1. LEGAL INFORMATION

1.1 Colossus Labs Pte. Ltd. (Company Registration No.: 200200939M) is a company incorporated in Singapore and having its registered office at 160 Kallang Way #01-03, Singapore 349246 (“Colossus Labs”, “we”, “our” or “us”).

1.2 This privacy policy (“Privacy Policy”) governs how Colossus Labs and/or its associated and affiliated companies, whether in Singapore or abroad (collectively, the “Group”) uses personal data (a) collected from you, or; (b) that you provide to Colossus Labs, in connection with the access and use of the Platform. This includes all services, features and Content provided through the Platform.

1.3 This Privacy Policy is based on the Singapore Personal Data Protection Act 2012 (“PDPA”) and all associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Singapore. It sets out the basis on which Colossus Labs collects any personal data from you, or the basis on which your personal data will be disclosed, used and/or processed by Colossus Labs.

1.4 By accessing and using the Platform, you are deemed to agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully before accessing and using the Platform, or otherwise providing any personal data. If you wish to amend or remove any of your personal data in our possession, please refer to clause 4 of this Privacy Policy for the required procedure.

1.5 This Privacy Policy supplements but does not supersede nor replace any other consent that you may have previously given us, nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/or retention of your personal data.

This Privacy Policy forms part of our General Terms and Conditions (https://owlsmart.sg/page/terms-and-conditions). Unless otherwise defined here, capitalised terms used shall have the meaning given to them in the General Terms and Conditions.

2. COLLECTION OF PERSONAL DATA

2.1 Personal data refers to data about an individual who can be identified from either (a) that particular data, or (b) from that particular data and other information which Colossus Labs has, or is likely to have, access to. Such personal data shall also refer to (i) data already in our possession; or (ii) the data to be collected by us.

Commonly collected personal data of our Users may include (but is not limited to):

1. personal particulars (e.g. name, contact details, residential address, date of birth, identity card details, passport details, and/or education details);
2. financial details (e.g. income, expenses, and/or credit history);
3. banking information (e.g. bank account numbers);
4. payment information (e.g. credit card number and related account and billing information);
5. images and voice recordings of our conversations with you;
6. employment details (e.g. occupation, directorships and other positions held, and/or employment history);
7. tax and insurance information;
8. information about your knowledge and experience, interests;
9. communications between you and other Users, made through the Platform; and/or
10. personal opinions made known to us (e.g. feedback or responses to surveys).

2.2 Collection of personal data

Wherever possible, we only collect personal data directly from you. Situations where this can occur include when (or before) you:

1. register for an account with us;
2. sign up for our newsletter and other mailings;
3. use the Platform; and/or
4. submit, post or upload any User-Generated Content.

2.3.2 In addition to personal data provided to us, we may also collect information related to you that is not considered personal data. We collect this information to improve the Platform. Such non-personal data includes information such as your IP address, the internet browser and operating system you use, details of your interaction with the Platform, and preferences. We use this information to improve the Platform, perform routine Platform maintenance, to generate aggregate Platform traffic reports, and enhance the performance of our Platform on different browsers and devices.

2.3.3 We may also receive personal information about you from other sources if you have given permission for that information to be shared. This may include information from commercially available sources, such as public databases and data aggregators, and information from third parties.

2.3 Use of cookies

2.4.1 The Platform may use data collection devices such as “cookies” and other technologies such as pixel tags and web beacons to personalise your online experience, help analyse the Platform flow, and measure promotional effectiveness. “Cookies” are small files placed on your hard drive that assist us in operating the Platform. We may offer features that are only available through the use of a cookie. We also use cookies to reduce the number of times you need to enter your password. Cookies may also help us provide you with information targeted to your interests. Most browsers automatically accept cookies but you can modify your browser to decline cookies (if your browser permits you to do so). However, in this case you may not be able to access certain features on the Platform or some interactive features offered on the Platform may be restricted or rendered inoperable.

2.4.2 The Platform may allow third parties (for example, analytics firms and business partners) to download cookies to your device. These third parties may use cookies and other technologies to collect non-personal data about your online activities while you are using the Platform. We have no access to, or control over these cookies, or other features these third parties use, and the information practices of these third parties are not covered by this Privacy Policy.

3. USE OF PERSONAL DATA

3.1 Using your personal data

3.1.1 We collect personal data from our existing and prospective Users for various reasons. These purposes include:-

1. fulfilling our obligations or exercising our rights under the General Terms and Conditions;
2. providing and improving your experience on the Platform;
3. authenticating your access to parts of the Platform you are authorised to access;
4. reviewing, processing and confirming any request, application or User-content which you submit, in using the Platform;
5. analysing the effectiveness of our advertisements, competitions and promotions;
6. customising your Platform experience, as well as evaluating statistics on Platform activity, such as what time you visited it, whether you have visited it before, and what site referred you to it;
7. making the Platform easier to use and tailoring the Platform to your interests and needs;
8. marketing and communicating with you in relation to the Platform and our relevant service partners;
9. processing, managing and administering accounts on the Platform;
10. sending you information you have requested;
11. responding to your comments, feedback or queries;
12. resolving disputes, collecting fees, distributing returns, troubleshooting problems;
13. fulfilling a legal or regulatory requirement;
14. detecting, preventing or otherwise addressing fraud or security issues;
15. informing you of any changes to our General Terms and Conditions;
16. improving the quality of the Platform, its Content and functionalities with market research and surveys;
17. supplying you with information that is relevant to your existing relationship with us; and
18. suggesting products or services which we think may interest you.

3.1.2 Personal data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by retaining it; and (b) retention is no longer necessary for legal or business purposes.

3.2 Sharing your personal data

3.2.1 Colossus Labs shares your personal information with trusted third parties and strategic partners. These parties and partners assist us with our business operations or provide the Platform. We may also share your personal data with trusted third parties and strategic partners that help Colossus Labs market to Users and potential Users. Such parties may either be in Singapore or abroad and may include:

1. any member in our Group;
2. our advertising, marketing and promotional agencies to help us deliver and analyse the effectiveness of our advertising campaigns and promotions;
3. third parties for the purpose of raising funds;
4. law enforcement or government authorities following due legal process in requesting disclosure of your information;
5. third parties who wish to send you information about their products and services, but only if you have given us your consent to do so;
6. third party providers of services, such as data processing; and
7. web analytics tool providers, such as Google.

3.2.2 We may also share your personal data for the following reasons: -

1. reasons provided under clause 3.1 ‘using your personal data’;
2. verification of your identity;
3. to protect our rights or property (including but not limited to any intellectual property rights);
4. to respond to claims that you violated the rights of third parties;
5. to conduct investigations into possible breaches of applicable laws; and/or
6. to comply with a court order or other legal or regulatory requirements in the jurisdictions we operate.

3.2.3 In situations where a third party under contract with Colossus Labs collects personal data about you, we use commercially reasonable efforts to require the third party to exercise reasonable care in protecting your information.

3.2.4 The Platform may also enable you to interact with or contain links to other party websites, applications and services that are not owned or controlled by Colossus Labs (which may include those which are owned or controlled by other Users). Colossus Labs is not responsible for the privacy practices or the content of these third parties and, accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to use or interact with.

3.2.5 To avoid doubt, if we have reasonable grounds to believe that you are in breach of any of the terms of this Privacy Policy, the General Terms and Conditions or any agreement(s) and/or terms and conditions that govern our relationship with you, we reserve the right, in our sole and absolute discretion, to report to, and cooperate fully with, other parties. These may include:

1. governmental authorities;
2. private investigators;
3. all the rightful owner(s) or interest holder(s); and/or
4. injured third parties in the investigat ion of any potential or ongoing criminal or civil wrongdoing.

3.2.6 Further, we may disclose your identity and contact information, or such other transaction-related data:

1. if requested by a government or law enforcement body, private investigator, rightful owner or interest holder and/or any injured third party or as a result of a subpoena or other legal action; or
2. if we are of the view, in our sole and absolute discretion, that it would be in our best interest to do so.

3.2.7 We shall not be liable in any way for damages or results arising from such disclosure, and you agree not to bring an action or claim against us for such disclosure.

4. AMENDMENTS TO PERSONAL DATA / OPT OUT

4.1 You have a right to access, change and remove the personal data held by Colossus Labs. If you wish to do so, please contact our Data Protection Officer at [email protected]. You may also access, change and remove your personal details by clicking on 'My Account'. You may also decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive.

To the extent not required by Colossus Labs in connection with providing the Platform, if you do not want your personal data to be shared among affiliates, business partners or unrelated third parties, you may opt-out of such information sharing by sending us an email at [email protected].

5. SECURITY

5.1 Colossus Labs uses reasonable measures to protect your personal data and to store it securely. Where personal information is entered on the Platform, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) technology. However, due to the inherent nature of the Internet as an open global communications vehicle, no method of transmission over the Internet or method of electronic storage is 100% secure. While security cannot be guaranteed, we strive to protect your personal data and are constantly reviewing and enhancing our security protocols to ensure that your personal data is not subject to unnecessary risks.

6. TRANSFER OF PERSONAL DATA

6.1 We may transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.

6.2 Colossus Labs, or substantially all of Colossus Labs’s assets, or effective control over them, may be acquired by one or more third parties as a result of an acquisition, merger, sale, reorganisation, consolidation or liquidation. In such a situation, databases containing User personal information may be one of the assets transferred, over which such third parties may gain control, or to which they may gain access. In using the Platform, you consent to such transfer of, control over and access to your personal data.

7. CONTACTING YOU

7.1 Colossus Labs is committed to complying with the Do Not Call ("DNC") provisions set out in the PDPA. If you have registered your telephone number with the DNC Registry, Colossus Labs will not send you promotional and marketing messages via phone calls, text messages and faxes. However, if you have previously given Colossus Labs consent to contact you for such purposes, we will continue to do so until you withdraw your consent.

7.2 If you no longer wish to receive marketing and/or promotional messages from Colossus Labs and had previously provided Colossus Labs with your consent to do so, you can withdraw your consent by contacting us at [email protected].

8. RIGHTS TO AMEND THIS PRIVACY POLICY

8.1 We reserve the right to amend this Privacy Policy at any time. If material changes are made to this Privacy Policy, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.

8.2 Your continued access and use of the Platform after any changes to this Privacy Policy constitutes your consent to any such changes.