This policy (together with our Terms and Conditions of Use (the “Terms”)
and any other documents referred to in it) sets out the basis on which
any personal data (as defined in the Personal Data Protection Act 2012
of Singapore (“PDPA”)) (the “Personal Data”) we collect from corporate
account holders or individual users or visitors to the Hust website and/or
the Hust mobile application (“our Platform”), or that is uploaded to our Platform,
will be processed by us. Account holders, users and visitors of our Platform
or owners of Personal Data collected by us (each, “you”) should read the
following carefully to understand our views and practices regarding your
Personal Data and how we will treat it.
By accepting our Terms or providing any Personal Data to us, you consent
to the collection, use, disclosure and transfer of such Personal Data in
the manner and for the purposes set out below.
Unless otherwise provided, defined terms in this privacy policy shall
have the same meaning as in our Terms.
Information that you provide by filling in forms on our Platform, including
information provided at the time of registering an Account to use our
Platform, subscribing to any services provided by us, posting material,
reporting a problem with our Platform, or requesting further services;
Information, data, documents or images that you upload onto our Platform;
Details of transactions you carry out through our Platform;
Details of your visits to our Platform, resources that you access and
actions you are working on through the Platform (including but not
limited to your clickstreams to, through, and from our Platform,
products you viewed, used, or searched for, page response times,
download errors, length of visits to certain pages, page interaction
information (such as scrolling, clicks, and mouse-overs), or methods
to browse away from the page);
If you contact us, a record of that correspondence; and
Responses to surveys that we send to you, although you do not have to respond to them.
We may also collect and process information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our business partners. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Our Platform uses cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.
The Personal Data that we collect may be transferred to, and stored
at, a destination outside Singapore. It may also be processed by
staff operating outside Singapore who work for us or for one of our
suppliers. Such staff may be engaged in, among other things, the
fulfilment of your services ordered by you, the processing of your
payment details and the provision of support services. By submitting
any Personal Data to us, you agree to this transfer, storing or
processing. We will take all steps reasonably necessary to ensure
that your Personal Data is treated securely and in accordance with
this privacy policy.
All information you provide to us is stored on our secure servers.
Where we have given you (or where you have chosen) a password
which enables you to access certain parts of our Platform,
you are responsible for keeping this password confidential.
We ask you not to share the password with anyone.
Unfortunately, the transmission of information via the internet is
not completely secure. Although we will do our best to protect
your Personal Data, we cannot guarantee the security of your
Personal Data transmitted to our Platform; any transmission
is at your own risk. Once we have received your information,
we will use strict procedures and security features to try to
prevent unauthorised access.
To ensure that content from our Platform is presented in the most
effective manner for you and for your computer;
To provide you with information, products or services that you
request from us, and to otherwise carry out our obligations
arising from any contracts entered into between you and us;
To provide you with information on products or services which
we feel may interest you, where you have consented to be
contacted for such purposes;
To allow you to participate in interactive features of
our service, when you choose to do so;
To investigate any complaints relating to the use of
our Platform or any suspected unlawful activities;
Complying with any applicable laws, regulations, codes of practice,
guidelines, or rules, or to assist in law enforcement and investigations
conducted by any governmental and/or regulatory authority;
Any other purposes for which you have provided the information; and
Carrying out whatever else is reasonable or related to or in connection
with the above and our provision of goods and/or services to you.
For one or more of the Purposes;
For the purposes of providing products or services that you request
from us, fulfilling our obligations arising from any contracts entered
into between you and us, processing payments in connection therewith o
otherwise in connection with your use of our Platform;
Where a third party claims that any content posted or uploaded
by you to our Platform constitutes a violation of their rights
under Singapore law, in which case we may disclose your identity
to that third party;
In the event that we sell or buy any business or assets,
in which case we may disclose your Personal Data to the
prospective seller or buyer of such business or assets;
In the event that it is required for us to provide information
of users of our Platform to obtain funding, investments or grants,
in which case we may disclose your Personal Data to such prospective
investors or grantors;
If we or substantially all of our shares or assets are acquired by
a third party, in which case Personal Data held by us about our
customers will be one of the transferred assets;
If we are under a duty to disclose or share your Data, in order
to comply with any legal obligation (including any direction from
a governmental or regulatory body or law enforcement) or in order
to enforce or apply our Terms; or
In an emergency concerning your health and/or safety for
the purposes of dealing with that emergency.
By providing your Personal Data to us, you consent to the collection,
use and disclosure of your Data by us for the Purposes set out
in this privacy policy.
Where any Personal Data relates to a third party, you represent
and warrant that the Personal Data is up-to-date, complete, and
accurate and that you have obtained the third party’s prior consent
for our collection, use and disclosure of their Personal Data for
the Purposes. You agree that you shall promptly provide us with written
evidence of such consent upon demand by us.
Each use of our services by you shall constitute a fresh agreement
for us to collect, use and disclose the Personal Data in accordance
with this privacy policy.
You may withdraw your consent and request us to stop using and/or
disclosing your Personal Data for any or all of the Purposes by
submitting your request to us in writing to our Data Protection Officer
at [email protected] Should you withdraw your consent to the collection,
use or disclosure of your Personal Data, it may impact our ability to
proceed with your transactions, agreements or interactions with us.
Prior to you exercising your choice to withdraw your consent, we will
inform you of the consequences of the withdrawal of your consent. Please note
that your withdrawal of consent will not prevent us from exercising our
legal rights (including any remedies) or undertaking any steps as we
may be entitled to at law.
The PDPA gives you the right to access your Personal Data. Your right of
access can be exercised in accordance with the PDPA. Any access request
may be subject to a fee of an administrative fee at our rates then in
force to meet our costs in providing you with details of the information
we hold about you.
In the event that you wish to correct and/or update your Personal Data in
our records, you may inform us in writing of the same by sending us an
email to our Data Protection Officer at [email protected] In certain cases,
Personal Data may also be corrected or updated via the Platform.
We will respond to requests regarding access and correction as soon as
reasonably possible. Should we not be able to respond to your request
within thirty (30) days after receiving your request, we will inform you
in writing within thirty (30) days of the time by which we will be able
to respond to your request. If we are unable to provide you with any
Personal Data or to make a correction requested by you, we shall generally
inform you of the reasons why we are unable to do so (except where we are
not required to do so under the PDPA).
We endeavour to ensure that all decisions involving your Personal Data are based upon accurate and timely information. However, we rely on you to disclose all relevant information to us and to inform us of any changes in your Personal Data. As such, please disclose all relevant information necessary for us to provide services to you and ensure all information submitted to us is up-to-date, complete, and accurate. Kindly inform us promptly if there are any changes in your Personal Data.
We may retain your Personal Data for at least five (5) years, or such other longer or shorter period as may be necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
Our Platform may, from time to time, contain links to and from the websites of our partner networks, business partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.
Where we process your Personal Data as a data intermediary on behalf of a third
party, we will process your Personal Data in accordance with the instructions of
the third party and shall use it only for the purposes agreed between you and the
third party. All such Personal Data will be protected and retained in accordance
with this privacy policy and the terms of the PDPA.
We will take steps to inform the third party of any requests, complaints or
questions that you may have regarding such Personal Data.
Any changes we may make to our privacy policy in the future will be posted on our Platform and, where appropriate, notified to you by us.
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to our Data Protection Officer at [email protected]