Personal Data Protection Act

ANNEX I
Privacy Policy

• 1.Introduction
  • 1.1.This privacy policy ("Privacy Policy") forms a part of the terms and conditions ("Terms") governing your relationship with Yellowbox ("Yellowbox", "we", "us" or "our") in relation to our products, services, website and any software provided on or in connection with Yellowbox's services (collectively, the "Services") and should be read in conjunction with those Terms.
  • 1.2.This Privacy Policy applies to all visitors, users and others who access the Services and governs the manner in which Yellowbox manages, collects, uses and discloses personal data in relation to the Services, which is subject to the Singapore Personal Data Protection Act.
  • 1.3."Personal Data" in this Privacy Policy includes any data about an individual who can be identified:-
    • 1.3.1.from that data; or
    • 1.3.2.from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
    Such Personal Data may without limitation include names, NRIC, passport or other identification numbers, telephone numbers, mailing addresses, email addresses, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
  • 1.4.When you use the Services or submit information to Yellowbox, you agree and consent to Yellowbox and its related companies (collectively, the "Companies"), their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.
• 2.Collection of Personal Data
  • 2.1.Yellowbox collects Personal Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our website, in the following manner:-
    • 2.1.1.when you submit a form for registering as a customer on our website or any other forms relating to any of our Services;
    • 2.1.2.when you interact with our customer service team, including but not limited to, telephone calls, letters, face-to-face meetings and emails;
    • 2.1.3.when you use some of our Services, for example, websites and applications including establishing any online accounts with us;
    • 2.1.4.when you request that Yellowbox contact you, be included in an email or other mailing list;
    • 2.1.5.when you respond to our promotions, initiatives or to any request for additional Personal Data;
    • 2.1.6.when you are contacted by, and respond to, our marketing representatives and customer service team;
    • 2.1.7.when we receive references from business partners and third parties, such as, without limitation, where you have been referred by them;
    • 2.1.8.when you submit your Personal Data to us for any other reasons.
  • 2.2.By providing Personal Data relating to a third party to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes listed above.
• 3.Purposes for the Use and Disclosure of Personal Data
  • 3.1.Yellowbox collects, uses and discloses your Personal Data for the following purposes in connection with the products and services which you have applied for, to the extent applicable:-
    • 3.1.1.helping you efficiently access your information after you sign in;
    • 3.1.2.remembering information so that you will not have to re-enter it during your visit or the next time you use the Services;
    • 3.1.3.providing personalized content and information to you and others;
    • 3.1.4.providing, testing, improving and monitoring the effectiveness of the Services;
    • 3.1.5.developing and testing new products and features;
    • 3.1.6.monitoring metrics such as total number of visitors, traffic and demographic patterns;
    • 3.1.7.diagnosing and fixing technology problems;
    • 3.1.8.collecting and measuring traffic and usage trends for analytics purposes, including but not limited to determining popularity of certain content to better understand your online activity;
    • 3.1.9.maintaining a history log of our systems' activities;
    • 3.1.10.responding to your queries and requests;
    • 3.1.11.managing the administrative and business operations of Yellowbox and complying with internal policies and procedures;
    • 3.1.12.facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
    • 3.1.13.matching any Personal Data held which relates to you for any of the purposes listed herein;
    • 3.1.14.resolving complaints and handling requests and enquiries;
    • 3.1.15.preventing, detecting and investigating crime and analyzing and managing commercial risks;
    • 3.1.16.providing media announcements and responses;
    • 3.1.17.monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
    • 3.1.18.organising promotional events;
    • 3.1.19.legal purposes (including but not limited to obtaining legal advice and dispute resolution);
    • 3.1.20.conducting investigations relating to disputes, billing or fraud;
    • 3.1.21.meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Yellowbox (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
    • 3.1.22.purposes which are reasonably related to the aforesaid.
  • 3.2.In order to carry out the purposes listed above, we may share and disclose your Personal Data to third parties, whether in Singapore or elsewhere, such as the following:-
    • 3.2.1.the Companies and employees to provide content, products and services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our products and services, to activate, deactivate, install, maintain and operate our systems and/or services;
    • 3.2.2.companies providing services relating to insurance and consultancy to the Companies;
    • 3.2.3.agents, contractors or third party service providers who provide operational services to Yellowbox, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services;
    • 3.2.4.vendors or third party service providers in connection with marketing promotions and services offered by Yellowbox or its partners;
    • 3.2.5.commercial shops and retailers in relation to providing rewards and benefits;
    • 3.2.6.any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
    • 3.2.7.our professional advisers, including but not limited to, auditors and lawyers;
    • 3.2.8.relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
    • 3.2.9.any other parties to whom you authorise us to disclose your Personal Data to.
• 4.Access and Correction of Personal Data
  • 4.1.You may access your Personal Data either via the Yellowbox website or by contacting our data protection officer ("Data Protection Officer").
  • 4.2.When you change, update or correct any of your Personal Data, third parties whom we work with may be updated of this change.
• 5.Accuracy of Personal Data
  • 5.1.You are responsible for the correctness, accuracy and completeness of any Personal Data you provide us. You shall inform us in a timely manner of all changes to the information provided to us.
• 6.Protection of Personal Data
  • 6.1.Yellowbox uses commercially reasonable safeguards to keep the information collected through the Services secure and take reasonable steps to verify your identity. However, Yellowbox cannot ensure the security of any information you transmit to us, nor guarantee that information on the Services may not be accessed, disclosed, altered or destroyed.
• 7.Retention Limitation
  • 7.1.Your Personal Data is retained to the extent that one or more of the purposes for which it was collected remains valid and for other legal or business purposes for which retention may be necessary.
• 8.Transfer Limitation
  • 8.1.Your Personal Data collected through the Services may be stored and processed in Singapore or any other country in which Yellowbox or its third-party partners ("Service Providers") maintain facilities.
  • 8.2.Yellowbox or its Service Providers may transfer information that we collect about you, including Personal Data across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
• 9.Openness
  • 9.1.You may withdraw your consent for any or all of the purposes set out in this Privacy Policy in writing by contacting our Data Protection Officer. If you withdraw your consent to any or all of the purposes, Yellowbox may not be in a position to continue to provide services to you. Your withdrawal may be considered a termination by you of any contractual relationship which you may have with us, and a breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
  • 9.2.You may contact our Data Protection Officer at [dpo@yellowbox.com].
• 10.Miscellaneous
  • 10.1.This Privacy Policy does not derogate from the Terms. Yellowbox's rights under this Privacy Policy shall be without prejudice to the other rights of collection, use and disclosure available pursuant to the Terms or under the law and nothing herein is to be construed as limiting any of these other rights.
  • 10.2.This Privacy Policy and your use of the Yellowbox website shall be governed by the laws of Singapore.