PRIVACY POLICY

Last updated: 19 May 2020

 

General Information

This is the Privacy Policy (“Policy”) of Lyte Ventures Pte Ltd (“Lyte Ventures”) that sets out how we collect, use, disclose and protect any Personal Data that you give to us. This Privacy Policy applies to all clients, customers, and content providers of Lyte Ventures, and is designed to meet the requirements of personal data protection laws in Singapore. 

Please take a moment to read this Privacy Policy before submitting any information requested by us, or signing up for any goods, services or activities offered by us, so that you are aware of and understand the purposes for which we collect, use and disclose your Personal Data.

From time to time, we may review and update this Privacy Policy to ensure that it is consistent with any changes in legal requirements. We encourage you to check this web page and our websites from time to time for any updated versions of our Privacy Policy that is posted and date stamped so that you are aware of when the Privacy Policy was last updated.

 

Scope of this Policy

This Policy applies to all Personal Data (as defined below) collected, whether or not processed online, through the http://www.jobsgowhere.sg website (the “Site”) operated by Lyte Ventures.

 

Types of Personal Data We Collect

The types of personal data that we collect depend on the circumstances of collection and on the nature of the transaction undertaken with us.

The personal data that we may request for includes but is not limited to (individually and collectively referred to as “Personal Data”):-

  1. personal identification information, including name, identification numbers, gender, date of birth, images, photographs, videos, voice recordings;
  2. contact information, including postal address, email address, phone number;
  3. payment information, namely credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
  4. demographic information such as academic qualifications, occupation, job details, preferences and interests;
  5. technical and statistical data, such as your IP address, browser type, domain names, access times and referring website addresses, which will automatically be collected by us to maintain quality of the service and to compile general statistics regarding use of our websites.

Separately, we encourage you to review the privacy statements of websites that we may link you to from time to time through the Site to understand how these websites collect, use and share your information. Your use of such third-party websites is subject to their privacy policies and is not covered by this Policy. As we cannot control or be responsible for the policies of other sites we may link to, or the use of any data you may share with them, you access these third-party websites at your own risk.

 

HOW WE COLLECT PERSONAL DATA

We use different methods to collect data about you, including the following: -

  1. Direct interactions

You may provide us with your Personal Data by filling in forms or by corresponding with us through our websites, by post, telephone, email, chatbots, or other means of communications we employ from time to time. Such interactions include, but is not limited, to the following scenarios: -

  • When you apply for our products or services;
  • When you create an account on the Site;
  • When you subscribe to our service or publications;
  • When you request for marketing to be sent to you;
  • When you enter a promotion or contest, complete a survey, or give us feedback;
  • When you use mobile or web applications developed by us; and/or
  • When you submit your resume or an application for employment or contracting opportunities with us.
  1. Automated technologies or interactions

As you use the Site, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this data by using cookies, server logs, and other similar technologies. Please see our Cookies Policy for further details.

  1. Third parties or publicly available sources

We may receive your Personal Data from various third parties and public sources, including financial and transaction data from providers of technical, payment, and delivery services.

 

WHAT WE DO WITH YOUR PERSONAL DATA

The Personal Data you provide helps us to understand your needs, maintain our relationship with you, process transactions, fulfil our delivery obligations for any goods, services or activities you undertake with us, and improve our service delivery. In particular, we collect your Personal Data for the following purposes, including without limitation:-

  1. to process relevant information including conducting analytics, for the provision of products, services or activities that best meet your preferences or needs;
  2. fulfilling instructions, sending postal mail and e-mails, providing marketing assistance, processing payments, and providing customer service;
  3. to respond to feedback from you and to respond to your queries, requests, and complaints;
  4. to provide updates on promotions and events;
  5. to improve our products and services and to customise our websites according to your interests;
  6. to develop content of our websites and our related network of websites;
  7. for safety, security and legal compliance;
  8. for record keeping;
  9. to conduct marketing activities including market research, customer profiling, customer insights, and targeted marketing activities;
  10. to carry out profiling and statistical analysis to improve the services provided to you;
  11. to market products, services and activities offered by us, our partners as well as our appointed agents, and to conduct product or customer satisfaction surveys and market research, which you will always have the option of opting out from receiving such information;
  12. to ourselves use or for the use of third parties, including Facebook, cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the Internet and to use such information to provide measurement services and targeted advertising,

(collectively referred to as “Purposes”).

Where we process your Personal Data pursuant to any of the above Purposes, we do so on one or more of the following legal basis: -

  1. it is necessary for the performance of our contractual relationship with you, which is regulated by the applicable terms and conditions governing the use of the Site and by the specific forms collecting your data;
  2. it is necessary for our legitimate interests;
  3. it is necessary to comply with our legal obligations;
  4. it is authorised under any applicable law or regulation; or
  5. you are deemed to have consented to such processing under any applicable law.

Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose(s) for which we are using your data. Please contact us if you need details about the specific legal grounds) we are relying on to process your Personal Data.

 

DISCLOSURE OF YOUR PERSONAL DATA

We may also use and disclose your Personal Data within the Lyte Ventures group of companies, and with and to third parties. Such third parties include our agents, authorised service providers such as marketing partners and web analysis companies, and their business partner, our auditors and professional advisors, business partners, our underwriters and insurers, law enforcement agencies, and any person to whom disclosure is permitted or required by any applicable laws, enforceable governmental requests or court orders. We impose strict obligations on the third parties mentioned above with which we share your Personal Data to maintain the integrity and security of that data. We only allow third parties to use your Personal Data for specified purposes and in accordance with our instructions.

We disclose your Personal Data in order to fulfil the Purposes, in which case, we may:-

  1. disclose, transfer, and jointly use your Personal Data to and with such third parties in Singapore and overseas, and your Personal Data may also be transmitted to data storage facilities or our offices and appointed agents in Singapore or other countries in connection with our performance of the transaction with you;
  2. share your Personal Data with our trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your Personal Data except to provide these services to us, and they are required to maintain the confidentiality of your Personal Data;

We may also disclose your Personal Data if required or authorised to do so by law or pursuant to a court order, including but not limited to circumstances where use and/or disclosure is:-

  1. necessary for any investigation or legal proceedings, including but not limited to fraud, intellectual property infringement or privacy;
  2. necessary for establishing, exercising or defending our legal rights, or obtaining legal services;
  3. necessary for responding to an emergency that threatens the life, health or safety of an individual;
  4. in connection with or forms part of any purchase, sale, lease, merger or amalgamation of the Lyte Ventures group of companies, including business or assets, or any other acquisition, disposal or financing, but otherwise it is not in our usual course of business to sell, rent or lease your Personal Data to third parties.

 

HOW WE SEEK YOUR CONSENT

Your express consent will be sought when first collecting your Personal Data. There will be instances where your consent for the collection or use of your Personal Data will necessarily be implied from the circumstances by nature of the task or transaction, including your interaction with us or in the course of signing up for, or accepting, any of our products, services or activities you have requested.

Where you are supplying the Personal Data of another individual (e.g. information of your spouse, children, parents, and/or employees, etc.), you represent, warrant, undertake and will ensure that the individual whose Personal Customer Data is supplied to us has consented to provide us with their Personal Data for the respective purposes, and is informed of and consents to the terms of this Privacy Policy.

This Privacy Policy shall supplement any other policies that you may have previously provided consent to us in respect of your Personal Data.

 

ACCESS TO YOUR PERSONAL DATA

We will, upon your written request to our Data Protection Officer (see contact details and requirements below), allow you to enquire about the ways in which your personal data has been or may have been used or disclosed within a year before the request. Where required or authorised to do so by law, we reserve the right to charge a reasonable administrative fee for this service and/or deny your request for access to your Personal Data.

 

ENSURING ACCURACY OF YOUR PERSONAL DATA

You should ensure that all Personal Data submitted to us is current, complete and accurate. Failure on your part to do so may result in our inability to provide you with the products, services and activities you have requested.

If you believe that any Personal Data we are holding on you is incorrect or incomplete, please write to or email our Data Protection Officer (see contact details and requirements below).

 

HOW LONG YOUR PERSONAL DATA IS KEPT

We will retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of the Lyte Ventures group of companies as set out above, or as required by relevant laws.

When destroying Personal Data, we will take commercially reasonable and technically possible measures to make the personal identifiable information irrecoverable or irreproducible.

 

SECURITY OF YOUR PERSONAL DATA

We are committed to ensuring the security and protection of your Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks.

We maintain physical, electronic and procedural safeguards to protect your Personal Data. For example:-

  1. We use industry-standard Secure Sockets Layer ("SSL") authentication to ensure the confidentiality of online transactions made on our site. SSL authentication and encryption of the information that you send to us over the Internet help protect your online transaction information from third party interception.
  2. We restrict the access of personally identifiable data to only specific authorised internal staff of the Lyte Group with dedicated login access and passwords.
  3. We ensure that our appointed IT service provider has the necessary security protocols in place to host and protect our data.

While we strive to protect your Personal Data, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter our websites or computer systems (for example viruses, bugs, trojan horses, spyware or adware). Despite all of our efforts, there is always a risk that third parties may unlawfully intercept transmissions. This reality is true of all Internet use. Further, we are not responsible for the privacy statements or content on websites not controlled by us.

 

PROTECTION OF YOUR PERSONAL DATA

If you access our website from a shared computer or a computer in an internet cafe, a library, or any public facility, certain information about you, such as your user ID, activity or reminders from our website, may also be visible to other individuals who use the computer after you. To protect your Personal Data or communication from being disclosed to others, you should log out, clear browsing data and close the web browser after using our website.

You should be aware of the risks associated with disclosing any information or transacting over the Internet or when using online portals, and we urge you to take every precaution when using the Internet to disclose your Personal Data to us, including using strong passwords, changing your password regularly, using a secure browser and not to share your password with anyone or via an unsolicited phone call or e-mail.

We will never ask for your password by phone or e-mail, so if you receive such an enquiry, please report the incident to our Data Protection Officer at dpo@lytepay.co.

If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place.

We are not liable for any loss or damage resulting from your act or omission to safe-keep your username and password from unauthorised use, and also for any information you transmit over the Internet which you do so solely at your own risk.

 

COMPLIANCE WITH THE GDPR

In the event that we have existing access and consent to your Personal Data, and you are a data subject in the EU, please contact us should you wish to exercise any of your following rights:-

  1. to request for the erasure of your Personal Data;
  2. to request for the restriction of processing of your Personal Data;
  3. to object to the processing of your Personal Data; and/or
  4. to request to transfer your personal Data to you or a third-party.

All requests made to us in exercising the rights above will be processed within a reasonable time except where we refuse such requests in accordance with any applicable laws or regulations.

To the extent the Personal Data contain personal data which we process are subject to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), you acknowledge and agree that for purposes of providing matching, measurement, and analytics services described hereinabove, the Lyte Group is the data controller in respect of such personal data, and where applicable, we may, from time to time, instruct Facebook Ireland Limited to process such personal data on your behalf as your data processor pursuant to these terms and Facebook’s Data Processing Terms, which are incorporated herein by reference. "Personal data", "data controller" and "data processor" in this paragraph have the meanings set out in the Data Processing Terms.

 

GOVERNING LAW

This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.

 

CONTACT US

If you:-

  1. have any questions or feedback relating to your Personal Data or our Privacy Policy;
  2. would like to withdraw your consent to any use of your Personal Data;
  3. would like to obtain access and make corrections to your Personal Data; or
  4. report any security incident relating to your username, password or transaction with us that involves your Personal Data,

Please contact us in writing at the e-mail address provided below referencing “Privacy Policy”:-

 

Data Protection Officer

Lyte Ventures Pte Ltd

Email address: dpo@lytepay.co

To protect your privacy and security, we will also require you to verify your identity before we can respond substantially to your request.

 

COOKIES POLICY

Last updated: 19 May 2020

General Information

Cookies are small text files placed onto your computer by certain websites and/or applications that you visit, or e-mails that you open. Cookies are used to help us improve your experience when using the Site – for example, storing your preferred language setting for the next time you visit.

By using the Site, you consent to our use of cookies to collect and use your personal data for the purposes of collecting website usage data, and to give you a personalised and more streamlined online experience.

The personal data that we collect may include information about the way you use our website, your choice of Internet browser, the type of device you are accessing our website from, and where you are in the world.

How We Use Cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies and other online tracking devices such as web beacons, action tags, single-pixel gifs on this website to: -

  1. tailor the Site to your personal needs;
  2. remember the notifications that you have been shown, so that you are not shown them again;
  3. recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);
  4. obtain information about your preferences, online movements, and use of the internet;
  5. carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor and/or customer requirements and interests;
  6. target our marketing and advertising campaigns and those of our partners more effectively by providing interest-based advertisements that are personalised to your interests; and
  7. make improvements and updates to our websites based on the way you want to use them; and
  8. make your online experience more efficient and enjoyable.

The information we obtain from our use of cookies may contain your personal data as we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information. In such circumstances in which we may collect personal information about you, we will do so only where you voluntarily provide it (e.g. by completing an online form) or where you purchase goods or services from us.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a service you have requested (eg to enable you to put items in your shopping basket and use our check-out process).

Why We Use Cookies

We collect and use cookies on our website for the following purposes: -

Technical
Cookies allow our website to function at its most efficient, including but not limited to: -

  1. Balancing website traffic to ensure all our users can enjoy consistent and reliable access;
  2. Limiting traffic to key sections of our website to maintain consistent performance; and
  3. Storing our users’ acceptance of our Terms and Conditions, Privacy Policy and Cookie Policy.

Ease of use

Cookies make navigating our website easier for you, including but not limited to: -

  1. Remembering your language and country preferences, and presenting relevant content;
  2. Keeping track of your user account when you have logged in; and
  3. Providing the most relevant information to you when using our products and services.

Analytic
Cookies are used to gather statistics on how you navigate and perform transactions on our website, including but not limited to: -

 Gathering feedback on your satisfaction through surveys; and

  1. Gaining insights into how you navigate and perform transactions on our website so that improvements can be made.

Marketing
Cookies allow us to present appropriate marketing messages to you, including but not limited to: -

  1. Allowing the Site to serve up different versions of a page for marketing purposes;
  2. Allowing third parties to display appropriate advertising to track its effectiveness; and
  3. Displaying relevant messages which offer a selection of products based on your viewing behaviour on the Site and certain other websites.     

We also use web analytics services, such as Google Analytics. Google utilises the data they collect to track and examine the use of the Site which is then used to prepare reports and its activities and share them with other Google services. Google may use the data they collect to contextualise and personalise the advertising on its own network. For more details, see Google’s Privacy Policy.

Online behavioural advertising

Online behavioural advertising is also known as interest-based advertising. It is a way of serving advertisements that are more relevant to your interests on websites visited by you. Shared interests are grouped together based on your previous web browsing activity. This allows us to display advertising that is relevant and useful to you. Advertising can also be delivered to you based on the website content you’ve just been viewing. This is called retargeting.

You may opt out of the use of cookies if you do not want to be retargeted or your advertising to be tailored. Opting out does not mean that you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer serve you advertising that is tailored to your web preferences and usage patterns. You may instead see more advertising that is not as relevant to your preferences.

Click stream data

A clickstream records which parts of a website you click on when you use it. We may collect clickstream data when you use our website and track referrals from other websites to improve your online experience with us. This data will not be stored as part of your customer record, and will only be used for statistical analyses.

Consent – Notification On Home Page

There is a notice on our home page which describes how we use cookies and which also provides a link to our website privacy policy. If you use this website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this website cookie policy and our website privacy policy.

Third Party Cookies

We work with third party suppliers who may also set cookies on our website, for example, Facebook, Google, YouTube, which we use to display and/or target content. These third party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party. You will find additional information in the table below.

Description Of Cookies

The table below provides more information about the cookies we use and why: -

Cookies

Owner

Category

Purpose for the cookie

Google Analytics

Google Inc.

Ease of Use, Analytic

This is a web analytics service provided by Google Inc which uses cookies to show us how visitors found and explored our site, and how we can enhance their experience. It provides us with information about the behaviour of our visitors (e.g. how long they stayed on the site, the average number of pages viewed) and also tells us how many visitors we have had.

Facebook pixel

Facebook Ireland Limited

Marketing; Online behavioural advertising

This is an analytics tool that allows us to measure the effectiveness of our advertising by understanding the actions visitors take on your website. We use pixel data to ensure that our ads are being shown to the right people, so that we can effectively build advertising audiences.

 

How To Turn Off Cookies

If you do not want cookies to be placed on your device, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of the Site. Further, some areas of our website may not function properly or be accessible.

Refer to the links below for each browser’s guide on how to turn off or delete cookies: -

  1. Chrome
  2. Firefox
  3. Internet Explorer
  4. Safari

If you delete your cookies, we will not be able to know that you have: -

  1. opted out of behavioural advertising on our website;
  2. recognise that you’ve agreed to our Terms and Conditions, Privacy Policy and Cookie Policy; or
  3. remember your language and country preferences.

This means that banners from our third-party partner websites may appear. You may then need to accept the use of cookies and provide other cookie-related information again.