Last updated: November 5, 2021

We, DTGC Pte. Ltd., and our affiliates (collectively such entities will be referred to as, “we” or “us”) respect the data of our users (referred to as “you”) and take responsibility for protecting your information provided to us during using our Services. By this Privacy Policy (referred to as “Policy”), we intend to inform you:

  1. This Policy does not apply to services provided by other third parties, nor to products and services with a separate privacy policy provided by us.
  2. This Policy explains the data protection practices adopted by us and should be read in conjunction with our Terms and Conditions (“T&Cs”). Please read and understand this Policy carefully before using our Services. When you use our Services, you agree to be bound by these terms and conditions. If you have any inquiries or suggestions regarding the Policy, you are free to contact us through any means made available to you.
  3. This Policy applies to any individuals who use our websites, apps, events, and other services operated by us (“Services”). Users agree to be bound by the terms and conditions of this Policy and the T&Cs and consent to inter alia, our collection, use, processing, and disclosure of personal information provided by yourselves by this Policy.
  4. We reserve the right, at our discretion, to amend this Policy over time and modify content within the Services. The new version of the Policy will be accessible on the Website and Software and you are requested to review the same. If you continue to use the Services after the changes are posted, it is deemed that you agree with and acknowledge the changes or revisions, and the new Policy shall apply to your continued use of the Services. Otherwise, if you do not agree to the terms of the Policy or any future updated version of the Policy, then you must not access or use, and must cease all access and use of any of our Services.

 This Hekka Data Privacy Policy will help you understand the following:

Table of Contents

  1. How we collect information

    To provide Services, we must process information about you. Please note that information is collected from you only for lawful purposes and necessary conditions. You have the option not to provide any data or info sought to be collected and in such cases, you may not consent to this Policy. Correspondingly, we have the right not to provide the Services as far as you are concerned. We collect information in the following ways:


    1.1 Information and content you provide

    (a) We collect profiles, messages, and other info you provided when you use our Services, including when you register for an account, create or share content or communicate with other users. This may include further info in or about the content you provided, such as metadata, the location of a photo, or the date a file was created. With your consent, we will also collect contact information you choose to upload, sync, or import from your device to the Services offered by us.

    (a) Your usage. We collect info generated as you use our Services as well as info from third parties (like when you access our Services through a social media account), such as your mobile phone number and password; the types of content you view or engage with; the features you use; the actions you take; the time, frequency and duration of your activities; and your feedback, for example, the access logs, photos, and videos you viewed while using our Services.

    (b) Device information. We collect and record information regarding and from the devices you used according to access you have granted when installing and using our Services. We will strictly abide by the rules and regulations for data collection to respect and protect your rights and interests. Information we obtain from these devices may include:

       (i) Device attributes: information such as the operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, app and file names, and types, and plugins.

       (ii) Device operations: information about operations and behaviors performed on the devices, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).

       (iii) Device identifiers: device IDs obtained from apps or accounts you use.

       (iv) Device signals: bluetooth signals, information about nearby Wi-Fi access points, beacons, or cell towers.

       (v) Data from device settings: information you allowed us to receive through device settings you activated, such as access to your GPS location, camera, or photos.

       (vi) Network and connections: information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed, and, in some cases, information about other devices that are nearby or on your network.

       (vii) Cookie data: data from cookies stored on your device, including cookie IDs and settings.

    1.3 Information our partners provide

    You can use products or services through links on your account provided by our affiliates, advertisers, and app developers. By using the above Services, you grant us permission to receive, gather and analyze personal and transactional info from our affiliates, advertisers, and app developers under your express consent provided to these entities while using their services.

    Advertisers, app developers, and publishers (like Adjust, Facebook, Google, etc.) can send us information via tools they use, including but not limited to APIs and SDKs. Your use of our Services is subject to the privacy policy of these entities and we request you to read and understand the privacy policy of these service providers before using our Services. These partners provide information about your activities while you use our Services, including info about websites you visit, purchases you make, advertisements you see, and other relevant data, no matter whether you have an account for our Services or not. We also receive info about your online and offline actions from third parties who have the right to provide us with your information so far as you may have provided consent in this regard.

    We require each of these partners to have your consent and lawful rights to collect, use and share your data before providing any data to us.

    1. How we use information

    We use the information to provide and support the Services and the information will be processed only for the purposes set out in this Policy. Please refer to the following on how we use this information:

    2.1 To provide and optimize our Services

    We use the information made available to us to deliver, develop, test, and improve our Services, including but without limitation to develop research, test, and troubleshoot new Services and features.

    2.2 To display and promote products or Services

    To better provide you with personalized browsing and transaction Services, we will display and push info such as ads according to your browsing and search record, device information, search preference, behaviors, and habits, and location.

    2.3 To enhance safety, integrity, and security

    We process the info we obtained to verify accounts and activities, combat harmful conduct, detect and prevent spam and other bad experiences to maintain the integrity of our Services and enhance your safety and data security.

    2.4 To communicate with you

    We use the info we obtained to send you marketing messages, communicate with you about our Services, and allow you to understand our policies and terms. We also use your info to effectively respond when you contact us.

    2.5 Others

    If we use the info we obtained for some other purposes not listed in this Policy, we will promptly inform you and seek your prior permission.

    1. Cookies and other similar data collection technologies

    3.1 Cookies

    To ensure proper operations of the Services and to provide you with personalized and better user experience, we will recommend meaningful connections. We will collect information from your mobile devices, and store information such as your preference in data folders through the usage of cookies (“Cookies”). In essence, Cookies allow us to serve you better and more efficiently. You can control how and whether Cookies are utilized by changing the options on your device or using functionalities available to you. However, blocking cookies related to our Services may disable certain features of our Services and may otherwise hinder seamless and excellent user experience.

    3.2 Other Similar Technologies

    In addition to cookies, we may also use other similar data collection technologies such as web beacon and pixel tags. For example, when you click the link sent by us through email, we can track this click and your preferences and thus optimize our customer service experience. A web beacon is usually a transparent image that is embedded within a website or email. With pixel tag, we can know whether the mail has been opened in the webmail. If you do not wish to be tracked through the above means, you can unsubscribe from our mail list anytime.

    3.2.1 Rakuten Advertising

    Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.

    Privacy policy : https://rakutenadvertising.com/legal-notices/services-privacy-policy/
    Your rights : https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/

     

    1. How the information is shared

    With your prior permission i.e. acceptance of this Policy, we will share or allow third parties to collect your information from our Services under the following circumstances and shall also contractually obligate such parties not to share your information with any other party.

    We may share your information according to Laws and Regulations, dispute resolution and litigation purposes, or legal requests from administrative agencies and judiciary institutions. We will share your information when necessary to achieve the following actions: to detect, prevent and address fraud, violations of our terms or policies, or other harmful or illegal activities; to protect ourselves (our rights, property, or Services), you or others (individuals involved in investigations or regulatory inquiries); or to prevent death or imminent harm.

    4.2 Sharing with affiliates

    We may share your information with our affiliates to provide you with better Services (recommending information tailored to your interest) or to protect the assets of other users and the public.

    4.3 Change of ownership

    We may transfer your information to the new owner, controller, or acquirer when merger, acquisition, or bankruptcy liquidation occurs.

    4.4 Sharing with third-party Partners

    We work with third-party partners who help us to provide and improve our Services to offer you high-quality services. The following are the types of third parties we share information with:

    (a) Partners who use our analytics services

    We provide aggregated statistics and insights that help to understand how users engage with our Services.

    (b) Measurement agencies

    We share information about you with agencies that aggregate it to provide analytics and measurement reports to our partners.

    (c) Other partners such as vendors and service providers

    We provide information and content to vendors and service providers, such as those who provide technical services, analyze how our Services are used, offer customer service, facilitate payments and conduct surveys, etc.

    1. How we protect your information

    We endeavor to protect you from unauthorized access or alteration, disclosure, or destruction of your information through responsible and feasible security measures that are universal within the industry. We have implemented reasonable security practices and documented information security policies that comprise all relevant security control measures that are commensurate with the protection of the information assets (including your data). However, despite our commercially reasonable efforts to safeguard your information, it is difficult and impossible for any entity to promise complete security to your data. If you deem that your account or information is no longer secure, please notify us (by section 11 below) immediately and we will take necessary actions as expeditiously as possible.

    You must be careful before uploading text, images, and others when engaging in our Services since your voluntarily or publicly sharing of information may involve personal data about you or others.

    1. How you manage your information

    You can access and manage your information via the following means:

    Unless required otherwise by Laws and Regulations, you reserve the right to access, rectify, add and erase your personal information. After deleting information on our Software, the corresponding information will be removed or anonymized with the backup system update if unable to be removed immediately.

    You can also modify the scope of your authorization. We will no longer process your information upon your withdrawn access. Please note that your decision does not affect the prior information displayed and processed. Please be aware that functions of our Services may require certain data to operate and thus modifying your scope of authorization may lead to the inability to use our Services.

    1. Rights of users to request access to and update information

    You may access your personal information by sending a request to our Grievance Officer. You may also seek to correct your inaccurate or deficient personal information or delete such information. You may withdraw your consent to provide any or all information or decline to provide the same as may be required from time to time. Whereas you choose to do so then your access to the Services may be limited, or we might not be able to provide the Services to you.

    1. How do we protect the information of underage users

    OUR SERVICES ARE NOT DIRECTED AT CHILDREN UNDER THE AGE OF 18. IF WE FIND THAT PERSONAL INFORMATION HAS BEEN COLLECTED FROM PEOPLE UNDER THE AGE OF 18, WE WILL DELETE THAT INFORMATION AND TERMINATE THAT PERSON'S ACCOUNT. IF THE LAW OF THE USER'S RESIDENTIAL AREA HAS SPECIAL PROVISIONS FOR USERS OVER THE AGE OF 18 TO USE THE PLATFORM AND FOR THE PLATFORM TO COLLECT THE PERSONAL INFORMATION OF USERS OVER THE AGE OF 18, WE WILL COMPLY WITH THE PROVISIONS OF THE LOCAL LAW. IF YOU THINK WE COLLECT INFORMATION ABOUT CHILDREN UNDER THE AGE OF 18 OR THAT IS PROHIBITED BY LOCAL LAW, PLEASE CONTACT US IMMEDIATELY.

    1. How we operate and transfer data as part of our global services

    As part of our international operations, we transfer, transmit, store or process your information globally to our affiliates or business partners under the guidance of local Laws and Regulations as well as by this Policy. You acknowledge and agree that, to the extent permissible under applicable Laws and Regulations, we may transfer or disclose your information to any other entities within or outside your country of residence for providing Services to you. In such cases, we place contractual obligations on the recipients to ensure that your information is not disclosed, shared, or transferred further to any other parties. Moreover, we contractually oblige the recipients to take protective measures of the same level as that adhered to your data by us under the reasonable security practices set out in section 5.

    1. Data retention

    We generally retain your data for as long as we need it for the performance of our Services and to comply with our legal obligations.

    We may keep it to evidence our compliance with applicable Laws and Regulations; there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved, or the information must be kept for our legitimate business interests. However, even though our systems are designed to carry out data deletion inquiries and processes, we cannot promise that all data will be deleted within a specific time frame due to technical constraints and legitimate reasons.

    1. How to contact us

    If you have any questions or grievances within this Hekka Data Privacy Policy relating to the processing of your information, or you would like to exercise any of your rights, please do not hesitate to reach out to our Grievance Officer whose contact details are set out below. We endeavor to redress all grievances received on an expeditious basis.

    You can contact our Grievance Officer via online customer service or email: [customerservices@hekka.com].