Privacy Policy

PRIVACY POLICY

 

1.         Introduction

 

1.1.    All capitalized terms specified hereunder shall have the same meaning as in the Terms and Conditions of www.leadupsystem.com, unless otherwise specified hereunder.

 

1.2.    This Privacy Policy governs how we collects, protect the information that you may provide on the Platform or through the Leadup Products.

 

1.3.    This Privacy Policy shall apply to the following data subjects: (i) users; (ii) customers and (iii) browsers/visitors of the Platform.

 

1.4.    Please note that privacy of the data subjects is of paramount importance to us. We ensure that the right measures are taken to ensure that we are in compliance with the applicable legislations.

 

2.         What Data is Collected?

 

2.1.    We collect different categories of personal data (hereinafter referred to as “Personal Data”). Following is a non-exhaustive list of the types of data which may be collected:

 

(a)              Contact details – this includes, but is not limited to, mailing address, telephone number, and email;

 

(b)              Personal details– this includes, but is not limited to, name, government issued identity document, gender, identification number, identification picture, marital status, number of dependents, date of birth and details of emergency contact;

 

(c)              Financial details – this includes, but is not limited to, details related to bank accounts;

 

(d)              Location – this includes, but is not limited to, residential address, business address and IP address;

 

(e)              Correspondence – this includes, but is not limited to, all communications and correspondence that you may have, in any form whatsoever, with us or our representatives.

 

(f)                Sensitive data – this includes, but is not limited to, biometric data procured for identity verification processes, and health-related data.

 

2.2.    We also obtain data through technological means, such as cookies. This data includes, but is not limited to domain name, IP address, web logs, traffic data and screen content.

 

3.         WHEN IS THE DATA COLLECTED?

 

3.1.    We may collect your Personal Data during the following instances:

 

(a)              You share your data with us;

 

(b)              You create an account on the Platform;

 

(c)              You avail the services;

 

(d)              You use the Platform;

 

(e)              You purchase any of the Leadup Products;

 

(f)                You participate in our marketing activities of whatsoever nature; and

 

(g)              You engage in a conversation with us or our representatives in any form whatsoever.

 

4.         HOW DO WE USE AND PROCESS YOUR DATA?

 

4.1.    We at all times use and process your data in accordance with the applicable laws.

 

4.2.    We will only use and process Personal Data if such and use and processing falls under one of the purposes stated herein below:

 

(a)              For compliance with all applicable legal or contractual obligations;

 

(b)              By obtaining your consent. If such consent is obtained, we reserve the right to use the Personal Data for such purposes for which we have been authorized. You may withdraw such consent at any time;

 

(c)              For the purposes of securing any legitimate interest of our own or our partners. However, we use reasonable efforts to ensure that such interests have greater weightage than your data protection rights;

 

(d)              If it is necessary for us to use and/or process the Personal Data to sell or market you the services through the Platform; or

 

(e)              For the purposes of securing any substantial public interest, such as prevention of harm, fraud or any other illegal activity.

 

4.3.    Subject to clause 4.2 of this Privacy Policy, we reserve the right to use and process the Personal Data as follows (this is a non-exhaustive list):

 

(a)              For your identity verification;

 

(b)              Conduct screenings (if required);

 

(c)              Creation of accounts on the Platform;

 

(d)              Compliance with legal, tax and regulatory obligations;

 

(e)              To ensure that all our obligations and responsibilities are properly complied with;

 

(f)                To ensure that reasonable access of the Platform and the Leadup Products are provided to all the users;

 

(g)              For the purposes of advertising the Platform and the products therein;

 

(h)              To apprise you with the details of the Leadup Products, and details in relation to advertising and marketing of the Platform (such as sending news-letters and emails);

 

(i)                For analysis and evaluation of the performance of the Platform and the Leadup Products therein, understand your requirements and needs and to ensure that better services and products can be provided from time to time;

 

(j)                To ensure that you can use the interactive features of the Platform; and

 

(k)              Disclosure to third parties when required.

 

5.         YOUR CHOICES AND RIGHTS

 

5.1.    You may choose to restrict our access to Personal Data by:

 

(a)              Disabling the cookies from your browser;

 

(b)              Withhold or not providing us the Personal Data;

 

(c)              Withdrawing your consent, wherever you have provided us the consent to use, access and process the Personal Data;

 

(d)              Requesting us to not use the Personal Data for any purposes of marketing.

 

5.2.    However, please note that restricting such access will negatively impact the experience of your usage of the Platform and the Leadup Products, particularly those parts which specifically require us to use, access or process your Personal Data.

 

5.3.    You may further exercise the following rights related to the Personal Data we use, collect and process:

 

(a)              Rights to access: All Personal Data retained by us can be accessed by you.

 

(b)              Rights to rectify: You can update all Personal Data through your account on the Platform. However, there may be certain data which may be restricted for rectification. Please contact us if you wish to rectify such data.

 

(c)              Rights to receive: You can request us to send you Personal Data that have been provided to us. Such data can be provided in a machine-readable format.

 

(d)              Right to object: In the event you do not wish for us to process your Personal Data, you have the right to object by providing specific reason as to why such data shall not be processed. We will entertain the objections unless we can substantiate that the use of Personal Data is necessary or falls within one of the grounds specified in clause 4 of the Privacy Policy.

 

(e)              Right to erasure: You may request us to completely erase your Personal Data from our records if you have reasonable grounds to believe that such data has been used in non-compliance of this Privacy Policy or other applicable laws. However, please note that you cannot exercise this right when we are under a legal obligation to retain the data.

 

6.         SECURITY OF DATA

 

6.1.    During the collection and retention of Personal Data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access and disclosure.

 

6.2.    Notwithstanding the above, please note that no method of electronic transmission or storage is 100% secure. Therefore, no one can guarantee absolute security. We disclaim liability for data breaches which are beyond our reasonable control.

 

7.         DATA RETENTION

 

Your Personal Data is only retained by us as long as we are required to do so. Such duration may depend on the nature of the Personal Data and the purpose for which it is retained. If the Personal Data is no longer required, it will be deleted. However, if necessary, we may retain your Personal Data for compliance with legal, accounting or reporting obligations.

 

8.         THIRD PARTY DISCLOSURES

 

8.1.    We may need to disclose Personal Data to various third parties in order to provide, improve and promote the Platform and Leadup Products therein. Such third parties may include, but is not limited to our suppliers (such as web-hosting companies, social media companies, search engines, financial institutions, auditors, lawyers etc.), agents, contractors, employees, customers, law enforcement agencies and other relevant regulatory authorities. Third party disclosures apply to all users.

 

8.2.    In the event our business is sold to another individual or entity, or we undergo a reorganization which includes but is not limited to any legal merger, acquisition and scheme of amalgamation, you agree that your Personal Data may be transferred to any such reorganized entity.

 

8.3.    Your Personal Data may need to be transferred to countries outside if required. We ensure that such transfer complies with all applicable laws.

 

9.         AMENDMENTS AND SUPPLEMENTS

 

9.1.    We reserve the right to change or modify this Privacy Policy at any time without prior notice. The updated version will be posted on the Platform. Please make sure to familiarize yourself with the latest version.

 

9.2.    This Privacy Policy may be supplemented by additional policies if needed.

 

10.      FURTHER INFORMATION

 

If you have any queries regarding this Privacy Policy and the contents therein, we would be happy to address those. Please contact us using the contact details

 

11.      CONTACT US

 

If you have any queries or concerns, you can reach out to us through at support@leadupsystem.com.