications

You can opt out of receiving certain promotional communications (emails or text messaging) from Rich Data Co at any time by (i) for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link, or if available by changing your communication preferences by logging onto your account. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt out of receiving promotional communications, Rich Data Co may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, or Rich Data Co’s ongoing business relations.

E. Cross-Device Data

To learn more about how you can exercise certain choices regarding Cross-device data for Interest-based Advertising, see the prior section regarding the DAA’s Interest-based Advertising choices.

12. STATE NOTICES

A. Nevada Residents. We do not believe we “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes and until such time as we change this policy by updating this Privacy Policy, and provide a method to opt-out of sale under the Nevada Revised Statutes, we will treat covered information collected under this Privacy Policy as subject to a do not sell request as relates to the Nevada Revised Statutes.

B. Your California Privacy Rights. We do not share personal information as defined by California Civil Code Section 1798.83 (“Shine The Light law”) with third parties for their direct marketing purposes without either obtaining your consent or giving you the ability to opt-out. To opt-out of future sharing with third parties for their direct marking purposes, check here. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us here or by sending a letter to [1 Paya Lebar Link #04-01 Paya Lebar Quarter Singapore 408533], (Attention: Legal Counsel). Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year

California minors should see “Children’s Privacy” at Section 9 regarding removal of certain content they have posted.

13. CHANGES TO THIS PRIVACY POLICY

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy, and may, in our discretion, choose to notify you of material changes in another reasonable manner. Your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected Rich Data Co -Collected PII, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

14. CONTACT RICH DATA CO

If you have any questions about this Privacy Policy, please email Rich Data Co at privacy@richdataco.com.

© Rich Data Co 2024. All Rights Reserved.