Last Modified: 28th January 2018



1.1.      In this Privacy Policy:

  • We”, “we”, “our”, “us”, “Us” means iVideoSmart Pte. Ltd. and its related corporations.
  • You”, “you”, “Your”, “your” means the persons to whom this Privacy Policy applies.
  • personal data” means any data which can be used to identify a natural person.
  • Service Providers” means our third party publishers, advertisers, partners and contractors, whether in Singapore or elsewhere.
  • Services” means our products, services, content, features, technologies or functions offered on websites, applications and services operated by us or our Service Providers.

2.          YOUR CONSENT

2.1.      This Privacy Policy applies to any individual’s personal data which is in our possession or under our control, and shall govern your use of the Services.  This Privacy Policy is in addition to the other terms and conditions which may apply in respect of your use of such Services.

2.2.      You are deemed to have accepted this Privacy Policy when you provide us with personal data or otherwise sign up for, access or use any of our Services.

2.3.      Notwithstanding the foregoing, you may withdraw your consent for us to collect, use or disclose your personal data, but this may affect our ability to provide you with the Services.  We will not be liable for any failure to provide any Services if such failure is due to your consent hereunder being withdrawn.


3.1.      We may from time to time amend this Privacy Policy by posting a revised version of this Privacy Policy on our website.  The revised version shall take effect from the published effective date, except where the revised version involves a substantial change, we will provide you with at least 30 days’ prior notice on our website.  If you continue to use our Services after the notice period, you will be deemed to have consented to the amendments made in such revised version.

4.          Collection OF PERSONAL DATA

4.1.      We may from time to time collect your personal data in order to provide you with the Services and to also improve your experience, such as:

(a)         general identification and contact information (for example, name, address, email address, telephone number, age, date of birth, gender, marital status, occupation, username, password, etc);

(b)         financial information and account details (for example, bank account numbers, credit card numbers, assets, liabilities, salary, etc);

(c)         information from cookies, pixel tags, web beacons or similar technologies;

(d)         images, photographs, closed-circuit television (CCTV) footage, voice recordings and electronic communications;

(e)         data about the pages you access, your Internet protocol address, your device unique identifier, your device type, your geo-location information, your mobile network information, referral URL, statistics on page views, other information automatically sent to us by your device or your service provider; and

(f)          other information you may provide us with.

4.2.      Your personal data may be collected:

(a)         automatically (for example, when your device or service provider automatically sends us that data);

(b)         from you (for example, when you submit a web form to us, add or update your account information, participate in discussions, chats or dispute resolutions, or correspond with us); and

(c)         from third parties (for example, from social media sites).

5.          Use OF PERSONAL DATA

5.1.      Core Business Purpose.  We may use your personal data to:

(a)         provide you with the Services; measure the performance of our Services; monitor the Services provided by or made available through us;

(b)         determine your geographic location, provide localised or targeted content, provide you with customised or personalised recommendations or content, determine your Internet service provider, respond to any inquiries, requests, queries or feedback; optimise our selection and recommendation algorithms and delivery;

(c)         communicate with you (such as by email, text messaging, online messaging, push notifications) to assist you with operational requests such as password reset requests;

(d)         verify your identity; conduct due diligence checks;

(e)         prevent, detect and investigate fraud or other potentially prohibited or illegal activities; to detect, prevent and remediate any violations of our policies or terms and conditions;

(f)          address or investigate any complaints, claims or disputes;

(g)         handle requests for data access or correction;

(h)         analyse and understand our users; improve our services (including our user interface experiences); participate in industry exercises and studies;

(i)          coach employees and Service Providers; monitor for quality assurance;

(j)          enforce any obligations owed to us;

(k)         seek professional advice, such as legal advice;

(l)          prepare and maintain financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;

(m)       enable any actual or proposed assignee, transferee, participant or sub-participant of our rights, business or obligations to evaluate any proposed transaction; negotiate a business transaction, including (but not limited to) any financing, merger, acquisition or liquidation;

(n)         manage our infrastructure and business operations (including information technology infrastructure) and complying with internal policies and procedures;

(o)         conduct due diligence enquiries and comply with enforcement of tax, sanctions or prevention or detection of money laundering, terrorism financing or other unlawful activities;

(p)         comply with all applicable laws, regulations, rules, directors, orders, instructions and requests from any authorities (whether local or foreign), including any regulatory, governmental, tax and law enforcement authorities or other authorities; and

(q)         any other purpose specifically provided for in any particulate product or service offered by us or permitted or required by law or the relevant authorities.

5.2.      Marketing Purpose.  We may also use your personal data to:

(a)         offer you our Services (such as special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible), via various modes of communication such as email, short message service and push notifications; and

(b)         improve and personalise the Services, content and advertisements.

If you do not wish to receive marketing communications from us or to participate in our advertisement personalisation programme, please let us know.


6.1.      We may from time to time disclose your personal data to any of our employees, personnel, our Service Providers or to third parties, whether located in Singapore or elsewhere, in order to carry out the purposes set out above.  When we disclose your personal data to such persons, we will request that they also comply with this Privacy Policy.

6.2.      We may transfer, store, process and/or deal with your personal data outside of Singapore, in compliance with applicable data protection or privacy laws.

7.          RETENTION

7.1.      Your personal data is retained for so long as the purpose for which it was collected remains and until it is no longer necessary for any other legal or business purposes.


8.1.      You may request access or make corrections to your personal data held by us, but we may charge a fee for processing your request for access.

8.2.      If you believe that any personal data we have of you is inaccurate, out of date, incomplete, irrelevant or misleading, please let us know.  We will endeavour to respond within a reasonable time and, where necessary, promptly correct any personal data found to be inaccurate, incomplete or out of date.


9.1.      When you access or use our Services, we may store some data on your device using technologies such as a cookie or other local storage provided by your browser or application (collectively, the “Cookies”).  Such data is stored on your device to enable us to (i) provide the Services; (ii) recognise, identify or authenticate you; (iii) customise our Services for you; (iv) advertising; (v) our measurements and reporting; (vi) fulfil the other purposes set out above.

9.2.      You are free to decline or block our Cookies (insofar as your browser or application permits), but this may interfere with our Services and you may not be able to use certain features or functions of our Services.  We will not be liable for any failure to provide any Services if such failure is due to our Cookies being declined or blocked.

9.3.      We may also use other technologies (such as a pixel tag or web beacon) for the purposes set out above.

10.       CONTACT US

10.1.   For any questions or notice regarding your personal data, please contact our Data Protection Officer at [].

Last Modified: 28th January 2018