Privacy Policy (Singapore)

Elemental Communications Pte Ltd (Co. No. 201727271H), thereafter referred to as “CLOUDROCK” or “the Company”, respects the privacy of individuals with regard to personal data and is committed to protecting the privacy of our users, and strives to provide a safe, secure user experience. This privacy policy is designed to help you understand what information we collect and how we use and share that information.

This Privacy Policy applies to CLOUDROCK’s websites (the “Sites”, which include without limitation URLS, mobile or localized versions and sub-domains) which is owned and operated by CLOUDROCK, as well as to the services provided by CLOUDROCK (the “Services”).

By using our Sites and Services, you agree to this Privacy Policy.

In this Policy, the following definitions apply:

The term “Customer” means any person or company who uses CLOUDROCK’s Sites and/or Services.

The term “Consumer” means a customer, user or visitor of a website developed and operated by a CLOUDROCK Customer.

The term “Personal Information” means any information which, either alone or in combination with other information, identifies you as an individual, such as your name, mailing address, email address and other information you submit to us at the Site.

We may also collect information about your behaviour or our other customers’ behaviour when visiting the Site. CLOUDROCK may display this information publicly, or provide it to others. However, CLOUDROCK does not disclose personally-identifying information other than as described below.

We may collect Personal Information from our Customers. Through the use of our Services, we may also receive information, which may include Personal Information about Consumers who use our Customers’ Sites. This Privacy Policy also applies to how CLOUDROCK uses and discloses the Personal Information it obtains or receives through its Sites and Services.

If you are a visitor to or user of a third-party website or service (“Third-Party Property”) that utilizes any CLOUDROCK products (such as the popups, forms and pages), then any information you submit to such Third-Party Property (including via the CLOUDROCK product/s) is collected under the privacy policy of the owner of such Third-Party Property, and you should contact such owner with any related requests or inquiries you may have.

CLOUDROCK is not responsible for the privacy or security practices of our Customers, which may differ from those set forth in this privacy policy. Please check with individual Customers about the policies they have in place.

 

Information Collected

We collect information about users during the registration process for certain parts of our site; through their participation in certain activities, including contests, forums, and polls; for the sending of newsletters and offers; and through the use of cookies. When you request pages from our server, it automatically collects some information about your preferences, including your IP address. We use this to help diagnose problems with our server, and to administer our site.

Registration and Contact Information. We collect information about you when you (a) register to use the Services and (b) otherwise provide contact information to us via email, mail, or through our Services. This information you provide may include your username, first and last name, email address, mailing address or phone number.

Authentication. By registering or authenticating, Users allow the Services to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, the Services will be able to access some Data, stored by these third-party services, for registration or identification purposes. To find out more, please refer to the description of each service.

Payment Information. When you purchase the Services, we will also collect transaction information, which may include your credit card information, billing and mailing address, and other payment-related information (“ Payment Information”).

‍Third-Party Platforms. We may collect information when you interact with our advertisements and other content on third-party sites or platforms, such as social networking sites. This may include information such as “Likes”, profile information gathered from social networking sites or the fact that you viewed or interacted with our content.

Information collected via Technology. When you visit our Sites or interact with the Services, some information is automatically collected via technology. In an effort to improve your experience of the Sites and Services, this may include information such as the date and time, information about your browser, IP address, operating system and computer or device, and the website you visited before our Sites (known as the “referring URL”), as well as other information. We also collect information on how you use Skyrock’s Sites and Services, including the elements you have interacted with, metadata and other details about these elements, clicks, the Site pages viewed, and other user actions.

We track this information using cookies. Cookies are small data files that are placed on your computer or mobile device when you visit a website, mobile app or use an online platform. Cookies are widely used by online service providers to facilitate and help to make the interaction between users and websites, mobile apps and online platforms faster and easier, as well as to provide reporting information. Skyrock uses cookies to help us and our customers to identify and track visitors, their website usage, and their website access preferences. The use of cookies by our customers, partners, affiliates, and service providers is not covered by our privacy policy. We do not have control over how they use cookies on their sites. If you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer’s hard drive, block all cookies or to receive a warning before a cookie is stored.

Some of our pages may also include pixels, which are electronic files to count users who have visited that page, to track activity over time and across different websites, to determine users’ interactions with emails we send, to identify certain cookies on the computer or other electronic device accessing that page, or to collect other related information, and this information may be associated with your unique browser, device identifier, or IP address. We may, for example, implement a pixel on specific pages where you view a certain listing so that we can track whether the listing is of relevance to you while offering recommendations. Through these pixels and cookies, we collect information about your use of our Sites, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Sites.

Personal Data Relating to a Third Party. Any Personal Data relating to a third party (e.g. information of your spouse, children, parents etc.) that you provide to us on the basis that you represent that, by submitting such information to us, you have obtained the consent of the third party to provide us with their Personal Data.

Location Information Determined by GPS Technology. You can withdraw consent at any time by not advancing further in the App, or by deactivating the service on your mobile device or computer.

Other Information. We may collect other information from you that is not specifically listed here. We may use any such information in accordance with this Privacy Policy or as otherwise permitted by you.

Customer Data. You may submit various types of information and data into the Services for hosting and processing purposes (“Customer Data”). Customer Data may include, without limitation, “Personal Information” such as names, email addresses and phone numbers of your end customers, potential customers, and other users of and visitors to your websites, apps, and other properties (“Consumers”), which information may be input into the Services by you or collected by the Services using CLOUDROCK scripts, pages and other code implemented on such properties.

 

Purpose of Personal Data Collected

Personal Data that you provide to us voluntarily on our website and its other related channels will be processed for the following purposes (“Purposes”):

  • to complete transactions with you, manage and verify your membership of our customer loyalty scheme where applicable;
  • to direct market to you;
  • to understand and analyse our sales, and your needs and preferences;
  • to develop, enhance, market and provide products and services to meet your needs;
  • to enable you to participate in promotions and contests;
  • to process exchanges or product returns;
  • to improve our services; and,
  • to respond to requests or complaints;
  • to meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms;
  • to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, and performance evaluation, and identity verification purposes;
  • to provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements;
  • In the manner described to you at the time of collection or as otherwise described in this Privacy Policy.

Although the precise details of the Personal Data collected will vary according to the specific purpose (such as contests, forums, surveys etc) whether via online or otherwise, we may typically collect the following Personal Data from or in relation to you:

  • Name
  • Address
  • Company Details
  • Phone Number
  • Date of Birth
  • Email Address
  • Gender

 

How We Share Information

Affiliated Businesses And Third Party Websites We Do Not Control. In certain situations, businesses or third party websites we’re affiliated with may sell items or provide services to you through a website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites as to privacy or anything else, so if you choose to enter into such transaction or to receive such service, please review the applicable third party websites’ policies.

Service Providers. CLOUDROCK may share Personal Information we collect with those of its employees, contractors and third-party service providers that need to know that information in order to process it on CLOUDROCK’s behalf, or to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Service, among other things. Some of those employees, contractors, and third-party service providers may be located outside of your home country. In all cases where we share your information with such service providers, we explicitly require the service provider to acknowledge and adhere to our privacy and customer data handling policies. Except as otherwise discussed in this Privacy Policy, CLOUDROCK will not sell Personal Information to anyone, and will not disclose Personal Information to any third parties for such third parties’ marketing purposes, unless we first receive your consent. However, we may share aggregated and non-personally-identifying information with third parties for marketing, advertising, research, or other purposes.

Advertising Partners. We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information with them for this purpose. We and our third-party partners may use cookies and other tracking technologies, such as pixels and web beacons, to gather information about your activities on our Websites and other sites in order to provide you with targeted advertising based on your browsing activities and interests.

Compelled Disclosure. We may share Personal Information with any competent law enforcement body, regulatory body, government agency, court, or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

To A Potential Buyer (And It’s Agents And Advisors). If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of CLOUDROCK’s assets, financing, acquisition of all or a portion of our business, a similar transaction, or steps in contemplation of such activities, your Customer Data and Consumer Data may be among the assets transferred. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Site.

Consumer Data. We may disclose Consumer Data to the Customer who has collected such information. Notwithstanding anything else in this Privacy Policy, our Customers may access, view and download any Consumer Data gathered through the website they operate, and we have no control over their collection, use or disclosure of this information. CLOUDROCK will not use such Consumer Data for any purpose other than to provide or improve our Services to Customer or as otherwise directed by Customer in accordance with Customer’s written instructions or consistent with applicable laws.

By disclosing Consumer Data, including Personal Information on Consumers, to CLOUDROCK, the Customer acknowledges that it has read, understood and agreed to this Privacy Policy, and warrants that it has obtained the consent of the relevant Consumer to such collection, use and disclosure of Personal Information as described in this Privacy Policy. Customer agrees that it may be necessary for CLOUDROCK to access Consumer Data to respond to Customer’s request for support with any technical problems. Customer shall hold CLOUDROCK, its subcontractors, suppliers and licensors harmless from any and all data protection claims relating to such access.

Any Other Person With Your Consent. Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

 

How We Protect Information

Security. The majority of our Sites and Services require a username and password to log in. Customers must keep their username and password secure, and never disclose it to a third party. Because the information in a Customer’s CLOUDROCK account is so sensitive, account passwords are hashed, which means we cannot see a Customer’s password. We cannot resend forgotten passwords either. We will only provide Customers with instructions on how to reset them.

We implement security measures to protect Customer Data and Consumer Data provided to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. However, these measures do not guarantee that your Customer Data and Consumer Data will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time. By visiting our Site and using our Services, you agree to indemnify, defend (if we so request) and hold harmless CLOUDROCK and its affiliates, suppliers, partners and agents from and against any claim, demand, losses, damages or expenses (including reasonable attorney’s fees) arising from your content, your use of the Sites or Services, your connection to the Sites, your violation of these Terms or your violation of any rights of any third party. Your indemnification obligation will survive the termination of these Terms and your use of the Sites and Services.

 

Right of Access to Personal Data

Withdrawing Your Consent. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Customers cannot opt out of these messages unless you cancel your account with us.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within twenty (20) business days of receiving it.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Opt-Outs. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Services to you.

Communication Preferences. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications, such as clicking the “unsubscribe” link at the bottom of our marketing emails. Please note, however, that you may be unable to opt-out of certain service-related communications.

Blocking Cookies. We may provide you with the opportunity to “opt-out” of having your personal information used for certain purposes when we ask for this information. If you decide to opt-out, we may not be able to provide certain features of the Services to you.

How We Respond to Do Not Track Signals. Your Web browser may have a “do not track” setting which, when enabled, causes your browser to send a do not track HTTP header file or “signal” to each site you visit. At present, the Services do not respond to this type of signal.

 

Data Retention

We will retain Customer Data and Consumer Data as long as your, or your company/organisation’s account remains active, or as needed to provide you services. If you wish to cancel your account, contact us at EMAIL.

We will retain and use your Customer Data and Consumer Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. However, CLOUDROCK reserves the right to delete your Customer Data and Consumer Data after seven (7) days following your account’s suspension date.

 

Transfer of Data Outside of Singapore

Our information technology storage facilities, servers and third party systems may be located in other jurisdictions outside of Singapore. This may include, but not limited to, instances where your Personal Data may be stored on servers located outside Singapore. In addition, your Personal Data may be disclosed or transferred to entities located outside Singapore or where you access the Sites from countries outside Singapore. Please note that these foreign entities may be established in countries that might not offer a level of data protection that is equivalent to that offered in Singapore under the laws of Singapore. You hereby expressly consent to us transferring your Personal Data outside of Singapore for such purposes. We shall endeavour to ensure that reasonable steps are taken to procure that all such third parties outside of Singapore shall not use your Personal Data other than for that part of the Purposes and to adequately protect the confidentiality and privacy of your Personal Data.

 

Links

This site contains links to other sites. CLOUDROCK is not responsible for the privacy practices or the content of such sites. CLOUDROCK has also established relationships with partners, but such relationships are generally technical in nature, or content collaborations. If any partner has access to any information entered by users in our database, this fact shall be disclosed to the user upon initiating the registration process. Users who feel they do not wish their information to be shared by anyone other than CLOUDROCK may then opt out of completing the registration.

 

No Use of Services by Children

The Services are not intended for use by anyone under the age of 18, nor does CLOUDROCK knowingly collect or solicit personal information from anyone under the age of 13. If we learn that a child under 13 submits personal information to CLOUDROCK, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: say.hello@cloudrock.asia.

 

Changes to Privacy Policy

We reserve the right to amend this Privacy Policy from time to time without prior notice. We advise that you check this Privacy Policy on a regular basis.

 

Data Protection Officer

If you have any questions or concerns about our Privacy Policy, you may contact us by emailing us at say.hello@cloudrock.asia or by writing to us at:

Fairuze Shahari
14 Robinson Road #08-01A
Far East Finance Building
Singapore 048545
+65 6653 5603

This Privacy Policy is effective as of January 01, 2020.