Privacy Policy

Straits Interactive is committed to safeguarding the privacy of the users of its websites and its services and products.  Straits Interactive recognises that visitors, users, licensees, members and others (collectively or individually “Users”) who enter, use and/or visit this website and any of our other websites (collectively, including all content available on or through our websites, to be collectively referred to as the “Website”) value their privacy.

This Policy also gives you notice regarding:

(a)  Personal information we collect, how we use it, and with whom we may share it;
(b)  How you can correct any accuracies in your personal information;
(c)  Security procedures we use to protect your personal information from misuse;
(d)  Retention of your personal information;
(e)  Changes to this Privacy Policy; and
(f)  Our relationship with other websites

Personal Data Collected

1.  If you register for an account on our Website, subscribe to our SpiderGate service or transact business with Straits Interactive, your personal information (including but not limited to your name, date of birth, credit card number, job title, company’s name, telephone, fax and mobile numbers, postal and email address) is collected by Straits Interactive and will be used and disclosed only for the purposes for which it was collected. By providing your personal information, you consent to the collection and use or otherwise processing (including disclosure) of your personal information in the manner and for the purposes described in this Privacy Policy.

Use of Personal Data Collected

2.  Straits Interactive will only use your personal information that you provide to us voluntarily for the following purposes:

2.1  to process your application, registration and subscription through the:

(a) Hoiio / SpiderGate Do-Not-Call online and communication services as well as the mobile application provided by our telecom partner Hoiio; and
(b)  Straits Interactive Compliance Dashboard

2.2  to enable you to use Straits Interactive’s SpiderGate products and relevant services through the Hoiio communications platform to make:

(a) phone calls;
(b) mobile / text messaging (including SMS and MMS); and
(c) fax

2.3 administration relating to our training programmes & providing the relevant services
2.4 to notify you of any changes to our policies or services which may affect you;
2.5  to respond to queries or feedback;
2.6  for billing and credit control purposes;
2.7  maintaining and updating your subscription membership details file;
2.8  informing you of new developments, services, promotions of Straits Interactive and third parties which we are associated with; and
2.9  share testimonial from satisfied clients.

3.  Straits Interactive will also use the information which you provide in aggregate form to determine demographic profiles, browsing and transactional patterns in order to:

3.1  develop marketing profiles and assist strategic development;
3.2  manage Straits Interactive’s relationship with its sponsors, advertisers and promotional partners;
3.3  enable site audits to be performed;
3.4  enable Straits Interactive to review, develop and improve the services which it offers; and
3.5  to facilitate media and public relations queries.

Limiting Use, Disclosure and Retention

4.  Note that personal information may be disclosed to third party government related organisation providing funding or grants so as to enable reimbursements.

5.  Straits Interactive will not disclose, share, transfer, sell or rent personally identifiable information of any User to any third party except where Straits Interactive has with the consent of the relevant user, or otherwise to third party service providers who perform services to Straits Interactive such as helping Straits Interactive to operate the Website or process queries by users.

6.  We use cookies on our website to track website visitorship and experience. Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse it.

7.  Straits Interactive would not display or make publicly available, whether through online directories, User lists or otherwise, the personally identifiable information collected. However, Straits Interactive may disclose your personal information if Straits Interactive is required to do so by law or requirement of a competent authority.

8.  Straits Interactive will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites from which you may have linked or been directed to Straits Interactive’s Website.

Role as Data Intermediaries

8.1  According to the Personal Data Protection Act, Straits Interactive and Hoiio are data intermediaries providing the subscribers with the relevant DNC and communication services and therefore will not be subjected to the main obligations except for:

    • Protection of Personal Data
    • Retention of Personal Data

Straits Interactive will take reasonable measures to comply with the above obligations as required by the Act as a data intermediary. The Licensee is advised to ensure its own compliance with the Act.

8.2  Straits Interactive via the SpiderGate Compliance Module shall collect transaction records relating to calls, SMS, faxes made using the Licensed Programs which are only accessible to the Users as well as the Licensee’s data protection officer. Straits Interactive and its partners shall be permitted access and use of such transaction records for the purpose of providing assistance in the event of an Error or Support Request.

8.3  In the event of any claim made against the Licensee or subscriber of a breach of the Act, Straits Interactive and its partners shall be entitled to disclose the subscriber’s transaction records for the purpose of assisting the Personal Data Protection Commission in any investigation.

8.4  When you terminate your Hoiio/SpiderGate account, your personal data will also be deleted or anonymized and will not be retained.

Safeguards

9. Straits Interactive will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason Straits Interactive cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

Checking Your Details

10. If you wish to verify the details you have submitted to Straits Interactive or if you wish to check on the manner in which Straits Interactive uses and processes your personal data, you may do so by contacting us via the contact details in Section 12. Straits Interactive’s security procedures mean that Straits Interactive may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, mobile number and email address. You must therefore keep this information safe as you will be responsible for any action which Straits Interactive takes in response to a request from someone using your membership details. We would strongly recommend that you do not use the browser’s password memory function as that would permit other people using your terminal to access your personal information.

Third Party Sites

11. This Policy only applies to the collection and use of data by Straits Interactive. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Straits Interactive does not share your personal data with these third party websites. Straits Interactive is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any personal data to these websites.

Contacting Us and Opt-Out Information

12. You may contact Straits Interactive at dpo@straitsinteractive.com if you:

(a) have questions or comments about our Privacy Policy;
(b) wish to make corrections to any personal identifiable information you have provided;
(c) want to opt out from receiving future marketing promotions from Straits Interactive and/or third parties which we are associated with. Should you want to opt out, please send a clearly worded email to our Data Protection Officer at the above contact address.

Making Personal Data Public

13. If you send to Straits Interactive contributions containing personal information to be posted on Straits Interactive’s websites, this information will be publicly accessible and is not covered by this Policy.

General

14. Straits Interactive may modify the terms of this Policy or include additional terms to, for example, reflect changes to the law, changes to Straits Interactive’s products and/or services or customer feedback. You should look at these terms regularly. If you do not agree to the modified terms, you should discontinue your use of the Website. If there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

15. These terms govern the relationship between Straits Interactive and you. Straits Interactive does not create any third party beneficiary rights and any law conferring rights on third parties, including the Contract (Rights of Third Parties) Act (Cap. 53B) of Singapore, is hereby excluded.

16. Straits Interactive’s websites do not target and are not intended to attract children under the age of 18 years old. Straits Interactive does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.

Governing Law & Jurisdiction

17. The use of this Website shall be governed by and construed in accordance with the laws of Singapore and we agree to submit to the non-exclusive jurisdiction of the Singapore courts.