PRIVACY POLICY
Getstan Technologies Pte Ltd (“Company”) has built the STAN - Play, Chat & Win application as a
free-to-use mobile application, along with the website at
https://getstan.app/ (collectively referred to as the “Platform”), and the offered content therein, which is provided to users
(“User”) at no cost and is intended for use as is. This page is used to
inform website visitors regarding Company’s policies in relation
to the collection, use, and disclosure of personal information of anyone
using Company’s Services through the Platform.
If User chooses to use any of the Services, then User agrees to the
collection and use of information in accordance with this policy. The
Personal Information that Company collects is used for providing and
improving the Service. Company does not use or share User’s
information with anyone except as described in this Privacy
Policy.
The terms used in this Privacy Policy have the same meanings as in
Company’s End User License Agreement (“EULA”), which are accessible at the STAN - Play, Chat & Win application and website, unless otherwise defined in this Privacy
Policy.
This Privacy Policy shall apply to all the Users using the Platform for
the Services.
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Salient Features of this Privacy Policy
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Company will collect Personal Information by lawful and fair means
and, with the knowledge or consent of the User concerned.
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Before or at the time of collecting Personal Information, Company
will identify the purpose for which information is being
collected.
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Company will collect and use Personal Information solely for
fulfilling those purposes specified by Us and for other ancillary
purposes, unless Company obtains the consent of the individual
concerned or as required by law.
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Company will protect Personal Information by using reasonable
security safeguards against loss or theft, as well as unauthorized
access, disclosure, copying, use or modification.
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Company will make readily available to Users/Users information about
Company’s policies and practices relating to the management of
Personal Information.
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Company will only retain Personal Information for as long as
necessary for the fulfilment of those purposes.
Please do note that Personal Information and non-personal information
may be treated differently as per this Privacy Policy
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Application and Scope
This Privacy Policy describes Company’s practices with respect to
the collection, use and disclosure of Personal Information by
Company.
This Privacy Policy (this “Policy”) is intended to establish responsible and transparent practices for
the management of Personal Information and to satisfy the relevant and
applicable legal requirements. This Policy sets out the standards,
responsibilities, rights and obligations of the Company in respect of
any Personal Information collected, accessed or processed by Company in
the course of its business operations and specifies the obligations of
Company that arise from Company’s End User License Agreement
(“EULA” available here) (the “Terms”) entered into between Company and its Users/ Users, whereby
Company might handle or have access to Personal Information.
This Policy also governs how Company uses and discloses Personal
Information collected from Users, who visit its Platform. It also
explains how Company uses cookies and similar technologies. If User does
not agree with this Policy, then User should not access, or use the
Platform and any related Services.
This Policy is an electronic record in the form of an electronic
contract formed under the applicable laws of Singapore. This Policy does
not require any physical, electronic or digital signature.
This Policy is published and shall be construed in accordance with the
provisions of the applicable laws of Singapore that require publishing
of the privacy policy for collection, use, storage and transfer of
sensitive personal data or information.
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Definition of Personal Information: “Personal Information” means any information about an identifiable individual,
including email addresses, contact details, information regarding
User’s transactions on the Platform, User’s financial
information, e-wallet address, internet protocol address, information
provided to Company in the course of its business operations, or which
Company may receive from business inquiries and any other items of “sensitive personal data or information” as such term
is defined under the laws of Singapore, identification code of User’s communication device which User
uses to access the Platform or any other information that User
provides during User’s registration process, on the Platform.
Personal Information that is aggregated and/or de-identified or that
cannot be associated with an identifiable individual is not considered
to be Personal Information.
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Collection and Use of Personal Information through the Services
(Purpose)
When providing the Services, Company only processes Personal
Information in accordance with the EULA and applicable laws. Company
generally uses Personal Information from or about its Users for the
following purposes:
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to create, establish and administer User’s account, to process
payments, to respond to User’s inquiries related to his/her
account and to contact User about Company’s Services or account-related matters;
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to provide Services, including to provide Users with access and use
of the Platform and User support;
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to manage and develop Company’s business and operations;
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to measure and analyze User behavior;
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to monitor, maintain and improve Company’s Services or
features;
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to understand how Users interact with Company and ensure
Company’s Services, products or features work correctly;
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to develop new services, products, features, programs and
promotions;
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to understand Users’ needs and preferences and customize how
Company tailors and markets products, programs and Services to
Company’s Users based on their interest;
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to meet legal and regulatory requirements and to allow Company to
meet contractual requirements relating to the Services provided to
User;
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to conduct surveys on the quality of Services or to collect feedbacks
on the Services;
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to provide User with offers for additional services, features and
products that Company believes may be of interest to User;
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to send User important information regarding the Platform, changes in
EULA, user agreements, and policies and/or other relevant
information;
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to implement information security practices and to determine any
security breaches, computer contaminant or computer virus;
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to investigate, prevent, or take action regarding illegal activities
and suspected fraud;
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to enable a potential buyer or investor to evaluate the business of
the Company;
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to conduct market or benchmarking research and data analytics by
tracking and analyzing current or previously collected Personal
Information; and
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to measure the effectiveness of Company’s marketing.
When possible, Company will use Personal Information in an aggregated
and/or de-identified format. Unless required or authorized by law,
Company will not use Personal Information for any other or new purpose
without obtaining prior consent.
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Collection and Use of Personal Information through the Platform
Company generally collects and uses Personal Information from or about
its Platform Users as follows:
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For Creation of Account: For enabling the access to the Services, User needs to create
an account. In order to manage such account from creation to deletion,
the Company shall collect and process identification Personal
Information such as User’s first name, last name, username and
contact details).
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For use of Services: The Company collects and processes User’s Personal
Information for the use of the Services. This processing requires the
Company to collect and process the following categories of Personal
Information:
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for the purchase, transfer, withdrawal and exchange of Collectibles:
username and the payment identifier and part of User’s bank
card's digits;
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for the participation in the Stan Events: username, payment
identifiers and prize winners;
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The legal basis on which the Company relies for this purpose is the
performance of a contract to which User is a party.
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Information Provided by Users. In many cases, Company collects Personal Information directly from
Users when they visit or use the Platform. For instance, Company may
collect the following types of information:
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Inquiries and Requests for a Trial or Service. Company may collect Users’ name, contact information, email
address and any other information provided when Users make an inquiry
or contact Company through the Platform, when Users sign up to receive
Company’s newsletter/updated about events or when Users submit a
request or an order for a Company trial for Service.
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Personalization of Platform: When Users visit the Platform, they may, from time to time, be
invited to provide information such as User’s title to help
Company personalize or customize the User’s experience when
using the Platform.
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Payment Processing: In connection with the payment of any Service on the Platform or
through any other linked platform (whether offered by Company or its
partners), Company may seek further information pertaining to the
payment instrument/modes used by the User for payments towards such
Service fee.
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Technical Information: When Users visit the Platform, Company may collect, using
electronic means such as cookies, technical information. This
information may include information about visits to the Platform,
including the IP address of the Users’ computer and which
browser was used to view the Platform, the Users’ operating
system, resolution of screen, location, language settings in browsers,
the site the User came from, keywords searched (if arriving from a
search engine), the number of page views, information entered,
advertisements seen, etc. This data is used to measure and improve the
effectiveness of the Platform or enhance the experience for Users.
While most of the time this information is depersonalized, if this
information relates to an identifiable individual, Company will treat
this information as Personal Information. Company may also, without
limitations, collect and use the following type of information when
Users visit and/or interact with Company on the Platform:
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Google Analytics: Company uses Google Analytics which allows it to see information on
User Platform activities including, but not limited to, page views,
source and time spent on the Platform. This information is
depersonalized and is displayed as numbers, meaning that it cannot be
tracked back to individuals. Users may opt-out of Company’s use
of Google Analytics by visiting the Google Analytics opt-out
page.
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HubSpot:[a] Company uses HubSpot which allows it to see information on
Platform activities including, but not limited to, page views, source
and time spent on the Platform. However, this information is not
depersonalized and Users may not opt-out of Company’s use of
HubSpot.
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Google AdWords: Company uses Google AdWords Remarketing to advertise Company across
the Internet and to advertise on third party websites (including
Google) to previous visitors of the Platform. AdWords remarketing will
display ads to Users based on what parts of the Platform they have
viewed by placing a cookie on the Users’ web browser. It could
mean that Company advertises to previous visitors who haven’t
completed a task on the site or this could be in the form of an
advertisement on the Google search results page, or a site in the
Google Display Network. This cookie does not in any way identify the
User or give access to the Users’ computer or mobile device. The
cookie is only used to indicate to other websites that the User has
visited a particular page on the Platform, so that they may show the
User ads relating to that page. If Users do not wish to participate in
Google AdWords Remarketing, they can opt out by visiting
Google’s Ads Preferences Manager.
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Interest-based Advertising. Company may also allow a limited number of trusted third parties to
install cookies on Users’ hard drive from the Platform. The
Platform may include third-party advertising and links to other
websites which may be used to generate personalized advertisements.
Personalized ads, sometimes referred to as interest-based or
behavioral ads, are ads based upon information about Users, such as
page views on the Platform, information requests or purchases on the
Platform. Company does not provide any Personal Information to
advertisers or to third party sites that display interest-based ads on
the Platform. However, advertisers and other third-parties (including
the ad networks, ad-serving companies, and other service providers
they may use) may assume that Users, who interact with or click on a
personalized ad or content displayed on the Platform are part of the
group that the ad or content is directed towards. Advertisers or ad
companies working on their behalf sometimes use technology to serve
the ads that appear on the Platform directly to Users’ browser.
They may also use cookies to measure the effectiveness of their ads
and to personalize ad content. Company does not have access to or
control over cookies or other features that advertisers and
third-party sites may use, and the information practices of these
advertisers and third party Platform are not covered by this Policy.
Please contact them directly for more information about their privacy
practices.
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Segment: Company uses Segment which allows it to transmit user Platform
activities including, but not limited to, page views, source and time
spent on the Platform to Company’s data warehouse. This information is depersonalized and is displayed
as numbers, meaning that it cannot be tracked back to individuals.
Users may not opt-out of Company’s use of Segment.
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Choice with Cookies. Users can block the use of cookies by activating the settings in
their browser/device. If Users choose to withhold consent, or
subsequently block cookies, they may not be able to access all or part
of the content of the Platform. Additionally, Users can disable or
delete similar data used by browser add-ons, by changing the
add-on’s settings or visiting the Platform.
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Privacy Policies of other Platform: This Policy only addresses the use and disclosure of information by
Company. Other platforms that may be accessible through the Platform
have their own privacy policies and data collection, use and
disclosure practices.
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Personal Information from Other Sources: Company may obtain from third parties additional Personal
Information about a Platform User if such User gave permission to
those third parties to share its information.
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Sharing of Personal Information
Company will not sell, rent or trade Personal Information to any third
party. However, Company may share Personal Information when authorized
and/or required by law or as follows:
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Within Company: Company may share Personal Information within Company (i.e. between
Company’s affiliates and subsidiaries) in Singapore and overseas
for the purposes described in this Policy.
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Service Providers: Company may grant access to Personal Information to third-party
service providers in connection with the performance or the
improvement of its Platform and Services. Before sharing any Personal
Information with any of its third-party service providers, Company
will request that the third party maintains reasonable data management
practices for maintaining the confidentiality and security of Personal
Information and preventing unauthorized access. Provided however, the
Company shall not be responsible for any misuse or unauthorized
disclosure of any Personal Information by such third party service
provider. Company shall inform the User of such unauthorized
disclosure as soon as reasonably possible.
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As Permitted or Required by Law: Company may disclose Personal Information as required by applicable
law or by proper legal or governmental authority. Company may also
disclose information to its accountants, auditors, agents and lawyers
in connection with the enforcement or protection of its legal rights.
Company may also release certain Personal Information when it has
reasonable grounds to believe that such release is reasonably
necessary to protect the rights, property or safety of others and
itself, in accordance with or as authorized by law. In the event
Company receives a governmental or other regulatory request for any
Personal Information, Company will promptly notify User, unless it is
prohibited to do so, in order that User shall have the option to
defend such action. Company shall reasonably cooperate with User in
such defense.
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Business Transaction: Company may disclose Personal Information to a third party in
connection with a sale or transfer of business or assets, an
amalgamation, re-organization or financing of parts of Company’s
business. However, in the event the transaction is completed, Personal
Information will remain protected by applicable data protection laws
of Singapore. In the event the transaction is not completed, Company
will require the other party not to use or disclose the Personal
Information received in any manner whatsoever.
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User Contributions
Company’s User agrees not to host, display, upload, modify,
publish, transmit, store, update or share any information that:
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belongs to another person and to which User do not have any
right;
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includes bodily privacy, insulting or harassing, that is libelous,
racially or ethnically objectionable, relating or encouraging money
laundering or gambling, or otherwise inconsistent with or contrary to
the laws in force;
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is harmful to children;
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infringes any patent, trademark, copyright, or other proprietary
rights;
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violates any law for the time being in force;
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deceives or misleads the addressee about the origin of the message or
knowingly and intentionally communicates any information which is
patently false or misleading in nature but may reasonably be perceived
as a fact;
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impersonates another person;
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threatens the unity, integrity, defence, security or sovereignty of
Singapore, friendly relations with foreign states, or public order, or
causes incitement to the commission of any cognizable offence or
prevents investigation of any offence or is insulting other nation;
and/or
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contains software virus or any other computer code, file or program
designed to interrupt, destroy, or limit the functionality of any
computer resource.
- Log Data
Whenever User uses Service, Company collects data and information
(through third party products) on User’s phone called Log Data.
This Log Data may include information such as User’s device
Internet Protocol (“IP”) address, device name, operating
system version, the configuration of the app when utilizing Service, the
time and date of User’s use of the Service, and other
statistics.[b]
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Cross-border data transfer
Personal Information that Company holds about User may be transferred
to countries outside of Singapore for any of the purposes mentioned in
this Privacy Policy. User expressly provides his/her consent for
transfer of such Personal Information outside Singapore. Any Personal
Information will be protected in accordance with this Privacy Policy as
well as any applicable laws and regulations.
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Security and Consent
Company has in place physical, electronic and administrative safeguards
to protect User’s Personal Information. User’s posting and
sharing of Personal Information through the Platform constitutes
User’s acceptance of the risk that Company cannot guarantee
absolute security, and User hereby agrees to waive any claims that User
may have against us and any right to seek legal relief from us due to
any misuse of the Personal Information in the manner aforesaid.
Company will store and process the Personal Information in a manner
consistent with industry security standards, and as long as necessary
for the purposes described in this Policy, unless a longer retention is
required by law. Company has implemented technical, organizational and
administrative systems, policies, and procedures to help ensure the
security, integrity and confidentiality of Personal Information and to
mitigate the risk of unauthorized access to or use of Personal
Information, including: (i) appropriate administrative, technical and
physical safeguards and other security measures designed to ensure the
security and confidentiality of the Personal Information it manages;
(ii) a security design intended to prevent any compromise of its own
information systems, computer networks or data files by unauthorized
Users, viruses or malicious computer programs; (iii) appropriate
internal practices including, but not limited to, encryption of data in
transit; using appropriate firewall and antivirus software; maintaining
these countermeasures, operating systems and other applications with
appropriate reasonable up-to-date virus definitions and security patches
so as to avoid any adverse impact to the Personal Information that it
manages; (iv) appropriate logging and alerts to monitor access controls
and to assure data integrity and confidentiality; and (v) permitting
only authorized users access to systems and applications (together,
“Security Program”). However, Company understands that as effective as
Company’s security measures are, no security system is
impenetrable. Thus, Company cannot guarantee the security of
Company’s database, nor can Company guarantee that information
User supplies will not be intercepted while being transmitted to Company
over the internet.
Company maintains adequate training programs to ensure that its
employees and any others acting on its behalf are aware of and adhere to
its Security Program.
User has the right to withdraw his/her consent at any point, by
contacting Company at contact@getstan.app
. Once consent is withdrawn, Company will be unable to provide User
with the Service.
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Links to Other Sites[c]
This Service may contain links to other sites. If User clicks on a
third-party link, User will be directed to that site. Company strongly
advises User to review the privacy policy of these websites before
proceeding to avail any services or engaging in a transaction with such
third-party websites. Company has no control over and assume no
responsibility for the content, privacy policies, or practices of any
third-party sites or services.
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Children’s Privacy
The Services do not address anyone under the age of 18. Company does
not knowingly collect personally identifiable information from children
under the age of 18. In the event that Company discovers that a child
under the age of 18 has provided Company with Personal Information,
Company shall immediately delete such Personal Information from
Company’s servers. If User is a parent or guardian and User is
aware that User’s child has provided Company with Personal
Information, please contact Company so that Company is able to take
necessary actions.
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Changes to This Privacy Policy
Company may update this Privacy Policy from time to time. Thus, User is
advised to review this page periodically for any changes. Company will
notify User of any changes by posting the new Privacy Policy or
amendments to the Privacy Policy on this page. These changes are
effective immediately after they are posted on this page. User’s
continued use of this Platform, Company’s Services or providing
Company with User’s Personal Information shall signify consent and
acceptance of the terms of the updated Privacy Policy.
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Governing Law
The Privacy Policy shall be governed in accordance with the laws of
Singapore and any disputes arising out of or in connection with the
Privacy Policy shall be subject to exclusive jurisdiction of courts in
Singapore.
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Grievance Redressal Mechanism
In accordance with the Information and Communications Technology Law of
Singapore and its rules thereof, if User faces any grievance with
respect to this Privacy Policy, User may contact Company’s
Grievance Office as provided below:
Name: GETSTAN TECHNOLOGIES PTE LTD
Address: 160 Robinson Road, Singapore
Email: contact@getstan.app
The Grievance Office shall acknowledge receipt of User’s
complaint within 96 hours and shall dispose of the same within days of
receipt.
- Contact
If User has any questions or suggestions about this Privacy Policy,
then contact the Company at contact@getstan.app