Effective Date of Current Policy: 19 April 2021
This Policy applies to Personal Information that is Processed by Santivia in the course of our business, including on Santivia websites (each a “Site”), mobile applications, and other online, offline or in-store offerings (together with any and all future online and offline offerings operated by or on behalf of Santivia, the “Services”). “Personal Information” is any information relating to an identified or identifiable natural person. All individuals whose responsibilities include the Processing of Personal Information on behalf of Santivia are expected to protect that data by adherence to this Policy. This Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.
3. TRANSPARENCY/NOTICE – TYPES OF PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Santivia and the requirements of applicable law. Some of the ways that Santivia may collect Personal Information include:
You may provide Personal Information directly to Santivia through interacting with the Services, participating in surveys, during events, and requesting products, Services, or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavour to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 TYPES OF PERSONAL INFORMATION WE COLLECT
Santivia collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Santivia, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:
Purchases. When you purchase products or services from Santivia, you must provide us with Personal Information, such as your name, email address, address that are associated with your debit/credit card. Please note that we do not store credit/debit card numbers.
Communications with Us. We may also collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our products and Services, register for a newsletter, affiliate, referral or loyalty program that we may offer from time to time, contact customer service or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys or in-person interviews and focus groups. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys or interviews is provided by you voluntarily. We may use such information to improve our products, Sites and/or services and in any manner consistent with the policies provided herein. Posting on the Site. We collect information you post through the Site. For example, when you interact with other users or the Site by posting a review or other materials, the Site will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through the use of the Services such as preferences. To the extent devices transmit location data through GPS, Bluetooth, or WiFi signals, we may also collect this data.
Promotion and Giveaways. Occasionally we will partner with Third Parties on social media and online channels to sponsor giveaways and promotions. Terms and conditions will accompany each give Santivia and promotion, and it is the responsibility of all entrants to read the terms and conditions and privacy policies carefully. If you choose to share your information in order to participate in a giveaway or promotion, your entry information may be shared with such Third Parties.
Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations, which may supplement information provided by you. This supplemental information can allow us to verify information that you have provided to Santivia and enhances our ability to provide you with information about our business, products, and Services. For example, if you access Third-Party services, such as Facebook or Twitter, to login to the Services or to share information about your experience with Santivia, we may collect information from these Third-Party services.
3.2 HOW SANTIVIA USES YOUR INFORMATION
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including: To Provide Products, Services, or Information Requested. Santivia may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
Generally manage Individual information and accounts;
Respond to questions, comments, and other requests;
Support the tracking and recovery of your Santivia and/or other products;
Provide access to certain areas, functionalities, and features of Services provided by Santivia;
Allow you to register for events.
Administrative Purposes: Santivia may use Personal Information about you for its administrative purposes, including to:
Measure interest in Services provided by Santivia;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual accounts and activities on Services provided by Santivia and systems, and, in the discretion of Santivia, changes to any Santivia policy;
Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
Process payment for products or services purchased;
Process applications and transactions;
Comply with regulatory requirements, including collecting and using information relating to adverse effects which you may have experienced when using our products;
Prevent potentially prohibited or illegal activities;
Marketing Santivia Products and Services: Santivia may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Santivia may provide you with these materials via online social platforms, websites, phone, text/SMS, postal mail, facsimile, or email, as permitted by applicable law. Such uses include: To tailor content, advertisements, and offers;
To notify you about offers, products, and services that may be of interest to you;
To provide Services to you and our sponsors;
For other purposes disclosed at the time that Individuals provide Personal Information;
or Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
Research and Development: Santivia may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Santivia may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilised to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, referral offers, newsletters, mailings, or phone calls from us with information on Santivia or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 6 below.
Mobile Devices. From time to time, Santivia may provide Services that are specifically designed to be compatible and used on mobile devices. Santivia will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings and the operating system of your device. Mobile versions of Santivia Services may require that users log in with an account. In such cases, information about the use of mobile versions of the Services may be associated with user accounts. In addition, Santivia may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Santivia to enable Individuals to access user accounts and to enable Santivia to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Santivia may use personal or non-identifiable information transmitted to Santivia to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices which Santivia provides.
Anonymous and Aggregated Information. Santivia may use Personal Information and other information about you to create anonymised and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Santivia Services, or other analyses we create. Anonymised and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymised or aggregated information is not Personal Information, and Santivia may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Santivia and with Third Parties for our or their purposes in an anonymised or aggregated form that is designed to prevent anyone from identifying you. Information Submitted Via Services. You agree that Santivia is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Santivia will not release your name or otherwise publicise the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Sharing Content with Friends or Colleagues. Santivia Services may offer various tools and functionality. For example, Santivia may provide functionality on its Services that will allow you to forward or share certain content with a friend or colleague. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Santivia or any other Third Parties for any other purpose. Other Uses. Santivia may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 COOKIES, PIXEL TAGS/WEB BEACONS, AND ANALYTICS INFORMATION
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other providers to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. Google Analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement. If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 THIRD-PARTY SITES AND SOCIAL MEDIA PLATFORMS
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Santivia does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
The Site and our other Services may also contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by Third Parties for any number of purposes.
4. ONWARD TRANSFER – SANTIVIA MAY DISCLOSE YOUR INFORMATION
4.1 INFORMATION WE SHARE
We may share your information as described in this Policy (e.g., with our Third-Party service providers; to comply with legal obligations; to protect and defend our rights and property) or with your permission.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Santivia has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. Santivia may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested Santivia may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with the Santivia name. Santivia requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Santivia provided them.
Displaying to Other Users. The content you post to the Site may be displayed on the Site. Other users of the Site may be able to see some information about you, such as your name if you submit a review. We are not responsible for the privacy practices of the other users who will view and use the posted information.
Marketing. Interest-Based Advertising and Third Party Marketing. Through our Services, Santivia may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Santivia related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioural advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt-out of such sharing at no cost by following the instructions in Section 6 below.
Disclosures to Protect Us or Others (e.g., As Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce Santivia policies or contracts; (v) to collect amounts owed to Away; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorised activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of unauthorised activities.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, Santivia will endeavour to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected.
4.2 DATA TRANSFERS
All Personal Information collected via or by Santivia may be stored anywhere in the world, including but not limited to, Singapore, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Santivia, you consent to the storage of your Personal Information in these locations.
5. OPT-OUT (RIGHT TO RESTRICT PROCESSING
You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to the Processing of your Personal Information or Sensitive Personal Information by Santivia, you may withdraw that consent at any time and opt-out to further Processing by contacting email@example.com. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
5.2 E-MAIL AND TELEPHONE COMMUNICATIONS
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have purchased. We may also send you certain communications regarding Santivia and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy). We will provide opt-out notices to third parties who may contact you on our behalf in accordance with this Policy. While we will endeavor to ensure that you are removed from any such contact lists, we cannot guarantee that this will occur (for example, if your Information is provided to the third party through another advertiser whose communications you have elected to receive and not opted out).
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
5.3 DO NOT TRACK
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
5.4 COOKIES AND INTEREST-BASED ADVERTISING
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
6. RIGHTS OF ACCESS, RECTIFICATION, AND ERASURE
You may inquire as to whether Santivia is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may send an email to firstname.lastname@example.org or use any of the methods set out in this Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Santivia. Such requests will be processed in line with local laws.
Although Santivia makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Santivia is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Santivia determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Santivia will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. SECURITY OF YOUR INFORMATION
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an email to you. You may have a legal right to receive this notice in writing.
Santivia retains the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
9. CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of the Site is directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected any Personal Information from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.
10. INTERNATIONAL USERS
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the Singapore and processing globally. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.
11. REDRESS/COMPLIANCE AND ACCOUNTABILITY
If after reviewing this Policy, you would like to submit a request or you have any questions or privacy concerns, please send an email to firstname.lastname@example.org. Santivia will address your concerns and attempt to resolve any privacy issues in a timely manner.
12. OTHER RIGHTS AND IMPORTANT INFORMATION
The following capitalised terms shall have the meanings herein as set forth below. “Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Santivia or to which Santivia discloses Personal Information for use on its behalf.
“Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of Santivia or its subsidiaries worldwide.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction. “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offence.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Santivia or Agents of Santivia.