privacy policy.
At Gluu, we take our customers’ privacy seriously. The purpose of this Privacy Policy is to provide you with information of how your personal data will be managed. Gluu managed our customers’ personal data in accordance and compliance with the Personal Data Protection Act 2012 (“the act”).
By engaging with the Gluu service, or signing up to any promotions offered by us, your personal information and data will be collected. You agree and consent to Gluu Life Pte Ltd (known as “us”, “we” or “our”), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data and disclosing such Personal Data to Gluu’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.
This Privacy Policy supplements but does not supersede nor replace any other consents you have previously provided to Gluu not does it affect any rights which Gluu may have at law in connection with the collection, use of disclosure of your Personal Data. Gluu may from time to time update this Privacy Policy to Ensure that this Privacy Policy is consistent with our future developments, and/or any changes in legal and regulatory requirements. Subject to your right t law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our websites. Please check regularly for updated information on the handling of your Personal Data.
For avoidance of doubt, this Privacy Policy forms a part of the Website Terms and Conditions (“Website Conditions”). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, this Privacy Policy will prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specified.
-
Your Personal Data
1.1 In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us:
1.1.1 Your name, NRIC, mobile number(s), email address, or any other information relating to you which you have provided to us in any forms you have submitted to us, or in other forms of interaction with you;
1.1.2 Information about your use of Gluu’s website and services, including cookies, IP address and subscription account details
1.1.3 Your payment related information such as credit card information, or other financial information and your payment history
1.1.4 Information about your usage of and interaction with our service and/or our website.
1.1.5 Location Data
a) Gluu collects this data when the Gluu app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
b) Location data (Sharers and takers). We collect precise or approximate location data from users’ mobile devices if they enable us to do so. Gluu collects this data from the time a user opens the app. We use this data to enhance your use of our apps, including notifications of nearby hotspots, showing of other active users that you can connect to or share data with.
-
Collection of Personal Data
2.1 Generally Gluu collects your Personal Data in the following ways :
2.1.1 When you submit forms relating to our service
2.1.2 When you interact with our officers and employees
2.1.3 When you use our service
2.1.4 When you respond to our marketing communications, emails, promotions and/or other initiatives
2.1.5 When we receive references from business partners and third parties
2.1.6 When you submit your Personal Data to us for any other reason.2.2 When you browse our website or application, you generally do so anonymously but please note Section 5 on use of Cookies.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives(, by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, and true. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
-
Purposes for the Collection, Use and Disclosure of your Personal Data
3.1 Generally, Gluu collects, uses and discloses your Personal Data for the following purposes
3.1.1 Responding to your queries, requests
3.1.2 Managing the operations of Gluu and complying with internal policies and procedures;
3.1.3 Facilitating business asset transactions (which may extend to any merger, acquisition or asset sale)
3.1.4 Verifying your identity
3.1.5 Preventing, detecting or investigating crime, including fraud and money laundering, and managing commercial risks;
3.1.6 Protecting and enforcing contractual and legal rights and obligations;
3.1.7 Conducting audits, reviews and analysis of our internal processes, action planning
3.1.8 Compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by the relevant authorities; and/or
3.1.9 Any other purpose relating to any of the above
3.2 In addition, Gluu may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationships with you:
3.2.1 If you are using Gluu’s service(s) and/or download or use any of our Apps
3.2.1.1 Process your subscription service
3.2.1.2 Maintain your account with us
3.2.1.3 Verify and process your personal particulars and payments in relation to the provision of the service to you
3.2.1.4 To communicate with you of changes and development to Gluu policies, terms and conditions
3.2.1.5 Resolving service issues and handling requests
3.2.1.6 In processing your personal data in relation of any of the purposes stated above
3.2.2 In addition, where permitted under the Actm Gluu may also collect, use and disclose your Personal Data for the following purposes
3.2.2.1 Providing value-added services to you including reward redemption programmes
3.2.2.2 Matching Personal Data with other data collected for other purposes and sources (including third parties) in connection with the provision of offering services by Gluu or other third parties
3.2.2.3 Administering marketing programmes and promotions
3.2.2.4 Sending you details of products, services, special offerings which may be of interest to you
3.2.2.5 Conducting marketing research, to improve our products, services
3.3 If you have provided your contact information such as mobile number(s) and email addresses, and have indicated consent to receiving marketing or promotional information, then from time to time, Gluu may contact you to provide information or updates to our products and services
3.4 You also consent to the collection, use and disclosure of your Personal Data by Gluu in connection with any transaction, relating to the acquisition, divestment, securisation, amalgamation, listing or other transaction relating to any interest in Gluu, and any other corporate transaction involving Gluu, including any evaluation or due diligence relating there to, as well as to the collection, use and disclosure of such information by the counterpart(its) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant
-
Disclosure of Personal Data
4.1 Gluu will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for purposes listed above (where applicable), to the following third parties, where they are located overseas or in Singapore :
4.1.1 Gluu affiliates
4.1.2 Contractors or third party providers who provide operational services to Gluu
4.1.3 Vendors or third party business partners who offer related good and services for redemption in Gluu Store
4.1.4 Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres
4.1.5 Any business partner, investor or assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale
4.1.6 Anyone to whom we may transfer our rights and duties
4.1.7 Banks, credit card companies and their respective service providers
4.1.8 Relevant government regulators or authority or law enforcement agency to comply with any laws or regulation
-
Use of Cookies
5.1 When you interact with us on our websites, we may collect or analyse anonymised information of your interaction from which individuals cannot be identified (“Aggregate Information”)
5.2 Gluu uses “cookies”, where a small amount of data file is sent to your browser to store and track Aggregate Information.
-
Third-Party Sites
6.1 Our website may contain links to other websites operated by third parties, such as business partners. We are not responsible for the privacy practices of websites Operators by third parties.
-
Withdrawal, Access and Correction of your Personal Data
7.1 Should you wish to withdraw consent of your Personal Data or obtain access to or make corrections to your data records, please email us as support@gluu.life
7.2 Please note if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Gluu may not be able to provide its service or administer any contractual relationship in place, and this may result in the termination of any agreements with Gluu, and this being in breach of your contractual undertakings. Gluu’s legal rights and remedies in such event are expressly reserved.
-
Governing Law
8.1 This Privacy Policy shall be governed in all respects by the laws of Singapore