Privacy Policy
Last modified: 24 November 2023
Unless otherwise defined herein, capitalized terms used in this privacy policy (“Privacy Policy”) shall have the same meanings as those defined in our Terms and Conditions.
This Privacy Policy explains how OtterHalf, a marketing agency, collects, holds, processes, uses, protects, stores, shares, and transfers (collectively ‘‘Process’’, and ‘‘Processing’’ shall be construed accordingly) information and/or data provided by you to us, including but not limited to your personal data and information (“Data”) when you use the services provided by OtterHalf ("Services"). This Privacy Policy covers both the “online” (e.g., web and mobile services) and “offline” (e.g., collection of Data through telephone or in person) activities owned, operated, provided, and/or made available by OtterHalf. This Privacy Policy specifically addresses our obligations in respect of personal data privacy under the Relevant Laws. Where practicable, OtterHalf undertakes to also apply the principles and the processes set out in the Relevant Laws to its operations globally. If OtterHalf's operations are subject to privacy legislation other than that of the Region, then this Privacy Policy will apply so far as practicable and consistent with such legislation.
Please review this Privacy Policy carefully so that you understand OtterHalf's privacy policies and practices.
BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR DATA, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY AND GIVE US YOUR CONSENT TO PROCESS YOUR DATA.
We request all persons using the Services to voluntarily provide us with the Data (as set out in section 1 below) for the purposes as set out in section 2 and section 4 below. Do not use the Services or give us any of your information if you do not agree to the terms of this Privacy Policy. However, OtterHalf will not be able to provide Services to you if you do not provide such Data. If you wish to revoke your agreement to the terms of this Privacy Policy, please notify us by sending an email to our Data Privacy Officer in accordance with section 11 below or via any other means as prescribed by us from time to time. This Privacy Policy is an integral part of our Terms and Conditions.
We may update or change this Privacy Policy from time to time to reflect our latest privacy policies and practices as it deems fit. Any changes will be effective immediately upon posting of the revised Privacy Policy. If OtterHalf makes material changes, we will notify you by means of a notice on the Platform. We recommend that you review our Privacy Policy regularly for information about our latest privacy policies and practices. Your continued access or use of the Services after such updates, changes, or notice, as applicable, constitutes your consent to be bound by the then-current Privacy Policy.
1. What Data do we Process? We may Process the following Data:
Your name, your email, your telephone number, and/or other contact details.
Cookies information as set out in section 7 below.
Any other information provided by you pursuant to your use of the Services.
If you contact us, a record of that correspondence.
You understand and acknowledge that this Privacy Policy may not apply to any unsolicited information you provide to us through the Services or through any other means in certain regions where OtterHalf operates. Where applicable, all unsolicited information shall be deemed to be non-confidential and OtterHalf shall be free to Process, reproduce, disclose and distribute such unsolicited information to others without limitation or attribution.
2. What do we use the Data for? The purposes for our Processing of Data on the Services (“Purposes”) include the following:
To verify your identity.
To provide the Services to you, including processing any orders and payments.
To operate, protect, improve and optimize the Services
To notify you about changes to the Services or respond to any communication and/or request from you.
To monitor the use of the Services.
To investigate any reported incidents, complaints, or potential breaches of the Services.
Where applicable and subject to compliance of the Relevant Laws, to provide you with marketing and promotional materials and messages in accordance with section 4 below.
To identify whether you have enjoyed promotional benefits by receiving and using marketing and promotional materials.
To compile aggregate statistics about you and to analyze the Services usage.
Where applicable and subject to compliance of the Relevant Laws, to match the Data with other Data collected for other purposes and from other sources including third parties in relation to the provision of Services to you.
To facilitate our Processing of the Data for purposes relating to the provision of Services offered by us and marketing services, special events, and/or promotions of us and/or our clients.
To comply with our obligations under the applicable laws and regulations from time to time.
To disclose to and/or assist relevant authorities where we suspect you have committed an offense, where we suspect existence of fraud or when required by the relevant laws or court orders, or as requested by relevant public and law enforcement authorities.
To design and provide products and services to you in relation to the above purposes.
We will seek your express consent to change how we Process the Data if required by the Relevant Laws, but otherwise use of the Services following such changes constitutes your acceptance of the revised statement then in effect.
3. Do we disclose any Data to outside parties? We generally only permit our duly authorized staff to access the Data, and we will only release such Data to third parties under the following circumstances:
Where the Data is disclosed, provided, and/or transferred to:
Any third-party suppliers or external service providers who have been duly authorized by us to use such Data and who will facilitate the Services on the Platform, under a duty of confidentiality.
Our agents who have been duly authorized by us to use such Data.
Any other parties in connection with a sale or proposed sale of all or part of our business or portfolio of products or other assets.
Us, our business partners, and/or agents in connection with marketing and/or cross-marketing.
Any Outside Parties (as defined below) as set out in section 4 below.
To credit reference agencies, debt collection agencies, fraud detection, and/or prevention agencies.
To any relevant public authorities or law enforcement agencies, including, for example, where we suspect you have committed an offense, where we suspect existence of fraud or where required by applicable law, regulation or legal proceedings.
In order to enforce or apply our Terms and Conditions of your use of the Services or any other agreement to which you and we are a party, as applicable.
Where we deem necessary, in order to maintain and improve the Services.
You should take care when using any Services social networking features since the Data you disclose can be seen by other users. You understand and acknowledge that we cannot control the actions of other users of social networking features with whom you may choose to share the Data with. We do not monitor the use of such features in the normal course of business although we reserve the right to do so at our discretion. Therefore, you understand and acknowledge that we cannot and do not guarantee that the Data will not be reviewed by unauthorized persons.
4. Do we Process any Data for marketing and promotional purposes? We may from time to time send promotional and marketing materials and messages based on the Data (“Additional Purposes”).
The following classes of services, products, and subjects may be marketed:
Special events hosted by us for you and other users of the Services, including but not limited to competitions and social gatherings.
Reward, loyalty, or privileges programs in relation to the Services and related products.
Special offers in relation to the Services and related products, including but not limited to coupons, discounts, purchase offers, and promotional campaigns.
Products and services offered by us and our business partners and agents which may be of your interest.
Products and services offered by us and our advertisers (the names of which can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); and
Donations and contributions for charitable and/or non-profit making purposes.
The above products, services, and subjects may be provided or solicited by us, third-party service providers providing the above services, products, and subjects and charitable and/or non-profit-making organizations (“Outside Parties”). We may provide the Data to Outside Parties for use by them in marketing their above services, products, and subjects.
You may opt out from receiving any communications of Additional Purposes at any time by sending an email to our Data Privacy Officer in accordance with section 11 below or via any other means as prescribed by us from time to time. Any such request should also clearly state the details of Data in respect of which the request is being made.
Please note that after opting out, you may still receive non-marketing and non-promotional messages, including but not limited to product updates and service notices as permitted under applicable local laws and regulations.
5. Can you access and correct your Data? You have the right, if expressly permitted by Relevant Laws, to:
Check whether we hold any Data and, if we hold the Data, to receive copies of such Data.
Request us to correct any Data which is inaccurate.
Any other request that is expressly permitted by Relevant Laws.
Subject to Relevant Laws, we have the right to charge a reasonable fee for processing a data access request; and if expressly permitted by Relevant Laws, we shall provide you with an estimate of the fee after we receive a data access request from you. However, the final fee to be charged may differ from the estimated fee. If the final fee to be charged is higher than the estimated fee, we shall inform you of the higher fee. Your data access request may be refused if you do not pay the fee.
The aforementioned requests in relation to the Data may be made by contacting our Data Privacy Officer by email or by post in accordance with section 11 below. Any such request should also clearly state the details of Data in respect of which the request is being made, and we may request you to prove your identity in relation to your request to access and/or correct such Data.
6. How do we protect the Data? We have adequate measures to protect the Data from unauthorized access, accidental loss, or destruction. Where we have given you (or you have chosen) a password which enables you to access certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of Data via the Internet is not completely secure. While we endeavor to protect your Data, we cannot guarantee the security of Data transmitted to the Services; any transmission is at your own risk. Once we have received the Data, we will use strict procedures and security features to try to prevent unauthorized access. In case of cybersecurity risks, we may issue warnings and provide instructions to you in accordance with the Relevant Laws.
7. Do we use cookies? We use certain cookies (such as Google Analytics’ cookies) and other similar technologies as part of our Services. The cookies used are for the purposes of enabling you to use the Services (for example, to enable you to complete a registration or access information) and for us to understand and save your preferences for future visits, analyze usage patterns, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools for the Platform in the future. We may contract with third-party service providers to assist us in better understanding our site visitors in accordance with this Privacy Policy.
You can choose to disable cookies (through changing your browser or device settings) although you should be aware that this may prevent you from being able to use all parts of the Services.
8. Retention of Data Once we have obtained the Data, it will be maintained securely in our system; and subject to legal requirements and our internal policy, may be retained by us after deactivation of the relevant Services where such Data is still required for the purpose for which it was Processed.
9. Links to third-party websites Subject to this Privacy Policy, at our discretion, we may include or offer third-party products or services on the Platform. You understand and acknowledge that the fact that we may include or offer third-party products or services on the Platform does not mean that we endorse or authorize the collection of Data by such third parties, nor does it constitute a representation of any affiliation between us and such third parties. You understand and acknowledge that:
Once you click on a link to third-party websites, applications, or advertisements, you will access third-party websites, applications, and advertisements which may collect Data.
Such third-party websites, applications, and advertisements follow separate and independent privacy policies regarding the Processing of the Data you submit to them.
Hence, we have no responsibility or liability for the content and activities of these linked websites, applications, and advertisements (including any Processing of the Data by such third parties).
Nonetheless, we seek to protect the integrity of the Platform and welcome any feedback about these sites.
10. Data of minors and/or other individuals In some circumstances, you may have provided Data relating to minors and/or other individuals and in such circumstances, you represent and warrant that you are authorized to provide the Data to us and you have obtained their consent for the Data to be Processed in the manner as set forth in this Privacy Policy.
Where applicable, as a parent or legal guardian, please do not allow the minor(s) under your care to submit the Data to us. In the event that such Data is provided to us, you hereby consent to the Processing of the minor’s Data and personally accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.
11. Data Privacy Officer contact details Your requests shall be sent to the Data Privacy Officer by email. Please send your requests to: info@otterhalf.co