2. PersonalInformation which we collect
3. The useof Personal Information which we collect
4. Sharingof Personal Information which we collect
5. Cross-bordertransfers of Personal Information
6. Retentionof Personal Information
7. Accessand correction of Personal Information
8. Where westore your Personal Information
9. Securityof your Personal Information
12. Acknowledgementand consent
13. Marketingand promotional material
14. Thirdparty websites
15. Limitationof Liability
16. How tocontact us
2. PERSONAL INFORMATION WHICH WE COLLECT
Wecollect certain Personal Information about you. The Personal Information whichwe collect may be provided by you directly (for example, when you opening anAccount to use the Service via the System, or you otherwise provide PersonalInformation to us) or by third parties, or be collected automatically when youuse the App and visit our Website. We may collect information in various formsand for various purposes (including purposes permitted under Applicable Law).
Informationobtained from you, from your Mobile Device or from your PC directly:
● When youregister and create an Account with us using the App or the Website, you haveto provide to us certain Personal Information, including your name, photo,physical address, e-mail address, your phone number, an Account ID and/orpassword that you will use to access the Account after registration and yourGoogle and Facebook account information.
● When youuse the App or the Website, you have to provide to us suchrelevant information as may reasonably be required by us in order for theApp or the Website to work. For example, when a payment is made through theelectronic money facility within the App, you will provide to us informationrelating to the payment, such as the type of payment card or mobile walletaccount used, the name of the issuer of that payment card or mobile walletaccount, the name of the account holder for that payment card or mobile walletaccount, the number of that payment card or mobile wallet account, and theamount of money paid.
● When youuse the App or the Website, in order to post an Announcement, chat with otherUsers, or leave a comment below certain User content, you have to provide to ussuch relevant information, which might include Personal information. Forexample, when you post an User Content about the real estate you or the thirdparty(in this case, you need to be legally authorized by that third party)intend to let or sell, you need to provide us information relating to the realestate, such as the real estate's address, your name, your personal ID, theauthorization Letter, the real estate owner's name, the certificate, the amountof the rent or house price.
● Sometimesyou may also need to provide to us additional information in the communicationwith our support team in order to fulfill your request (for example, if youraccount was previously blocked, we may ask you to confirm your identity byproviding an ID document).
Informationcollected whenever you use the App or visit our Website:
● Wheneveryou use the App or visit our Website, we may collect certain technical dataconcerning your usage such as, URL (i.e., the place on the Web where you were whenyou tapped on our advertisement), internet protocol (IP) address, informationas webpages previously or subsequently viewed, duration of every visit/session,the internet device identity (ID) or media access control address, and alsoinformation regarding the manufacturer, model and operating system of thedevice that you use to access the App or our Website. We also record how youinteract with our Service. For example, we log the features, and content youinteract with, how often you use the Service, how long you are on the Service,what sections you use, what columns you browse, how many advertisement youwatch.
● Wheneveryou use the App through your Mobile Device, we will track and collect yourgeo-location information in real-time. In some cases, you will be prompted orrequired to activate the Global Positioning System (GPS) on your Mobile Deviceto enable us to give you a better experience in using the App.
● Meanwhile,your will be required to provide technical information to us while using theApp, including the type of Mobile Device you use, a unique device identifier(for example, your mobile device's IMEI number, the MAC address of your MobileDevice's wireless network interface, or the mobile phone number used by yourMobile Device), mobile network information, your mobile operating system, thetype of mobile browser you use, time zone setting, language settings, devicesettings, internet service provider, mobile carrier, hardware ID, Facebook IDand Google ID. We will also collect information stored on your Mobile Device,including contact lists, call logs, SMS logs, Facebook friends, contact listsfrom other social media accounts, photos, videos or other digital content.
● Wecollect your geo-location information when the App is running in theforeground. We endeavour to cease collection of your geo-location informationwhen the App is in the background, but such information may still be collectedunintentionally. You can always choose to disable the geo-location trackinginformation on your Mobile Device temporarily. However, this may affect thefunctionalities available on the App.
Informationcollected from third parties:
Informationabout third parties you provide to us:
● You mayprovide us with Personal Information relating to other third party individuals(such as Personal Information relating to your spouse, family members, andfriends).
● You may provide us with other third party’sPersonal Information in the case that you post an Announcement in the Systemwhere you are legally authorized by that third party with documentationaccepted by us.
Undersuch circumstances, you will of course need their consent to do so–see Section12“Acknowledgement and Consent”, below, for further information.
Informationcollected from Collecting Content:
3. THE USE OF PERSONAL INFORMATION WHICH WE HAVE COLLECTED
We mayuse Personal Information collected for any of the following purposes as well asfor such other purposes as are permitted by Applicable Law:
a. We mayuse your Personal Information:
● toidentify you and to register you as a User and to administer, manage or verifyyour Account as such;
● tofacilitate or enable any checks as we may in our discretion consider necessarybefore we register you as a user;
● to provide you our Service, which enabling youto use the Service in a seamless manner and preventing or addressing Serviceerrors or technical issues;
● to manage your account and provide you withcustomer support, we process your Personal Information to respond to yourrequests for technical support, Service information or to any othercommunication you initiate, including accessing your account to addresstechnical support requests. For this purpose, we may send you, for example,notifications or emails about the performance of our Service, security, paymenttransactions, notices regarding our Terms and Conditions of Use or this PrivacyPolicy;
● to communicate with you and to send youinformation in connection with the use of the App and our Website, for example,by push notifications or in the chat. As a result, you may, for example,receive a notification whether on the Website or via email that you received anew message on KwickMe;
● tonotify you of any updates to the App or changes to the Service available;
● toprocess and respond to enquiries and feedback received from you;
● tomaintain, develop, test, enhance and personalise the App and the Website tomeet your needs and preferences as a User;
● tomonitor and analyse user activities and demographic data including trends andusage of the Service available on the App; and
● to sendyou direct marketing communications and information on special offers orpromotions (if any).
b. We mayalso use your Personal Information more generally for the following purposes(although we will in each such case always act reasonably and use no morePersonal Information than what is required for the particular purpose):
● toundertake associated business processes and functions;
● tomonitor usage of the App and administer, support and improve the performanceefficiency, user experience and the functions of the App and the Website;
● toprovide assistance in relation to and to resolve any technical difficulties oroperational problems with the App and the Website;
● togenerate statistical information and anonymous analytics data for the purposeof testing, research, analysis and product development;
● toprevent, detect and investigate any prohibited, illegal, unauthorised orfraudulent activities;
● tofacilitate business asset transactions (which may extend to any mergers,acquisitions or asset sales) involving us and/or any of our Affiliates; and
● toenable us to comply with our obligations under any Applicable Law (includingbut not limited to responding to regulatory enquiries, investigations ordirectives) and conducting audit checks, due diligence and investigations.
4. SHARING OF PERSONAL INFORMATION WHICH WE COLLECT
a. We maydisclose to or share with Affiliates and other parties your PersonalInformation for any of the following purposes as well as for such otherpurposes as are permitted by Applicable Law (although we will in each such casealways act reasonably and disclose or share no more Personal Information thanwhat is required for the particular purpose):
● whererequired or authorized by Applicable Law (including but not limited toresponding to regulatory enquiries, investigations or directives, or complyingwith statutory or regulatory filing and reporting requirements), for thepurpose so specified in that Applicable Law;
● wherethere is any form of legal proceeding between you and us, or between you andanother party, in connection with, or relating to the Service, for the purposesof that legal proceeding;
● inconnection with, or during negotiations of, any merger, sale of company assets,consolidation or restructuring, financing or acquisition of all or a portion ofour business by or into another company, for the purposes of such a transaction(even if the transaction is eventually not proceeded with);
● where weshare your Personal Information with third parties (including our agents,vendors, suppliers, contractors, partners, and any others who provide servicesto us, perform functions on our behalf,or whom we collaborate with), for or inconnection with the purposes for which such third parties are engaged or thepurposes of our collaboration with such third parties (as the case may be),which may include allowing such third parties to introduce or offer products orservices to you, or other conducting activities including marketing, salesleads acquiring, research, analysis and product development;
● where we publish statistics relating to the useof the App and the Service, in which case all information will be aggregatedand made anonymous; and
b. Where itis not necessary for the Personal Information disclosed or shared with otherparties to be associated with you, we will use reasonable endeavours to removethe means by which the Personal Information can be associated with you as anindividual before disclosing or sharing such information.
5. CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION
YourPersonal Information may be transferred to, stored, used and processed in ajurisdiction other than your home nation or otherwise in the country, state andcity in which you are present while using any Service provided by us (“AlternateCountry”), to companies under our group which are located outside of your homenation or Alternate Country and/or where our group’s servers and/or serviceproviders and partners are located outside of your home nation or AlternateCountry. You understand and consent to the transfer of your PersonalInformation out of your home nation or Alternate Country as described herein.
6. RETENTION OF PERSONAL INFORMATION
a. YourPersonal Information will only be held for as long as it is necessary tofulfill the purpose for which it was collected, or for as long as suchretention is required or authorized by Applicable Law. We shall cease to retainPersonal Information, or remove the means by which the Personal Information canbe associated with you as an individual, as soon as it is reasonable to assumethat the purpose for which that Personal Information was collected is no longerbeing served by retention of Personal Information and retention is no longernecessary for legal or business purposes.
b. Pleasenote that there is still the possibility that some of your Personal Informationmight be retained by the other party (i.e., the User who provides goods orservice to you or any User who browses your Personal Information provided byyou via your Announcement), such as transaction information. Informationrelayed through communications between Users and you made other than throughthe use the Application (such as by telephone, mobile messaging or other modesof communication) may also be retained by some means. We do not authorize theretention of Personal Information by such means and we have no responsibilityto you for the same. To the fullest extent permitted by Applicable Law, weshall not be liable for any such retention of your Personal Information. Youagree to indemnify, defend and release us, our officers, directors, employees,agents, suppliers, contractors and Affiliates from and against any and allclaims, losses, liabilities, expenses, damages and costs (including but notlimited to legal costs and expenses on a full indemnity basis) resultingdirectly or indirectly from any unauthorized retention of your PersonalInformation.
7. ACCESS AND CORRECTION OF PERSONAL INFORMATION
a. You mayrequest us for access to and/or the correction of your Personal Information inour possession and control, by contacting us at the details provided below.Subject to Applicable Law, we reserve the right to charge an administrative feefor such requests.
b. Wereserve the right to refuse your requests for access to or to correct some orall of your Personal Information in our possession or control, if permitted orrequired under any Applicable Law. This may include circumstances where thePersonal Information may contain references to other individuals or where therequest for access or request to correct is for reasons which we reasonablyconsider to be trivial, frivolous or vexatious.
8. WHERE WE STORE YOUR PERSONAL INFORMATION
a. ThePersonal Information that we collect from you may be stored at, transferred to,or processed by third party service providers. We will use all reasonableendeavours to ensure that all such third party service providers provide alevel of protection that is comparable to our commitments under this PrivacyPolicy.
9. SECURITY OF YOUR PERSONAL INFORMATION
Confidentialityof your Personal Information is of utmost importance to us. We will use allreasonable efforts to protect and secure your Personal Information againstaccess, collection, use or disclosure by unauthorized persons and againstunlawful processing, accidental loss, destruction and damage or similar risks.Unfortunately, the transmission of information via the Internet is not completelysecure. Although we will do our best to protect your Personal Information, youacknowledge that we cannot guarantee the integrity and accuracy of any PersonalInformation which you transmit over the internet, nor guarantee that suchPersonal Information would not be intercepted, accessed, disclosed, altered ordestroyed by unauthorized third parties, due to factors beyond our control. Youare responsible for keeping your Account details confidential and you must notshare your password with anyone and you must always maintain the security ofthe Mobile Device and PC that you use.
12. ACKNOWLEDGEMENT AND CONSENT
b. Incircumstances where you provide us with Personal Information relating to otherindividuals (such as Personal Information relating to your spouse, familymembers, friends or any third party who authorizes you to do so), you representand warrant that you have obtained such individual’s consent for, and herebyconsent on behalf of such individual to, the collection, use, disclosure andprocessing of his/her Personal Information by us.
c. You maywithdraw your consent to any or all collection, use or disclosure of yourPersonal Information at any time by giving us reasonable notice in writingusing the contact details stated below. You may also withdraw your consent forus to send you certain communications and information via any “opt-out” or “unsubscribe”facility contained in our messages to you. Depending on the circumstances andthe nature of the consent which you are withdrawing, you must understand andacknowledge that after such withdrawal of consent, you may no longer be able touse the App, the Website or any part of the Service. A withdrawal of consent byyou may result in the termination of your Account or of your contractualrelationship with us, with all accrued rights and obligations remaining fullyreserved. Upon receipt of your notice to withdraw consent for any collection,use or disclosure of your Personal Information, we will inform you of thelikely consequences of such withdrawal so that you can decide if indeed youwish to withdraw consent.
d. You mayalso request us for erasure of your Personal Information in our possession andcontrol, by contacting us at the details provided below. When you requestdeletion of your Personal Information, we will use reasonable efforts to honoryour request. The erasure of your Personal Information may in thetermination of your Account or of your contractual relationship with us, withall accrued rights and obligations remaining fully reserved. Upon receipt ofyour notice to erasure of your Personal Information, we will inform you of thelikely consequences of such withdrawal. In some cases, we may be legallyrequired to keep some of the data for a certain time; in such event, we willfulfill your request after we have complied with our obligations.
13. MARKETING AND PROMOTIONAL MATERIAL
a. We maysend you marketing and promotional communications via post, telephone call,short message service (SMS), e-mail, online messaging, or push notificationsvia the App to notify you about special privileges, promotions, or eventsoffered or organised by us, our partners, sponsors, or advertisers, or toprovide updates on our App and/or the products and services offered therein.
b. You mayopt out from receiving such marketing communications at any time by clicking onany “unsubscribe” facility embedded in the relevant message, or otherwisecontacting us using the contact details stated below. Please note that if youopt out, we may still send you non-promotional messages, such as Loandisbursement or repayment receipts, or information about your Account or theApp.
14. THIRD PARTY WEBSITES
a. The Appand Website may contain links to websites that are operated by third parties.We do not control nor accept liability or responsibility for these websites andfor the collection, use, maintenance, sharing, or disclosure of data andinformation by such third parties. Please consult the terms and conditions andprivacy policies of those third party websites to find out how they collect anduse your Personal Information.
15. LIMITATION OF LIABILITY
We shallnot be liable for any indirect, incidental, consequential, special, exemplaryor punitive damages arising out of:
a. Your useof or reliance on the System or Service, or your inability to access or use theSystem or Service; or
b. Anytransaction or relationship between you and any other third party, even if wehave been advised of the possibility of such damages.
We shallnot be liable for delay or failure in performance resulting from causes beyondour reasonable control.
16. HOW TO CONTACT US
If youhave any questions regar