This policy describes how we collect and use your personal data, in accordance with the REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter, the "General Data Protection Regulation" or the "GDPR") and any other related regulations which may be in force from time to time.
We are committed to protecting your privacy. This Policy tells you what personal information we collect, why we need it, how we use it during your use of the app and since you do not unsubscribe from the same, and what protections are in place to keep your personal information secure. It also set out your rights in relation to your personal information.
It is important that you read this Policy, and any information policy or notice that we may subsequently provide to you, carefully so that you are aware of how and why we are processing your personal information.
We will only use your personal data as set forth in this Policy which is applicable at the time of collection of your personal data. We reserve the right to amend this Policy at any time by publishing said amendments on our app. Therefore, we recommend that you check the Policy every time you enter the app. If we decide at any time to use personal data other than as stated at the time of collection, we will communicate said decision to you by email, provided that we have your email address. You will then be given the chance to authorise other uses or disclosures of the personal data provided by you before the amendment of our Policy.
Should any of the clauses in this Policy be eliminated or considered null and void, this will not affect the rest of the terms and conditions or clauses of this Policy, which shall remain fully valid and effective under regulations in force from time to time.
Creative HotHouse Technologies Pte. Ltd., 103A (Level 2), Amoy Street, 069923 Singapore (hereinafter referred as to “JET8”, “we”, “us” or “our”), act as data controller in respect of the personal information that we process. This means that we are responsible for deciding how we hold and use personal information about you.
We have appointed a data protection officer (DPO) to oversee compliance with this policy. If you have any questions about this Policy, how we handle your personal information, or you would like to update the information we hold about you, please contact firstname.lastname@example.org.
Our obligations in relation to processing your personal information are set out in this Policy.
You also have responsibilities in relation to personal information, which includes:
- taking appropriate steps to protect the security of personal information;
- being careful about who personal information is disclosed to, and
- protecting your communications and devices.
In any event, users will hold full responsibility for any information which they may provide on the app. Should JET8 wish to use said information for purposes other than as explained above, we will inform you of said new purposes and request your consent if necessary.
The user guarantees that the information provided to JET8 is truthful and up to date and undertakes to communicate any changes with may affect his/her status. Furthermore, the user guarantees that he/she has any authority necessary to communicate information belonging to third parties and that he/she has informed said third parties of the personal data processing by JET8 for purposes connected to our services.
2. What personal information do we hold about you?
Which are the Data Protection Principles?
We will comply with data protection law. This says, among other matters, that the personal data we hold about you must be:
- used lawfully, fairly and in a transparent way;
- processed only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- relevant to the purposes we have told you about and limited only to those purposes;
- accurate and kept up to date;
- kept only as long as necessary for the purposes we have told you about; and
- kept confidential and secure.
What is “personal information” or “personal data”?
Your 'personal information' or ‘personal data’ means any information about you from which you can be identified - either by reference to an identifier (for example your name, location data or online identifier (e.g. IP address)) or from factors specific to your physical, cultural or social identity (e.g. your social background, outside interests etc).
It does not include information where the identity has been removed (such as anonymous information).
What personal information do we process?
JET8 collects and use personal information that you provide as part of the registration as a user, as well as additional personal information that is collected in the course of your interaction with the app (e.g. for wallet creation). We primarily use this personal information for the services we offer, to comply with our Terms and Conditions, for managing the user’s interaction and relationship with JET8 and any other apps depending on JET8.
The personal information about you that we may collect, store and use include, but is not limited to, the following categories of information:
When creating a JET account:
- Name and Surname
- Phone number
- Postal Code
- Street & Number
Please note that the type of personal information we collect about you will depend to some extent on your circumstances, your role and our legal obligations.
'Special category' personal information.
Certain 'special categories' of more sensitive personal information. We will neither collect nor process any personal data which may be especially sensitive or included in the special category of user personal data, unless said data have been provided explicitly. Special personal data categories include information related to race/ethnicity, political opinions, religious, philosophical or similar beliefs, membership in trade unions, genetic data, biometric data used for exclusive purposes of identification of an individual, health data, sexual lite or sexual orientation.
We do not knowingly collect personal data from, children under the age of 13 (or your country’s age of minority). Nevertheless, if you believe that your child has provided us with their personal data and you need to let us know to delete it, please email us at email@example.com.
3. Where do we collect your personal information from?
Where does your personal information come from?
We collect your personal information:
- From you: we typically collect your personal information directly from you through the app (when downloading, creating an account or providing us with more information).
- From your device.
- From the JET8 related apps (i.e. Fotoku): Data stored by JET8 from the Apps/API: App User: Name & Surname, Username, Avatar, Email, Phone, Birth date, Gender, Country, Region, City, IP, Language, Followers and Following count, Facebook access token, Instagram access token, Twitter access token, Device platform and version, App platform and version, Operator, Device unique ID, Device push token, IMEI (Not used anymore but stored).
- From third parties: we may sometimes collect additional information from third parties including social networks, such as Facebook and Instagram. The categories of personal information we may collect, store and use from third parties includes, but is not limited to, the following categories of information:
- Email address.
- Friends list.
- Public profile.
- Birth date.
- In the app activities: throughout the period you are joining with us, we collect additional personal information about you, including likes, comments, shares and views.
4. How will we use your personal information?
What is the legal basis for using your personal information?
We will only process your personal information when the law allows us to. In most cases, we will process your personal information where it is necessary:
- to perform the Terms and Conditions we have entered into with you for the purposes of joining the app and services (e.g. email to become user) (Basis 1)
- to comply with a legal obligation (e.g. transparency in countries where no regulation exists) (Basis 2)
- for our legitimate interests as app and service provider (or those of a third party). Where we rely on legitimate interests as the reason for processing personal information (e.g. promotion or evaluation of the services), we have considered whether those interests are overridden by any separate rights or freedoms of our users and have concluded that they are not (Basis 3)
- with your specific consent (Basis 4).
We may also process your personal information in the following circumstances, but this is likely to be rare:
- where we need to protect your interests (or someone else’s interests);
- where it is needed in the public interest.
What is the purpose for processing your personal information?
We process your personal information for a number of purposes including, but not limited to, the following. In relation to each, we have also identified the legal basis for processing your personal information by reference to each legal basis set out in 4A above:
- To register the user and generate a new Fotoku user account as a member. (Basis 1)
- To provide our services under the Terms and Conditions entered between JET8 and each of the users. (Basis 1)
- To enable access to any options requiring registration (e.g., accessing options within the account profile, activating custom alerts). (Basis 1, 3, 4)
- To respond to consultations or information requests made by the users. (Basis 1, 3)
- Provided that you have ticked the relevant box, to keep you informed of our services, activities, projects, updates and new website or application features by means of notices/newsletters sent by email and/or other electronic means. (Basis 4)
- To communicate your personal data to our partners to obtain points. (Basis 3)
- If you have ticked the relevant boxes, we may also send you push notifications in connection with our products and services. (Basis 4)
Change of purpose
We will only use your personal information for the purposes for which we collected it - unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose.
If we need to use your personal information for an unrelated purpose, we will notify you and explain the basis upon which that is necessary.
5. Do we need your consent?
Your right to withdraw consent
If you do provide your consent to the processing of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for that purpose.
If you wish to withdraw your consent, please contact firstname.lastname@example.org.
6. What steps do we take to protect your data?
How do we secure your data?
JET8 has security measures in place to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, or inappropriately altered or disclosed. In addition, we limit access to your personal information to those who need to process that information for business reasons. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected information security breach and will notify you and any applicable regulator of a suspected breach as appropriate and in accordance with our legal obligations.
7. Who do we share your personal information with?
What is the legal basis for sharing your personal information with third parties?
We may share your personal information with third parties, including third party service providers and other Group companies in the following situations:
- where required by law;
- where it is necessary to administer the services we provide, or
- where we have another legitimate interest in doing so, as app.
In these circumstances, we require third parties to ensure the security of your personal information and to process it in accordance with the law.
What protections are in place?
The terms of our contracts with third parties include obligations on them in relation to what personal information they can process and what they can do with that information. All our third-party service providers, professional advisers and other entities in the Group are required to take appropriate security measures to protect your personal information in line with our policies.
We do not permit our third-party service providers to use your personal information for their own purposes – they may only process your personal information for specified purposes and in accordance with our instructions.
Which third parties process your personal information?
We may disclose your personal information to the third parties listed below where relevant to the purposes described in this Policy. This might include:
- other companies as part of our regular reporting activities on company performance, in the context of a business reorganisation or Group restructuring exercise, for system maintenance support and hosting of data;
- agents or contractors that provide services to us including, for example, IT services or quality of service, and order fulfilment;
- staff authorised by JET8 or its representatives acting on behalf of JET8, subject to applicable personal data protection law.
- regulatory authorities or other third parties as provided far by applicable law.
8. Which countries do we transfer data to?
International data transfers
Your personal information may be disclosed to JET8 outside the European Economic Area (EEA) – this is the case for all transfers from Europe to Singapore.
Additionally, certain suppliers and service providers may also have personnel or systems located outside the European Economic Area (EEA). Your personal information may therefore be transferred to non-European Economic Area countries.
What protections are in place?
Where we transfer your personal information outside the European Economic Area, we will take steps to ensure that your personal information receives an adequate level of protection, for example by entering into information transfer agreements or by ensuring that the third parties are certified under appropriate information protection schemes.
9. How long do we use your personal information for?
We will retain your personal information only for as long as is reasonably necessary to satisfy the purposes for which it was collected, and for the purposes of satisfying any legal or reporting and regulatory requirements. These legal and other requirements require us to retain certain records for a set period of time, including following the termination of your user account. In addition, we retain certain records in order to resolve queries and disputes that may arise from time to time.
When you are no longer a user, we will retain and subsequently securely destroy your personal information in accordance with the personal data regulations in force and uses.
In some circumstances we may anonymise your personal data so that you are no longer identifiable, in which case we may use such information without further notice to you.
10. Social networks
JET8 is present in some of the main social networks on the Internet, where it acts as data controller in connection with personal data published by JET8.
JET8 will process personal data on each social network in accordance with the rules established by the relevant social network to such end. Therefore, except as otherwise stated, JET8 may inform its followers on each social network of its activities, events and related matters, including follower services, through the channels provided by the social network for such purpose.
JET8 will not collect personal data from social networks except otherwise expressly agreed to by the user.
11. Direct marketing
We undertake not to use your personal data for direct marketing purposes without your express prior consent, as provided . If, at any time, you wish to stop receiving commercial or promotion or information from JET8 or third parties, you may unsubscribe from direct marketing campaigns processing of your personal data far said purposes, free of charge, by contacting us on email@example.com or by pressing the opt-out button on the subject field of the email. You may also use the opt-out procedure provided in any promotional message received from JET8.
Please note that, even if you decide not to subscribe or if you decide to unsubscribe from receiving promotional emails or newsletters or other electronic means we may need to continue contacting you in connection with important information of a non-commercial nature, such as problem solving, inactivity or lack of use, detection and prevention of errors or, in general, compliance with the Terms and Conditions and operational procedures of the app.
12. Automated decision-making
Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:
- where we have notified you of the decision and given you [detail] days to request a reconsideration;
- where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights;
- in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights; and
- if we make an automated decision on the basis of your sensitive personal data we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
13. What are your rights and responsibilities?
Inform us of changes
Please ensure you inform us if your personal information changes while you are a user as it is important that the personal information we hold about you is accurate and current. We also encourage you to monitor and update your personal information where appropriate.
Failure to provide personal information
Certain information has to be provided so that we can provide you with the services of our app, such as basic demographics (age, gender, country) and activity within the app. Without this information, we may not be able to carry out the actions and offer you our app’s experience.
Your rights in relation to your personal information
You have a number of rights in relation to the personal information that we hold about you (subject to certain exemptions (e.g. public interest), including the right:
- request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, e.g. the fulfilment of a legal obligation. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below);
- object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and the circumstances of your particular situation mean you wish to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes (including profiling);
- request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it; and
- request the transfer of your provided personal data to another party.
Further information about your rights are available from firstname.lastname@example.org.
Lodge a complaint before the supervisory authority?
Users in the EU also have the right to lodge a complaint with a supervisory authority in a member state of the EU if you believe we are infringing EU data protection laws. You can lodge a complaint with the supervisory authority in your EU member state of residence, the member state in which you work or the member state in which the alleged infringement took place.
To opt-out of our collection of information from mobile devices, please visit your device’s settings to set the “Limit Ad Track” or another similar feature on your device. You can also opt-out of our data collection and use through the process we described here Opt-Out. You can also make choices about data collection for certain companies by visiting http://preferences-mgr.truste.com/.
Note that if you opt-out you will still see advertising on your device, but it may be less relevant to your interests. In addition, if you reset your device identifier or use a different device you may need to renew your opt-out.