1. Introduction

1. This privacy policy (“Privacy Policy”) supplements the Proxtera website (the “Website”) terms of use (“Terms of Use”) which can be accessed here and sets out the ways in which we collect, use and disclose information in connection with the operation of the Website and the provision of the Services (as defined in the Terms of Use), including personal data about you as a user of the Website and/or Services (“User”, “you”, or “your”), as well as any individual designated by a User to be granted access credentials to access and use the Website.

2. By accessing and using the Website and/or the Services, you consent to how we collect, use and disclose personal data, including the purposes for which we process data and how we share personal data internally and with third parties.

3. We may update this Privacy Policy from time to time. Any changes we make to this Privacy Policy in the future will be posted on this page and, for material changes only (where appropriate and/or permitted under applicable laws), notified to you, whereupon your continued access to the Website or use of the Services shall constitute your acknowledgment and acceptance of the changes we make to this Privacy Policy.

2. Collection of personal data

1. In this Privacy Policy, “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 an organisation has or is likely to have access.

2. During the course of your use of the Website and/or the Services, we may collect and receive personal data from you, including but not limited to in the following situations:

1. When you register for an account on the Proxtera Website (a “Proxtera Account”).

2. When you use any of the features and functions available on the Website or Services.

3. If you submit a query or report a problem to us in respect of the Website and/or the Services.

4. When you interact with us offline or through a third party.

3. The types of personal data we collect from you may include but is not limited to:

1. Account credentials / profile information such as your username and password.

2. Contact information such as billing address, delivery address, email address and phone numbers.

3. Usage data such as information on how you use the Website and/or the Services.

4. Device and technical information such as login data, time zone setting and location, browser type / version and plug-ins, operating system and platform, internet protocol (IP) address, hardware model, unique device and application identifiers, and other information and technology on the devices you use to access the Website and/or the Services.

5. Any communications on the Website made between you and another User of the Website and/or the Services.

6. Any other personal data disclosed by you in any of the above-mentioned methods and/or through the access and use of the Website and/or the Services.

4. You are under no obligation to provide personal data to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may not be able to provide you with access to or use of the Website and/or the Services (or certain aspects thereof).

5. By providing us with any personal data or other information of or relating to a third party, you represent to us that you have validly obtained the consent of the third party to disclose and share the third party’s personal data or other information to us, and for us to collect, store, use and disclose that personal data or other information in accordance with the terms of this Privacy Policy.

3. Use and disclosure of personal data

1. The personal data we collect from you or via third parties may be used by us, or shared with or transferred to third parties (such as our related companies, partners, third party service providers, and/or other Users), for purposes including but are not limited to:

7. Providing, and facilitating your access to and use of, the Website and/or the Services.

8. Developing, improving, and maintaining the Website and/or the Services.

9. Updating our records and generally maintaining your Proxtera Account with us.

10. Responding to your queries and resolving issues reported in respect of the Website and/or the Services.

11. Assessing and monitoring account security, monitoring and detecting fraud or prohibited content, businesses or activities on the Website or Services, and processing any complaints, feedback, or enforcement action (including take-down requests).

12. Conducting analysis, research, polls or surveys on the usage of, and how we can improve, the Website and/or the Services.

13. Complying with Proxtera’s obligations under any applicable laws, regulations, guidelines or notices issued by any government or regulatory authority (whether in Singapore or overseas including disclosing such data to Singapore or overseas law enforcement agencies or courts).

1. By using our Services, you agree and consent to us:

1. using your information in any of the countries where Proxtera operates for the purposes described above, provided that any transfer of personal data shall be made in accordance with this Privacy Policy and protected in accordance with applicable data protection laws; and

2. disclosing your personal data, to the extent permitted by applicable laws, regarding your usage of and activities carried out on or via the Website, for the purposes of cooperating with or complying with a request from any governmental, regulatory, or law enforcement bodies, and/or injured third parties in the investigation of any suspected criminal activity or civil wrongdoing by a User. We shall not be liable for damages or results arising from such disclosure, and you agree not to bring any action or claim against us for such disclosure.

4. Withdrawal of consent in respect of your personal data

1. You may at any time communicate (via the contact details set out in Section 11 below) the withdrawal of your consent to the continued use, disclosure and/or processing of your personal data in any manner or for any of the purposes stated in this Privacy Policy. However, if you communicate your withdrawal of your consent to our use, disclosure or processing of your personal data, we may not be in a position to continue to provide the Services (or aspects thereof) or access to the Website to you. In such an event, we shall not be liable for any loss or damages arising out of or in connection with such cessation of the Services or access to the Website, and all our legal rights and remedies are expressly reserved.

2. You may delete your account at any time by emailing contact@proxtera.com with the subject ‘deletion of account ‘ as well as the reason for cancellation in the body of the email or by using the ‘account deletion’ functionality within the Portal. On a best effort basis, we will endeavor to attend to your request within 14 working days of receipt of the cancellation request. We will remove all personal information associated with the account, subject to any legal or regulatory obligations that may require us to retain certain data. We reserve the right, but are under no obligation to, to delete an account from the Portal that remains inactive (i.e., the user fails to log in) for a continuous period of at least six (6) months.

5. Amending or updating of personal data

To facilitate our provision of the Services, and to minimise or avoid issues arising from inaccurate, incomplete, misleading or out-of-date information, please ensure that any personal data which you provide is accurate, complete and not misleading, and to update such personal data as and when it becomes inaccurate, incomplete, misleading or out-of-date.

6. Accessing personal data

Subject to applicable laws, you may request (via the contact details set out in Section 11 below) to obtain a copy of your personal data which we have collected, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us. To facilitate our processing of your request, we may request further information relating to your request. We reserve the right to charge a reasonable administrative fee for retrieving your personal data records (which will be communicated to you before processing your request).

7. Other personal data and data protection rights

Subject to applicable laws and regulations, you may have rights in respect of your personal data which are in addition to, or differ from, those which are stated in this Privacy Policy. We respond to all requests we receive from individuals (via the contact details set out in Section 11 below) wishing to exercise their personal data and/or data protection rights in accordance with applicable data protection laws and regulations.

8. Security measures

1. We implement appropriate technical and organisational security measures to prevent unauthorised access to or use of the Website and/or the Services, to maintain data accuracy and to ensure the correct use of the information in our possession. However, no method of transmission over the internet or method of electronic storage is completely secure. As such, while we strive to deploy appropriate technical and organisational measures to protect the personal data in our possession, we cannot guarantee its absolute security.

2. Upon becoming aware of a data breach, we will notify you and the regulatory authorities in accordance with the timescales and scope required by applicable data protection law.

3. For Users with a registered Proxtera Account, it is important that you protect against unauthorised access of your Proxtera Account and personal data by keeping your Proxtera Account password secure and not disclosing it to anyone. We will never ask you for your password (whether via the Website, Services, email, phone or otherwise). When using a shared computer to sign in to your Proxtera Account, we would recommend that you do not choose to save your log-in information (i.e. username and password) on the shared computer. If you share your Proxtera Account password with others, you will be deemed responsible for all actions taken in the name of your account. If you become aware or have any reason(s) to suspect that your password has been compromised, we recommend that you immediately change your password.

9. Cookies and other tracking technologies

1. We or our authorised service providers may use cookies and/or other similar technologies (collectively, “cookies”) to recognise and distinguish you from other Users of the Website and/or the Services. A cookie is a small data file sent from a website to your browser that is stored on your device. Depending on the browser and/or device which you use to access the Website and/or the Services, you can configure your browser or device’s settings to reflect your preference to accept or reject cookies. However, if you reject all cookies, you may not be able to take full advantage of the Website and/or the Services.

2. Cookies are used for a number of purposes such as:

1. technical and/or security reasons in order for the Website and Services to operate;

2. analytics, collecting information in aggregate form to help us analyse and understand how Users use the Website and the Services; and

3. determining the total audience size and traffic on the Website and Services and conducting research to improve our Services.

10. Third party sites

The Website and/or the Services may contain links to other websites or platforms operated by third parties (“Third Party Sites”). This Privacy Policy does not apply to Third Party Sites and we are not responsible for the privacy practices of Third Party Sites and have no control over the information you submit to such third parties. You are advised to read the relevant privacy policies of such Third Party Sites to determine how they will handle any information they collect from you when accessing and/or using such Third Party Sites.

11. Contact us

If you have any questions on personal data protection or data privacy, please contact us at contact@proxtera.com.