1. Introduction 

1.1 This Privacy Policy (the "Policy") applies to Hi5 and/or Anjels Media Pte, including its subsidiaries, affiliates, brands, related entities, and any jointly controlled entities. This encompasses all shareholders, directors, employees, suppliers, contractors, and permitted individuals associated with these entities (collectively referred to as "Hi5", "we", "us", or "our"). Hi5 is dedicated to safeguarding your online privacy. This Policy outlines our procedures for the collection, use, disclosure, storage, transfer, and processing of your personal data.

1.2 This Policy is integrated into Hi5’s Terms of Use. Your access to and use of our Platform and Services are governed by both the Terms of Use and this Policy. Terms not explicitly defined in this Policy will retain their meanings as set out in the Terms of Use.

1.3 To effectively manage and administer your relationship with us, we will need to collect, use, disclose, store, transfer, and process your personal data. This Policy covers personal data about you and/or individuals you provide to us, whether currently or in the future. We will handle your personal data in compliance with the applicable data protection laws in the regions where we operate, as well as in accordance with this Policy.

1.4 For companies, entities, or organizations, the terms "you" and "your" also include your employees, representatives, and agents.

1.5 By accessing, browsing, downloading, or using our Platform and/or Services, or engaging with us, you confirm that you have read and understood this Policy and consent to our processing of your personal data as described herein, subject to any updates or amendments.

1.6 We may update or revise this Policy at any time by posting the new version on the Platform. Unless specified otherwise, updates will be effective immediately. Continued access to or use of our Platform and Services, or ongoing interactions with us, after a Policy update signifies your acceptance of the revised Policy.

2. Collection of Personal Data

2.1 "Personal data" refers to any information, whether in physical form or not, that, when combined with other information, can identify an individual or make them identifiable.

2.2 We may collect various types of personal data from you, including: (a) Identity details such as your name, nationality, gender, date of birth, biometric data, and photographs; (b) Contact information including your billing address, delivery address, email address, and phone numbers; (c) Account information such as bank details, credit/debit card information, payment details, financial data, and employment information; (d) Transaction details, including payment methods, information about transactions to and from you, and details of goods, products, or services you have purchased from or through us; (e) Technical information like your IP address, login details, browser type and version, time zone, location, browser plug-ins, operating system, mobile carrier, URLs, and other technological data from the devices you use to access our Platform and/or Services; (f) Profile information including your username and password, purchase or order history, interests, preferences, feedback, and responses to surveys; (g) Location data such as GPS coordinates or similar geographic information from your computer or mobile device; (h) Usage data detailing how you interact with our Platform and/or Services; and/or (i) Marketing and communication preferences, including your choices regarding receiving marketing materials from us or third parties and your communication preferences.

The type of personal data collected will vary depending on the purpose of collection. We may handle your personal data through various means such as collection, recording, modification, storage, transfer, deletion, and other processing activities.

2.3 Your personal data may be collected through interactions with us, including transactions and communications. We may also obtain your data from other sources, such as: (a) When you create an account with us; (b) When you complete and submit forms, whether online or in physical form; (c) When you engage in transactions or provide documentation related to your dealings with us; (d) When you utilize features or functions of the Platform and/or Services; (e) When you use our or our partners’ products, services, publications, or marketing materials; (f) When you participate in meetings, events, contests, promotional activities, loyalty programs, or surveys; (g) When you interact with Hi5’s social media pages by following, liking, or becoming a fan; and/or (h) From publicly available sources and directories.

2.4 We may also receive, store, and process personal data from third parties authorized by you, credit reference/reporting agencies, regulatory and law enforcement bodies, for purposes such as providing our services, fulfilling agreements, and complying with legal and regulatory requirements.

2.5 You must ensure that any personal data you provide is accurate and not misleading, and you are responsible for keeping it updated and notifying us of any changes. We reserve the right to request documentation to verify the personal data you provide as part of our verification procedures.

2.6 If you provide personal data of third parties, you confirm that you have obtained the necessary consent from those individuals to share their data with us. You also consent to our collection, use, and disclosure of that data in accordance with this Privacy Policy.

3. Purpose of Collecting and Processing Your Personal Data

3.1 The personal data you provide or that we collect from you, or from other sources as necessary for the purposes for which it was collected, may be used for the following purposes (collectively referred to as the “Purposes”):

For Hi5 members/users:

  • To create and manage your user account with us;
  • To verify and manage your identity;
  • To offer, maintain, and enhance the Platform and/or Services for you;
  • To process and complete your orders, transactions, or purchases, and to notify you of any issues or unusual account activities;
  • To conduct financial transactions, including authorizing online banking, credit/debit card payments, and sending you receipts;
  • To handle customer service requests, fulfill your instructions, and respond to inquiries, requests, or complaints made by you or on your behalf;
  • To communicate with you about the administration and management of your account or use of our Services, including sending administrative information through various channels such as email, notifications, or platform messages;
  • To tailor and enhance your experience with the Platform and/or Services;
  • To facilitate your involvement in activities such as contests, promotions, surveys, or campaigns;
  • To perform market research, internal marketing analysis, customer profiling, and trend analysis based on anonymized data;
  • To conduct due diligence or screening, including background checks, as required by legal, regulatory, or risk management procedures;
  • To protect and enforce our legal rights, including defending against claims;
  • To comply with legal and regulatory requirements, including court orders;
  • To respond to requests from governmental or law enforcement authorities and public agencies;
  • To detect, investigate, and prevent suspicious transactions, fraud, or misuse of the Platform and/or Services;
  • To transfer or assign our rights and obligations under any agreements with you;
  • For internal administrative purposes such as auditing, data analysis, record-keeping, and security;
  • To store and back up your personal data, including disaster recovery purposes;
  • To perform automated decision-making as part of these purposes; and/or
  • For any other purposes disclosed to you at the time of obtaining your consent.

By using our services, you agree to the collection and processing of your personal data for these Purposes.

3.2 Marketing and Promotional Purposes

  • We may also use and process your personal data for marketing and promotional activities (“Marketing and Promotional Purposes”) such as:
  • Sending you updates, newsletters, promotional materials, and information about products, services, events, and offers from us or our business partners that might interest you;
  • Sending festive greetings or messages;
  • Inviting you to events or activities organized by us or our partners;
  • Processing your registration for events or activities and communicating with you about them;
  • Sharing your data with our partners to communicate with you about their products, services, or promotions via various channels including SMS, email, phone calls, social media, or other methods.

You can opt out of receiving marketing and promotional materials at any time by requesting us to stop or by using the “Unsubscribe” link in marketing emails. Even after unsubscribing, you may still receive non-marketing communications related to your account or our ongoing business relationship.

You can also disable push notifications by adjusting the settings on your device.

  • For users, your profile information such as your username may be visible to other users when you post ratings or reviews. We will not disclose your email address or other personal details without your consent.
  • We may also use and share aggregated, non-personal, statistical, or anonymous data with third parties for data analysis, marketing strategy development, and to improve the Platform and/or Services.
  • By using our services, you consent to the processing of your personal data for the Purposes outlined in this Privacy Policy.
  • Any additional purposes not covered above will require separate consent from you.
4. Consequences of Withholding Consent or Failing to Provide Personal Data

The provision of your personal data to us may be required or optional depending on the specific Purposes for which it is collected. If providing your personal data is mandatory and you choose not to provide it, or if you do not consent to this Privacy Policy, we may be unable to offer you access to our Platform and/or Services. In such cases, we may not be able to fulfil your requests or provide the services you seek.

5. Disclosure of Your Personal Data

We are committed to protecting your personal data and will not sell, rent, or transfer your data to third parties without your consent. However, we may disclose your personal data to the following parties for the purposes outlined in this Privacy Policy:

Affiliated Entities:

  • Our subsidiaries, affiliated, or associated companies.

Emergency Contacts:

  • Your immediate family members or emergency contacts as you have informed us.

Business Successors:

  • Entities succeeding our business operations.

Merchants:

  • Our merchants for transactions you make on the Platform, including feedback or comments you provide about their services, as though you dealt directly with them.

Business and Marketing Partners:

  • Selected third parties, including business partners, sponsors, and advertisers who may collaborate with us on new products, services, promotions, or events.

Confidentiality Obligations:

  • Parties who are under a confidentiality agreement with us and are engaged to fulfill our obligations to you.

Legal and Professional Advisors:

  • Auditors, consultants, lawyers, accountants, and other professional advisors providing services to us under strict confidentiality.

Service Providers:

  • Third parties nominated or appointed by us for data processing, centralization, or logistics purposes, as well as storage and record management services.

Regulatory and Legal Entities:

  • Government agencies, law enforcement, courts, regulatory bodies, and statutory agencies if required by law, regulation, or legal proceedings.

Credit Agencies:

  • Credit reference and reporting agencies for credit assessment purposes.

Third-Party Service Providers:

  • Business partners, vendors, suppliers, and contractors who assist in providing our services or related products.

Insurance and Financial Institutions:

  • Insurance companies and financial institutions for insurance or credit facility applications, as needed.

Transaction Processing Entities:

  • Banks, financial institutions, merchants, and credit/debit card companies involved in your transactions.

Public Information:

  • The general public in cases such as contest winnings, event participation, or public ratings and reviews on the Platform.

Business Transactions:

  • Third parties involved in any business restructuring, merger, acquisition, or asset sale, and in the unlikely event of insolvency or bankruptcy.

Operational Necessities:

  • Any other persons reasonably required for us to conduct our business or perform the activities described in the Purposes or as authorized by you.

We will ensure that any third parties receiving your personal data are obligated to protect it in accordance with applicable data protection laws.

6. Accuracy of Your Personal Data

We rely on the accuracy and completeness of the personal data you provide and assume that it is not misleading or outdated. You are responsible for promptly informing us of any changes to your personal data. Please be aware that failure to keep your personal data accurate, complete, and current—such as having an invalid or expired payment method—may affect your ability to access and use the Platform and/or Services.

7. Your Rights

7.1 Access and Correction: Subject to applicable personal data protection laws in the jurisdictions where we operate, you have the right to request access to, obtain a copy of, and request updates or corrections to your personal data that we hold. We may impose a nominal fee (as permitted by relevant laws) to cover the costs associated with processing your access request. However, we reserve the right to apply any statutory exemptions or exceptions regarding the collection, use, and disclosure of your personal data.

7.2 Withdrawal of Consent: You may withdraw your consent, either fully or partially, by providing written notice to us, subject to applicable legal constraints, contractual obligations, and a reasonable timeframe for processing the withdrawal. Please be aware that withdrawing consent may have legal implications. Depending on the extent of your withdrawal, we may be unable to maintain our relationship with you or may need to terminate any contracts in place.

7.3 Updating Personal Data: You can update, correct, or delete your personal data at any time by modifying your profile on the "Account Settings" page of the Platform. Please note, however, that personal data may be retained in our backup systems for a period of time and records associated with past transactions cannot be deleted as they are retained for historical purposes.

8. Retention of Your Personal Data

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected. Once your personal data is no longer needed for these purposes, it will be securely destroyed or anonymized in accordance with our data retention policy. However, if longer retention is required to meet operational, legal, regulatory, tax, or accounting obligations, your personal data may be retained for that extended period.

9. Security of Your Personal Data

9.1 Security Measures: We are dedicated to safeguarding your personal data. To prevent unauthorized access, disclosure, or other risks, we strive to implement appropriate technical, physical, electronic, and procedural security measures. These measures align with applicable laws, regulations, and industry standards to protect your data from unauthorized processing, destruction, accidental loss, damage, alteration, or disclosure.

9.2 Updates and Third-Party Security: We will periodically review and update our security measures to ensure they remain effective. We also require that any authorized third parties handling your personal data use it only for the purposes outlined in this Privacy Policy. However, we are not liable for the actions or inactions of these third parties regarding your data.

9.3 Internet Security: While the Internet is inherently insecure, we implement reasonable security practices for the Platform and electronic communications with us. All employees and data processors with access to your personal data are bound by confidentiality obligations.

9.4 Limitations of Security: No data transmission over the Internet or any wireless network can be guaranteed to be completely secure. Despite our efforts to protect your personal data, we cannot guarantee absolute security and will not be responsible for any unauthorized access, illegal interception, or loss of data transmitted to or from Hi5. Additionally, we are not accountable for the actions of any third parties who may receive such data.

10. Personal Data from Children and Other Individuals

10.1 Data from Third Parties: If you provide us with personal data about family members, spouses, dependents (if you are an individual), or directors, shareholders, employees, representatives, and agents (if you are a corporation, entity, or organization), you confirm that you have informed them about the collection and processing of their data by us. You also warrant that you have obtained their consent for the processing, including disclosure and transfer, of their personal data as outlined in this Privacy Policy.

10.2 Data from Minors and Incapable Individuals: For children (under the age of 18 or as defined by the applicable laws in your jurisdiction) or individuals who are not legally capable of giving consent, you confirm that you are their parent, legal guardian, or an individual appointed by the court to manage their affairs. You agree to consent on their behalf to the processing, including disclosure and transfer, of their personal data in accordance with this Privacy Policy.

11. Transfer of Your Personal Data Outside of Your Country

Our IT storage facilities and servers may be situated in countries outside your country. This means your personal data could be stored on servers located abroad and may be disclosed or transferred to entities in other countries. Please be aware that these countries might not provide the same level of data protection as your country’s applicable laws. By using our services, you expressly consent to the transfer of your personal data outside your country for these purposes.

12. Use of the Internet and Mobile Applications

12.1 Risk of Internet Data Transmission: You acknowledge that providing personal data over the Internet is done at your own risk.

12.2 Public Ratings and Reviews: Any rating or review you post on our Platform will become public information and may be retained even after your account is terminated. Your email address and phone number will not be visible through any rating or review you post.

12.3 Links to Other Websites: If our Platform links to other websites, please be aware that these sites operate independently and are not covered by our Privacy Policy. We are not responsible for the content or practices of these external websites. We recommend reviewing their privacy policies before providing your personal data.

12.4 Cookies and Tracking Technologies: We use cookies to enhance your experience on our Platform, including remembering your login details and tracking your usage. Cookies are not used to collect personal data but may be used in aggregated, statistical, or anonymized forms. You can disable cookies via your browser or device settings, though this may affect the functionality of certain features on our Platform.

12.5 Third-Party Advertising: We may allow third-party companies to display ads tailored to your interests based on your activity on our Platform. These companies might use cookies and other tracking technologies to deliver and personalize ads.

12.6 Mobile Application Permissions: Upon installing our mobile application, we will create an account linked to your device. Personal data collected through the app will be used as described in this Privacy Policy. Mobile platforms like iOS and Android may require permissions for data access, which you can accept or deny based on your preferences.

12.7 Social Sharing Features: Our Platform may include social sharing tools that allow you to share information with others based on your social network settings. The use of your personal data by these social networks is governed by their privacy policies, not by ours. By connecting your social network account, you consent to our collection of personal data from that account in accordance with your privacy settings and this Privacy Policy.

12.8 Location Services Information: We may collect and store location data from your device when interacting with us. This data is used in anonymized form, but if it is personally identifiable, you will be given options to manage its disclosure. You can control location services settings on your device, and by enabling these services, you consent to our collection and use of location information as outlined in this Privacy Policy.

12.9 Discretionary Location Data Collection: The collection of location data is optional and can be managed through your device settings. If you enable location services while using our Platform, you agree to our collection and use of this information. We are not liable for any issues arising from your decision to share location information with other users.

13. Contact Information

For any questions regarding this Privacy Policy, or if you need to make a request for feedback, corrections, or limitations concerning your personal data, you can:

13.1 Adjust your account settings directly within your account on our Platform; or

13.2 Reach out to us through the communication channel available on the Platform; or

13.3 Email us at: hello@anjelsmedia.com.sg

14. Governing Language

In case of any discrepancies or inconsistencies between the English version and any translated versions of this Privacy Policy, the English version will take precedence.

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