1.0 GENERAL POLICY
Active8me respects the privacy of individuals. However in response to a legal requirement in an emergency or in exceptional circumstances the Chief Executive Officer may at his or her discretion authorise the release of personal information. In all other circumstances this policy governs the collection, storage, use and disclosure of personal information when you provide it to us whether through the provision of our services, our website (www.active8me.com), mobile sites or mobile applications, and such other features, content or applications (“App”), or otherwise in the course of our normal business operations and to you (collectively, the “Services”).
2.0 COLLECTION & USE OF PERSONAL INFORMATION
2.1 Collection of your personal information
2.2 What personal information about me does Active8me hold, and how it is collected?
2.2.1 Registration process
When you register to become a member of the Services, or when you register your interest to sign up in the future, you will be asked to complete an online form to submit different information about you to us. Such information includes:
- your name;
- your contact details such as your telephone number, physical address and email address
- personal details such as your date of birth, height, weight;
- your username and password
- information that allows us to process your payment to us, such as bank account details and credit card information;
- information about your reason for joining, your goals, your problem areas and your health history;
- names and contact details for nominated accountability partners
- a brief biography about yourself such as your hobbies, interests, occupation and relationship status; and
If you do not provide us with the necessary information, you may not be able to complete the registration and receive the information from us.
If you access the Services through a Third Party Application such as Twitter, Instagram, Linkedin or Facebook, we may automatically collect certain information that could include Personal Information, such as your name, picture, email address and names of your Facebook friends. We will use all information collected in accordance with the Third Party’s policies and your preferences.
2.2.2 Purchases made on our online store
If you make purchases on our online store, then you will be asked to complete an online form as part of the purchase. We may collect information such as:
- your name
- your contact details such as your telephone number and email address
- information that allows us to process your payment to us, such as bank account details and credit card information; and
- your delivery address.
2.2.3 Competitions and promotions
From time to time we may organise and run various competition and promotions for users of the Website. As part of these competitions and promotions, we may ask you to submit other personal information about yourself, such as your height, weight, marital status, age, fitness levels and nutrition details.
You do not have to provide us with your health information, however this means that you may not be eligible to enter some competitions, nor able to receive tailored information specific to your needs.
2.2.4 User submitted content
The Services allow you to post and submit content, including written comments, photographs and images, height, weight, marital status, age, fitness levels, nutrition details and so on. You do not need to post or submit any content, however, if you do, we collect the information that you submit.
All content submitted by you to the Services is User Content and may be retained indefinitely even after you terminate your account. Some User Content you upload can be viewable by the public or by other users of the Services, so we encourage you to consider your privacy settings when providing User Content.
We also collect any other information you provide to us (whether orally, by mail or email or online).
2.3 Use of your personal information
Active8me uses the personal information that it collects to provide our Services to you, to fulfil its legal obligations and to keep its members and licensees informed of Active8me’s activities and the services that it provides to its members and licensees.
Active8me may from time to time send you marketing material that Active8me considers will be useful to you. Active8me may also send you material about its activities. If you do not wish to receive this information, you can let us know and we will not send it to you. This does not apply to information that we are legally required to send, or information regarding the rights of our members.
2.3.1 What does Active8me do with my personal information?
We collect, hold and use your personal information for a number of purposes, as outlined below. In general, we use the information that we collect to:
- assist us in providing goods and services to you;
- contact you or respond to your queries;
- display, update, maintain the content of the Services;
- operate the Services
- conduct marketing research, user profile and statistical analysis;
- tailor your experience of the Services and our communications to you;
- send information about future events, regular email communications or newsletters (both electronic and hardcopy) outlining news, services or events;
- comply with law, the requests of law enforcement and regulatory officials, or orders of court;
- enforce our legal rights and remedies; or
- for such other purposes notified to you on or before collection or use of the data.
2.3.2 Running Competitions and Promotions
If we collect information from you as part of any competitions or promotions, we use the information that we collect in profiling your fitness, displaying the results of competitions, promoting the service and encouraging other members of the Services.
2.3.3 General uses
We may also use the information that we collect from you:
- to advertise our Services and to send you information that complements your use of the Services, including product announcements and fitness news and information. You may unsubscribe from these messages from the unsubscribe link in the emails or from within account preferences. Some emails we send are necessary to the operation of the Service and you may not unsubscribe from receiving them;
- for our internal administrative, marketing and planning requirements;
- to compile and report statistics, with all the relevant personal and/or proprietary information de-identified prior to the completion of such statistics; and
- for purposes that are expressly permitted under any agreement with you.
2.4 Disclosure of your personal information
We generally do not disclose contact information about you publicly or to any third party, except, to:
- external service providers (on a confidential basis and such service providers will be limited in their use of your information to the purpose of Active8me’s activities only);
- any affiliate, subsidiary or partner of ours including Active8me Health POD Pte. Ltd (UEN No. 201701502Z);
- any companies with which Active8me has information exchange agreements including Active8me Health POD Pte. Ltd (UEN No. 201701502Z);
- specialist advisers to Active8me who have been engaged to provide Active8me with legal, administrative, financial, insurance, research, marketing or other services;
- lawyers, auditors, professional advisors or potential investors of Active8me; and
- any other person authorised by you, as specified by you.
Active8me may at other times notify you about its disclosure practices in relation to specific services that it provides in relation to its activities.
We may display personal information about you (including your health information and your profile photograph) on the Services. This is for the purposes of publicly profiling your fitness, displaying the results of competitions, promoting our Services and encouraging other members. If you do not wish this to happen, then you must contact us where directed below.
We will display your user submitted content as part of the Services. The Services may include functionalities that allow you to control whether or not the public or other users of the Services are able to view your user submitted content. We will use reasonable endeavours to implement your selection.
From time to time, we will also disclose your personal information (on a confidential basis) to agents and others that we use in the ordinary operation of our business, such as account and billing, shipping and fulfilment, marketing and promotion, user experience research and surveys, website hosting and support and maintenance. We will only disclose your information to the extent required for the limited purpose of the third party providing services contracted to us so that we may service you.
We may decide to buy or sell assets which form part of or relate to our business. In any such transaction, your personal information may be one of the transferred assets and will be disclosed to the purchaser.
We may disclose your personal information to law enforcement agencies and government for security or any other purposes for legal / regulatory compliance in Singapore or other jurisdictions, where such disclosure is required or permitted.
While we store the majority of the personal information that we collect from you in Singapore, we may from time to time store some of the information in a computer server located elsewhere. We will take such steps as are reasonable in the circumstances to ensure that the overseas recipient is legally bound to provide a standard of protection for your personal information comparable to the protection afforded under the PDPA.
We publish customer testimonials on our Services, in social media profiles, on our Youtube channel and within advertising creative material. These testimonials may contain personally identifiable information. We obtain your written consent to publish any testimonial. If you want your testimonial removed please contact us at firstname.lastname@example.org.
2.6 Manner of collection
We will use reasonable endeavours to only collect information directly from you. If you are disclosing details of another person (for example, a minor on whose behalf you are registering), it is your sole responsibility to ensure that that person understands and consents to the collection, use and disclosure of their personal information in the manner set out in this policy. Further, in disclosing details of the said third-party person, you hereby declare that you are acting in accordance to the PDPA, or any such law as may be applicable, and that the said third-party person has consented to the usage of such information by us.
3.0 INFORMATION COLLECTED BY OUR SERVICES
Active8me may make a record of your visit and log your visit for statistical and business purposes.
3.1 Tracking of user experience
Cookies are small text files that are sent by servers to web browsers and stored on a user’s computer for record-keeping purposes. They tell us which parts of the Services you’ve visited so we can understand user preferences or alert you to software compatibility issues. We link the information we store in cookies to any personally identifiable information you submit while on our Services.
We also use third-party advertising cookies to present you with opportunities to purchase Active8me products from our Services; and retargeting cookies, to present you with Active8me advertising on other websites based on your interaction on our Services and other websites. If you do not wish information to be gathered on a cookie it is possible to opt-out of their use depending on your browser’s settings or you can contact your ISP.
Web beacons and pixel tags are images embedded in a webpage or email for the purpose of measuring and analyzing usage and activity. Active8me, or third party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality.
As is true of most web sites and mobile applications, we and, in some instances, our third party tracking-utility partners gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, pages accessed, documents downloaded, operating system, date/time stamp of your visit, and clickstream data.
We use this information, which does not identify individual users, to analyze trends, to administer the Services, to track users’ movements around the Services and to gather demographic information about our user base as a whole.
3.3 Social Media Features
Our Services offers blogs or community forums that may be publicly accessible (or accessible by other users of the Services). You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
If you send Active8me an email message, or an email to any staff of Active8me, Active8me will record your email address. Active8me will only use your email address for the purpose for which it was provided. Active8me will not use your email address for any other purpose (including adding it to any mailing list), without your express consent.
If this site contains a link to another site, Active8me is not responsible for the privacy practices or the content of such other sites.
3.7 Information provided to Active8me
4.0 MARKETING MATERIAL
We may use your personal information to provide you with material, promotions and communications from time to time about services and products available to you from us, or from other service providers in partnership with us, or to invite you to continue to use our services. This information will only come from us. We will not on-sell your personal information to other providers without your consent.
You may opt out of receiving promotional materials from us at any time by contacting us at firstname.lastname@example.org, or by following the ‘unsubscribe’ link on the relevant promotional emails.
5.0 PROTECTING AND MAINTAINING PERSONAL INFORMATION
We store all of our information using industry-standard techniques. We will take all reasonable steps to protect the information we hold about you from unauthorised access, use and disclosure, however we cannot guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store or that our systems and stored data will be completely free from third party interception or are free from corruption. We also limit the disclosure of personal data both internally and to our agents, contractors, Third Party Service Providers and other third parties to a need-to-know basis. We require all third parties to respect the security of your personal data and to treat it in accordance with the law and in accordance with their own privacy policies.
Certain parts of the Services (such as those parts that require you to provide us with your credit card number) provides the ability for you to transmit information to our Services in an encrypted form by using secure socket layer technology (SSL). However, other parts of the Services are not protected by any form of encryption to protect information you send from your computer to us over the Internet. Further, no method of transmission over the Internet, or method of electronic storage, is 100% secure. In light of this, we cannot ensure or warrant, and do not warrant, the security or privacy of your personal information, including payment and account details. You transmit this information at your own risk. . If you have any questions regarding security you can contact us at email@example.com.
You are solely responsible for maintaining the security of your passwords and/or any account information. You need to prevent unauthorised access to your account by selecting and protecting your password appropriately and limiting access to your computer, browser and/or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of your account at any time.
We will destroy or de-identify your personal information when it is no longer needed or required to be kept by law or to provide services to you, subject to the paragraph below. Please note that, as you may continue to have access to your account after your service subscription expires, we will continue to retain your personal information on the Services so that you may access it.
Should you ever decide to delete your Account, you may do so by emailing firstname.lastname@example.org. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any activity and data (whether or not it is public) on your Account prior to deletion will remain stored on our servers and, where applicable, will remain accessible to the public. We will also preserve the content of any email or information you submit if we believe we have a legal requirement to do so, or if any form of email abuse is suspected.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6.0 ACCESSING PERSONAL INFORMATION
Subject to the exceptions referred to in section 21 of the PDPA, you have the right to request access to a copy of your personal data which we hold about you or information about the ways in which we use or disclose your personal data.
You also have the right to request for the correction or update of any personal data of yours which we hold. We generally rely on personal data provided by you. We want to ensure that your personal data is current, complete and accurate. Please update us if there are changes to your personal data.
It is your responsibility to advise us of any changes to your personal details to ensure we can keep our records accurate and up to date. If you wish to access the information we hold about you, please submit a request to email@example.com or by logging into your account and making the appropriate changes. If you believe that the personal information we hold about you is incorrect, you are entitled to request amendment of such information. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it. You may also request that we delete the personal information that we hold about you. Please note that if we delete your contact information, we may not be able to provide you with the subscribed service.
If you request us not to use personal information in a particular manner or at all, we will adopt reasonable measures to observe your request but we may, to the extent permitted by law, still use or disclose your information if you subsequently consent to the disclosure or we believe the use or disclosure is reasonably necessary to assist a law enforcement agency or as otherwise required or authorised by law. If you know the information we hold about you is not accurate or complete, please notify us. We will respond to your request as soon as reasonably possible or practicable. 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 receiving 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 may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also need to verify the accuracy of any new data you provide us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if (a) your request unreasonably interferes with our operations due to its repetitious or systematic nature; (b) the burden or expense of providing access would be unreasonable to us or disproportionate to your interests; (c) the information is does not exist, cannot be found, or is trivial; or (d) your request is otherwise frivolous or vexatious. Alternatively, we may refuse your request in these circumstances.
7.0 PRIVACY CONCERNS
If you have any concerns about how we handle your personal information or require further information, please send us a detailed message to firstname.lastname@example.org. We will make every effort to resolve your concerns.
We are not responsible for resolving or intervening in any dispute over Your Data.
You are solely responsible for resolving disputes regarding ownership or access to Your Data, including those involving any current or former owners, co-owners, employees or contractors of your business. You acknowledge and agree that Active8me has no obligation whatsoever to resolve or intervene in such disputes.
We cannot distinguish the age of persons who access and use our websites. We do not knowingly collect or solicit personal data from those below the age of 18, or knowingly allow such persons to register an account with us or use our Services. If you are under 18, please do not use our Services, or attempt to register an Account or send any personal data about yourself to us.
9.0 CHANGES TO THIS POLICY
This document represents our policy as at 3rd February, 2019. Active8me reserves the right to amend this policy at any time and from time to time, and the policy will be published on Active8me’s Services. Although we intend to observe this policy at all times, it is not legally binding on us in any way. From time to time we may regard it as necessary or desirable to act outside the policy. We may do so, subject only to any statutory rights you have under the PDPA or other applicable legislation. We encourage you to regularly review this statement to inform yourself of any amendments.
10.0 GOVERNING LAW
Copyright, last updated on 24th April, 2020
Active8me Pte Ltd (UEN No.: 201530491Z).
All rights reserved.