- At-Counter – Our Privacy Policy
1.1 This Privacy Policy explains how we collect, use, share and store personal data relating to the Services.
1.2. Personal data (“Information”) in this Privacy Policy refers to data that can be used to identify an individual.
1.3. By using the Services, as a User you consent to our collection, use, sharing and storing of Information in accordance with this Privacy Policy. In particular, you understand and agree that the Information which we collect from you is necessary for us to provide the Services.
1.4. Unless otherwise stated, the capitalised terms in this Privacy Policy are used in the same way as used in our Terms of Use.
1.5. Our Privacy Policy applies to all visitors, Users and others who access the Services.
1.6. This Privacy Policy contains the following sections:
Information we collect
How we use your Information
Sharing your Information
How we store your Information
Children’s Privacy
Other Websites
Contacting us about your Information
Changes to this Privacy Policy
- Information we collect
A. The following is Information which you provide to us directly:
2.1. Registration Information
2.1.1. When you register an Account on the Services, we may collect Information which we ask you to provide, such as your name, password, email address, and Social Network ID (if you have signed up using a social network account (e.g. Facebook or Google)). Such Information must be provided in order to register an Account.
2.1.2. Once your Account has been registered, your name, username and profile picture (if you have signed up using your Social Network ID) will automatically be displayed on your profile page and will be available to other Users through the Services. This allows other Users to identify you, find you, and refer to you properly.
2.2. Profile Information
2.2.1. In addition to your name and username, which are automatically displayed on your profile page, you may voluntarily provide Information on your profile page such as your profile picture (if not already available via your sign up using your Social Network ID), date of birth, gender, location and other information about yourself and your interests.
2.2.2. Any such Information which you add to your profile page (except for date of birth and gender) on the Services becomes publicly available. Please exercise personal discretion in how much Information you choose to share.
2.3. Content which you upload to the Services, which allows others to identify you (e.g. photos of you, audio recordings or text containing your name, status updates, comments on Content which refer to you).
2.4. Communications between you and us (e.g. your reply to our service updates, emails to you, and support tickets).
B. The following is Information which other Users provide about you:
2.5. Content which others upload to the Services which allows you to be identified (e.g. photos of you, audio recordings or text containing your name, status updates, comments on Content which refer to you).
C. Other Information which we receive when running the Services:
2.6. Analytics Information
2.6.1. We use third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by your device including the web pages you visit, add-ons, and other information that assists us in improving the Services. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
2.7. Cookies and similar technologies
2.7.1. The Services may contain “cookies”, clear gifs (also known as “web beacons” or “web bugs”), or similar technology. A cookie is a piece of data that is sent to your Internet browser, which will store the cookie on your computer if your browser is enabled to accept cookies. Web beacons assist in the delivery of cookies and the collection of non-personally identifiable information, such as “click path” and other data as described above.
2.7.2. The Services use cookies, clear gifs, frames, server log analysis and other technologies as they are developed to customise your experience with our website and services. Most Internet browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some services and portions of this website may not function properly.
2.8. Log file information
2.8.1. Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of a web page or app is downloaded to your browser or device.
2.8.2. When you use the Services, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then helps us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Services.
2.9. Device identifiers
2.9.1. When you use a mobile device like a tablet or phone to access the Services, we may access, collect, monitor, store on your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, that uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us.
2.9.2. A device identifier may deliver information to us or to a Third Party partner about how you browse and use the Services and may help us or others provide reports or personalised content and ads. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
- How we use your Information
3.1. How we use your Information will depend on the nature of your interaction with the Services and with us. We need to have valid grounds to process your Information. Most times, we would seek your consent, like when you register for an Account or subscribe to our mailing list. Other times, when you reasonably expect us to use your Information, we will not ask for your consent, but only when it is legally permissible for us to do so (e.g. it is necessary for our performance of a contract, or for us to comply with a legal obligation etc.). Generally, we collect and use Information for the following purposes:
a) To allow you, and those whom you have given permissions to, to access Content and Information which you have uploaded;
b) To identify you with Content which you have uploaded;
c) To remember Information so that you do not have to re-enter it each time you use the Services;
d) To provide personalised Content to you and others such as Followers and Band Members or other interest segment updates, personalised online advertisements or other forms of marketing like emails about products, services and other information you might be interested in. We may also contact you for market research purposes;
e) To test, improve and monitor the Services, including diagnosing and fixing technology problems, and including use as part of our API;
f) To provide you with At-Counter feature and other updates, respond to your feedback, answer your queries and to otherwise communicate with you;
g) To allow other Users to communicate with you to the extent that you give them permission to (e.g. by activating Chat in At-Counter);
h) To monitor metrics such as site traffic and demographic patterns;
i) To automatically update the At-Counter application on your device;
j) To process payments made by or to you; and
k) To comply with applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us.
3.2. For clarity, you’re granting us permission to use your Information for the above-mentioned purposes (through your use of the Services) not only allows us to provide the Services as they exist today, but also to provide you with new capabilities as we develop the Services in the future.
3.3. Apart from the above purposes, we may also notify you of other purposes for which we process your Information and seek your consent to such purposes (e.g., when you participate in a survey, provide feedback, enter a competition etc.).
- Sharing of your Information
4.1. We will not rent or sell your Information to Third Parties without your consent, except as noted in this Privacy Policy.
4.2. We may share your Information with the following parties:
a) Related Entities: These are businesses that are legally part of the same group of companies that we are part of, or that become part of that group.
b) Service Providers: These are our Third Party contractors. We engage them to assist us in providing and managing aspects of the Services, such as developing the Services’ features and functionality, marketing, processing payments, processing data or statistics, hosting Content, providing server space, reviewing Content for compliance with our Terms of Use, and legal advice.
c) Third Party Advertisers: We may provide Information to Third Party advertisers so that they can notify you of events or products which may be of interest to you. For instance, you may be notified of an upcoming concert or product release.
d) Analytics Services: We may use third party analytics providers and products to obtain, compile and analyse Information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data), and may provide such Information to these analytics providers for the purpose of obtaining statistics and other information about how Users are using and interacting with the Services.
e) We may remove parts of data that can identify you and share anonymised data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.
4.3. We require that all parties with whom we share Information to implement adequate levels of protection in order to protect such Information. We also require that these parties only process your Information strictly for purposes which we engage them for and consistent with the purposes that we have described in Section 3 “How we use your Information” or with other purposes for which your consent has been sought and obtained.
4.4. We will only share your Information and Content in accordance with this Privacy Policy.
4.5. If you delete Information or Content which you have uploaded or posted on the Services, copies may remain viewable in cached and archived pages of the Services, unless you contact us to request permanent deletion as per Section 8.3 below.
4.6. We may also share your Information with Third Parties in the following circumstances:
(a) Change of control: If the ownership of our business changes or we undertake a reorganisation of our business, we may transfer your Information and Content to the new owners so they can continue to operate the Services. The new owners may subsequently make changes to this Privacy Policy;
(b) If permitted or required by law: We may disclose Information if we believe that such disclosure is required or permitted by law (e.g. by responding to requests from government authorities, or disclosure pursuant to court orders or other legal demands); and
(c) To protect interests: We may disclose information if we determine it is necessary to enforce or protect our rights or the property or personal safety of the Users of the Service (e.g. to enforce this Privacy Policy or our Terms of Use, or to prevent or take action against illegal activities, suspected fraud, or potential threats or breaches).
- How we store your Information
5.1. We, our Related Entities or service providers may transfer your Information to other countries in which our facilities or businesses are located, to be stored or processed. We will ensure that all entities located outside of Singapore to which we transfer information observe a standard of data protection which is comparable to that required under the Singapore Personal Data Protection Act 2012. This includes the entities’ making of reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk to your Information, and removing the Information as soon as it is reasonable to assume that its retention is no longer necessary.
5.2. Currently, the countries to which Information is transferred for the purpose of storage on cloud servers are Singapore and the United States of America. We may update this list periodically to reflect any new locations where your Information may be stored.
5.3. By registering for and using the Services, you acknowledge that the transfer of your Information to countries in which we, our Related Entities, or service providers have facilities or businesses are necessary for us to provide the Services to you, and that we have provided you with a reasonable summary of how your Information would be protected when it is transferred out of Singapore. You consent to the transfer of information to Singapore, United States of America or to any other country in which we, our Related Entities, or service providers maintain facilities or businesses, and the processing of Information as described in this Privacy Policy.
5.4. On your part, you should maintain the secrecy of your Account password at all times.
- Children’s Privacy
6.1. We do not knowingly collect Information from children under the age of 13 without parental consent. If you are a child under 13 years of age, you are not permitted to use the Services and should not send any information about yourself to us through the Services.
6.2. In the event that we become aware that we have collected Information from any child, we will delete that Information. If you are a parent or guardian and you believe that your child under the age of 13 years has provided us with Information without your consent, please email us at [email protected] and we will take reasonable steps to ensure that such Information is deleted from our systems.
- Other websites and services
7.1. If you use a link to go from the Services to other websites, applications or platforms, this Privacy Policy does not apply to those websites, applications or platforms. They have their own privacy policies and you should familiarise yourself with them before you permit them to access and process your Content or Information.
7.2. We are not responsible for and do not have control over any other third party websites, applications or platforms which you authorise to access or process your Content or Information. If you are using a third-party website, application or platform and you allow them to access or process your Content or Information, you do so at your own risk.
- Contacting us about your Information
8.1. If you have any questions or feedback regarding this Privacy Policy, you may contact our Data Protection Officer:
8.2. If you (i) wish to update or correct your Information, (ii) wish to request for information from us on what Information of yours we have and how we have used and shared your Information during the last one year before the date of your request, (iii) wish to restrict or withdraw your consent to our processing of your Information, (iv) wish us to delete your Information, or (v) have any questions, concerns or feedback on this Privacy Policy, please contact our Data Protection Officer in writing via email to [email protected]
8.3. If you are a resident of the European Union using the Services, you have the following rights under the General Data Protection Regulations:
a) Right to be informed: This right means that when we ask you to provide us with your Information, we will give you details such as what we are using it for, how and with whom it will be shared, and how you may contact us if you have any queries;
b) Right to access: This right allows you to ask us for details of the Information we hold on you, e.g. what Information is being processed and for what reason, what Information is being transferred and to whom, what rights you have etc;
c) Right to rectification: This right allows you to ask us to correct anything that you think is wrong with the Information we have about you;
d) Right to erasure also known as the “right to be forgotten”: This right means you can ask us to delete your Information from our system;
e) Right to restrict processing: This right allows you to ask us to only process your Information for those certain purposes that you specify;
f) Right to data portability: This is the right to ask us to send you your Information electronically. You may also ask us to transmit such Information to another party;
g) Right to object: This is your right to tell us to stop processing your Information;
h) Right not to be subject to automatic decision-making, including profiling: We sometimes use computers to study and analyse Information. We might do this so we can understand how you, and other visitors, are using the Services. This allows us to improve the Services for better customer experience e.g. by providing personalised Content and marketing to you. For situations that may significantly impact you, you have the right to ask us not to do this; and
i) Right to complain, right to judicial remedy: If you feel your rights are breached, these rights allow you to make a complaint to the relevant authorities or to sue us in court.
8.4. EU residents may exercise their rights above by writing to our Data Protection Officer at [email protected] The parent or guardian of a User resident in the European Union under the age of 13 years old or applicable age of consent can request this on behalf of their child.
- Changes to this Privacy Policy
We may, at our sole and absolute discretion, change or update portions of this Privacy Policy at any time and without prior notice to you. We will notify you when changes are made via the email address associated with your Account. We also recommend that you review this Privacy Policy from time to time so you are aware of any changes or updates. We will indicate the effective date of the notice. Your continued use of the Services after any modification to this Privacy Policy constitutes your acceptance of such modification and your consent to our processing of Information in accordance with the modified Privacy Policy. If you do not wish to continue using the Services under the modified Privacy Policy, you should terminate your Account.