This Privacy Policy ("Policy") describes how and when OFFEO collects, uses and shares your information when you use our Services and how we comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) ("PDPA"). In this policy, "personal data" shall have the meaning ascribed to it in the PDPA being (or including) data, whether true or not about and individual who can be identified from that data or from that data and other information to which OFFEO has or is likely to have access. OFFEO receives your information through our various web sites, application programming interfaces, email notifications, ads, commerce services (the "OFFEO Services"), our other covered services that link to this Policy (collectively, the "Services") and from our partners and other third parties. When using any of our Services you consent to the collection, transfer, storage, disclosure, and use of your information as described in this Privacy Policy.

By utilising the services from OFFEO, communicating with OFFEO through email by telephone, in writing or by using any of OFFEO's services, including the OFFEO web site, or by providing personal data to us, you agree to the collection, use and disclosure of your personal data in the manner described in this policy. The data controller responsible for your information is OFFEO Private Limited with its registered office at 29 Media Cir #05-21, Alice@Mediapolis, Singapore 138565. Irrespective of which country you reside in or supply information from, you authorize OFFEO to use your information in Singapore, and any other country OFFEO Private Limited may operate.

If you have any questions or comments about this Privacy Policy, please contact us at[email protected]

1.1 Type of personal data

The type of personal data that OFFEO may collect from individuals will depend upon the particular transaction and the dealing. Typically, the personal data collected by OFFEO may include an individual's:-

(a) name, title, address;

(b) personal identification and/or passport number;

(c) telephone number;

(d) email address and online passwords;

(e) records of communication with OFFEO;

(f) responses to market surveys and contests conducted by OFFEO or on OFFEO's behalf;

(g) credit card or debit card information; and

(h) web site usage information.

1.2 Collection and consent

1.2.1 Broadly, personal data may be collected from you in one or more of the following ways:-

(a) when you order or purchase products of services from us;

(b) when you post a feedback or interact with our customer service officers, eg. via meetings, emails or telephone calls (which may be recorded for training, quality control, business and/or other lawful purposes);

(c) when you use some of our services including establishing any online accounts with us;

(d) when you request that we contact you, be included in an email or other mailing list;

(e) when you respond to our promotions, campaigns or other initiatives to attend our events;

(f) when we receive references from business partners and third parties, for example, where you have been referred by them;

(g) when you visit our web sites;

(h) when you take part in any contest, survey or promotion conducted by us and/or our business partners (including submission of photographs);

(i) when we receive information about you from third party social networking services when you choose to connect with those services;

(j) when you submit your personal data to us for any other reasons; and/or

(k) when we collect your personal data by other lawful means.

1.2.2 Unless permitted by applicable laws, we will not collect personal data without your consent.

1.2.3 You warrant and represent to us that (a) personal data which you disclose to us is accurate and complete; and (b) where you volunteer personal data of another person to us, that you are authorised by such other person to disclose such personal data to us, and that such personal data is accurate and complete.

1.2.4 You shall consult your parent or guardian before giving us your personal data if you are under the age of 18.

1.3 Purposes for which we collect, use and disclose your personal data

1.3.1 Your personal data may be collected, used and/or disclosed for the following purposes:-

(a) to verify and process your personal particulars and payments;

(b) to provide goods and services to you;

(c) to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;

(d) to manage payment, billing, account, credit checks and debt-recovery matters;

(e) to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and that of our group companies;

(f) to manage, develop and improve our business and operations to serve you better;

(g) to carry out marketing promotions and campaigns, contests and lucky draws and personalising your experience at our customer touchpoints;

(h) to carry out market research and customer surveys;

(i) to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;

(j) to comply with legal and regulatory requirements;

(k) to enforce our legal rights and obligations;

(l) to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);

(m) for other purposes for which we have obtained your consent; and

(n) for any other purposes reasonably necessary, ancillary or related to the above specified purposes.

1.3.2 Your personal data may be disclosed for the purposes indicated above to our officers and employees, third parties, affiliates, service providers, advisors which include without limitation, the following persons or entities:-

(a) banks, credit card companies, and payment vendors;

(b) debt collection agencies;

(c) credit information companies;

(d) logistics and courier services companies;

(e) call centre services providers;

(f) our business partners and authorised distributors, dealers or resellers;

(g) relevant government regulators or authorities or law enforcement agencies;

(h) our insurers and advisors, including consultants, auditors and lawyers;

(i) data intermediaries; and

(j) any other party to whom you authorise us to disclose your personal data to.

1.4 Basic Account Information: When you create or reconfigure an account, you provide some personal information, such as your name, username, password, email address or phone number with OFFEO. On the OFFEO Services, your name, username and company name are listed publicly, including on your profile page and in search results, and you can only use your real name.

1.5 Contact Information: You may use your contact information, such as your email address or phone number, to customize your account or enable Services, for example, for login verification. If you provide OFFEO with your phone number, you agree to receive text messages to that number from OFFEO. We may use your contact information to send you information about our Services, to market to you, to help prevent spam, fraud, or abuse, and to help others find your account, including through third-party services and client applications. You may use your settings for email and mobile notifications to control notifications you receive from the OFFEO Services.

1.6 Additional Information: You may provide us with profile information to make public on the OFFEO Services, such as a short biography, your location, your web site, or a picture. You may choose to upload your address book so that we can help you find users you know or help other users find you. We may later make suggestions to you and other users based on imported address book contacts. You can delete your imported address book contacts at any time. If you email us, we may keep your message, email address and contact information to respond to your request. If you connect your account on our Services to your account on another service in order to cross-post between our Services and that service, the other service may send us your registration or profile information on that service and other information that you authorize. This information helps us improve the Services, and is deleted from our Services within a few weeks of your disconnecting from our Services your account on the other service.

1.7 Location Information: OFFEO may receive information about your location. We may also determine location by using other data from your device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device, or your IP address. We may use and store information about your location to provide features of our Services, such as posting with your location, and to improve and customize the Services, for example, with more relevant content like local offers, stories, ads, and suggestions for people to connect with. We may also share your data with other services like Google Maps that will help us to determine your exact location.

1.8 Links: OFFEO may keep track of how you interact with links across our Services, including our email notifications, third-party services, and client applications, by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.

1.9 Cookies: Like many web sites, we use cookies and similar technologies to collect additional web site usage data and to improve our Services, but we do not require cookies for many parts of our Services. A cookie is a small data file that is transferred to your computer or mobile device. OFFEO may use both session cookies and persistent cookies to better understand how you interact with our Services, to monitor aggregate usage by our users and web traffic routing on our Services, and to customize and improve our Services. Most Internet browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the web sites you visit. However, some Services may not function properly if you disable cookies.

1.10 Log Data: When you use our Services, we may receive information such as your IP address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information ("Log Data"). We receive Log Data when you interact with our Services, for example, when you visit our web sites, sign into our Services, interact with our email notifications, or visit a third-party web site. We may also receive Log Data when you click on, view or interact with links on our Services, including links to third-party applications. OFFEO uses Log Data to provide, understand, and improve our Services. If not already done earlier, we will either delete Log Data or remove any common account identifiers, such as your username, full IP address, or email address, after a maximum of 18 months.

1.11 Subscriptions: You may provide your payment information, including your credit or debit card number, card expiration date, CVV code, and billing address (collectively, "Payment Information"), to complete a commerce transaction with our Services. To facilitate future transactions, we store your Payment Information, excluding CVV code, and billing address, which you can remove from your account at any time using your account settings. We consider your Payment Information and billing address private and do not make such information public. We collect and store information created by your subscriptions made with us ("Transaction Data"). OFFEO may also use a third party service to store the credit or debit card data or other data needed for future payments. OFFEO will each time inform about the third party data handler.

2.1 Disclosure: OFFEO discloses personal data (a) for the primary purpose for which it was collected or (b) for purposes that a reasonable person will consider appropriate in the circumstances or (c) where the individual has consented or (d) for direct marketing by OFFEO where consent has been given but giving individuals the opportunity to opt out of such direct marketing or (e) where permitted under the PDPA or other applicable law or if required by law.

2.2 Limits to Disclosure: OFFEO does not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under PDPA or other applicable laws and regulations. OFFEO will not sell or license any personal data that it collects from an individual. When a situation arises where OFFEO may collect and use personal data, which are outside a person's reasonable expectation, OFFEO is committed to providing the individual with an explanation for the possible use of the personal data when asking for the individual's consent.

2.3 Service Providers: We engage service providers to perform functions and provide services to us in Singapore. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions. We share your Payment Information with payment services providers to process payments; prevent, detect and investigate fraud or other prohibited activities; facilitate dispute resolution such as chargebacks or refunds; and for other purposes associated with the acceptance of credit or debit cards. We may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.

2.4 Law: Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect OFFEO’s rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

2.5 Business Transfers and Affiliates: In the event that OFFEO is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your information as transferred to the new entity. We may also disclose information about you to our corporate affiliates in order to help provide, understand, and improve our Services and our affiliates’ services, including the delivery of ads.

2.6 Withdrawal of Consent & Access

2.6.1 You may withdraw your consent to our continued use and disclosure of your personal data or seek access to your Personal data (to a reasonable extent and as permitted by PDPA) at any time by writing to our data controller. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.

2.6.2 In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.

2.6.3 We will, at your request, endeavour to provide you with an account of your Personal data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request.

3.1 If you are a registered user of our Services, we provide you with tools and account settings to access, correct, delete, or modify the personal information you provided to us and associated with your account.

3.2 You can also permanently delete your OFFEO account. If you follow the instructions here or send us a request to[email protected], your account will be deactivated and then deleted. When your account is deactivated, it is not viewable on offeo.com. For up to 30 days after deactivation it is still possible to restore your account if it was accidentally or wrongfully deactivated. Absent a separate arrangement between you and OFFEO to extend your deactivation period, after 30 days, we begin the process of deleting your account from our systems, which can take up to a week.

3.3 Keep in mind that search engines and other third parties may still retain copies of your public information, like your user profile information and public posts, even after you have deleted the information from the OFFEO Services or deactivated your account.

OFFEO will take reasonable steps to ensure that personal data is securely stored. OFFEO protects personal data from misuse of loss by restricting access to the information in electronic format and by appropriate physical and communications security. Any data destroyed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.

If an individual wishes to be provided with information regarding their Personal data that is in the possession or under the control of OFFEO or the ways in which such Personal data has been used or disclosed by OFFEO in the year preceding such request, then that person needs to send a written request by email to us at[email protected]or to the address as detailed below. OFFEO will handle such requests as soon as reasonably possible in accordance with the PDPA.

Your Personal data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal data outside Singapore. We will however ensure that any party to whom we transfer your Personal data outside Singapore provides to such Personal data a standard of protection at least comparable to the protection under the PDPA. This includes without limitation ensuring that any party coming into contact with the Personal data outside Singapore:

(a) complies with the PDPA and accompanying guidelines issued by the relevant regulatory authorities, all applicable laws and regulations and this Privacy Policy ("Data Standards") and shall not do or permit anything to be done which might cause such party or us to breach the Data Standards;

(b) takes all appropriate measures to ensure such compliance by implementing such Data Handling Principles as notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal data that is comparable to the protection under the PDPA; and

(c) protects the Personal data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.

OFFEO complies with all provisions regarding the DNC Registry under the PDPA.

If you are accessing the Site from the European Economic Area, which includes the European Union, Iceland, Liechtenstein, and Norway, or you are a citizen of a member state of the European Economic Area, you have the following rights under the EU General Data Protection Regulation (GDPR).

(a)Right to be informed about the collection and use of your personal data

(b)Right to access your personal data

(c)Right to have any inaccurate personal data corrected

(d)Right to have your personal data erased

(e)Right to restrict use of your personal data

(f)Right to personal data portability

(g)Right to object to the processing of your personal data

If you are from the European Economic Area and wish to exercise any of these rights under the GDPR, please email us at[email protected]. We will use reasonable efforts to respond to any such requests without undue delay.

We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be athttps://offeo.com/privacy-policyuntil our official launch, where the policy can be found athttps://offeo.com/privacy-policy.If we make a change to this policy that, in our sole discretion, is material, we will notify you via email to the email address associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.