This policy describes the types of information we may collect from you or that you may provide when you access or use the Site, the Applications, the Products, the Photo Services and the other TSBC Services or other features, functions, services or products and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect or may collect:
- In accessing and using the Site or Virtual Web applications.
- In registering to use the Photo Services and the other TSBC Services.
- In accessing and using the Applications, the Photo Services and the other TSBC Services.
- In e-mail, text and other electronic messages sent on or through any of the TSBC Services.
- When you interact with other users of the TSBC Services.
- When you send any content, including photographs, on or through any of the Photo Services or the other TSBC Services.
- When you interact with our advertising and applications on third-party websites and services.
- Through services provided to us by third-party companies, agents or contractors.
It does not apply to information collected by:
- Offline or through any other means, including on any other website operated by TSBC or any third party; or
- Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site, the Applications, the Photo Services or the other TSBCServices.
Minors under the Age of 13
None of the TSBC Services is intended for minors under 13 years of age. If you are below the ages of 13, you may only use the TSBC Services under the supervision of a parent or legal guardian who agrees to be bound by these Terms. No one under age 13 may provide any information on or through the Site, the Applications, the Photo Services or the other TSBC Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of the TSBC Services or any of its features or register on the Site or the Applications, use any of the interactive or public comment features of the Photo Services or the other TSBC Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
Information We Collect About You and How We Collect It
We collect or may collect several types of information from and about users of the Site, the Applications, the Products, the Photo Services and the other TSBC Services, including:
- Information by which you may be personally identified, such as photographs (the “Photos”), name, company name, postal address, date of birth, mobile phone number and e-mail address (“personal information”).
- Information that is about you but individually does not identify you, such as IP address and date and time of visit, device information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information. Analytics or usage information and details such as when you use the Site or any of the other TSBC Service, your search queries on or through any of the TSBC Services, information about your internet and mobile connections, IP addresses and information collected through cookies, web beacons and other tracking technologies and location data.
- The content you provide, including any Photos, comments or postings through the Site and Applications and information about that content, such as if the recipient has viewed the content, replayed the content, interactions with the content, logs of users that accessed the content and metadata or statistics associated with the content.
- Information that you provide by registering or filling in forms, surveys, questionnaires on or through the Site or the Applications for research, marketing and other purposes. This includes information provided in connection with registering to access and use the Applications, the Photo Services and the other TSBC Services, posting notes, photos, comments and other information in connection with the Photo Services or otherwise or requesting further services or products. We may also ask you for information when you report a problem with the Site, the Applications, the Photo Services or any of the other TSBC Services.
- Records and copies of your correspondence (including e-mail addresses), if you contact us.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through or use the Site, the Applications, the Products, the Photo Services and the other TSBC Services.
- From third parties, such as other Users and our customers, business partners and other third parties that provide us or you with certain services.
Now or in the future you may also be able to provide Photos, notes, audio and video recordings, text, data, information and other input or any other content linked, posted, and/or submitted by you or other users in connection with the Photo Services to be published or displayed (hereinafter, “posted”) on the Site or the Applications, or transmitted to other users of the TSBC Services or third parties (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site, the Applications, the Photo Services or the other TSBC Services, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded or shared by unauthorised persons.
The technologies we use for automatic data collection may include:
- Web Beacons. Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit TSBC, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Do Not Track Policy
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honour any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services.
Third-party Responsibilities and Services.
We may use or partner with other third party companies for various purposes in connection with our business and operations (“Service Providers”), including, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analysing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. Many Services Providers have adopted their own privacy policies, which are not subject to control by TSBC. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information.
The Service Providers may also transmit cookies to your computer or device, when you click on ads that appear on or through the TSBC Services. Also, if you click on a link to a third party website, such third party may also transmit cookies to you. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left all of the TSBC Services, and those third parties may not honour “Do Not Track” requests you have set using your web browser.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To provide you the Photo Services that you request from us.
- To provide you the Virtual Web Applications and the other TSBC Services and the content and the other products and services that you request from us.
- To provide the Site and its contents to you.
- To provide technical and other support to you.
- To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers and events; and providing other news or information about us, our users, our customers and our select partners. You must opt-in to receive any of these communications. Notwithstanding the foregoing, if you have created an account with respect to the Photo Services, we may send you general information about licenses to use the Photo Services and the other TSBC Services without your opting-in to receive such information.
- To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.
- To fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to the Site, the Applications, the Photo Services or the other TSBC Services and other products and services we offer or provide though them.
- To allow you to participate in interactive features on or through any of the TSBC Services.
- To personalise the services by, among other things, providing advertisements, content, or features that match user profiles, interests, or previous activities.
- To enhance the safety and security of the TSBC Services.
- To verify your identity and prevent fraud or other unauthorised or illegal activity.
- To enable marketing, remarketing, targeted advertising and similar services from Service Providers, including direct and indirect marketing and on-line behavioural advertising regarding our own and third party products and services that we believe may be of interest to you, advertising on third party websites.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
The information that we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties or you provide to us. It helps us to improve the TSBC Services and to deliver a better and more personalised service, including enabling us to:
- Estimate our audience size and better understand usage patterns.
- Store information about your preferences, allowing us to customise the Applications and the Site according to your individual interests.
- Speed up your searches.
- Recognise you when you return to the Site or the Applications.
We may store any information that we collect (personal or otherwise) ourselves or in databases owned and maintained by our affiliates, agents or service providers. If you use the Site, the Applications, the Photo Services or the other TSBC Services outside of the Singapore, information that we collect about you may be transferred to servers inside the Singapore and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by TSBC and you. By allowing TSBC to collect information about you, you hereby consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Applications and the Site and view content faster.
Although users from all over the world may access the Site, the Applications, the Photo Services and the other TSBC Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the Singapore and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.
Use of the Photos
TSBC uses your Photos to provide the Photo Services and other related ancillary purposes. You can withdraw your consent to the use of your photos at any time and we will delete your photo(s) upon your request by emailing us the unique link to your photo with your request to email@example.com.
TSBC also uses your facial features in the mobile Application to provide the Photo Services. The mobile Application uses geometric points for facial features (such as the eyes, nose, chin or whole face) to determine where to place a digital prop that you have selected with intent to put on your face. The facial data itself is not uploaded to our servers. It is instead converted into placement information for the specific digital prop.
At no time does TSBC use the facial features of participants in Photos for face recognition. The Application does not use any face recognition technology or other technical means for the processing of biometric data for the unique identification of participants in Photos.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To other Users of the Photo Services and the other TSBC Services.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
In addition, we may upload to, or disclose any or all of your Photos on, the Site or any of our social and other networks, including Facebook and Instagram
We may also disclose your personal information:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply the Terms and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TSBC, our customers or others.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Promotional Offers from TSBC. To have your e-mail address/contact information used by TSBC to promote our own or third parties’ products or services, you have to opt-in. This opt-in does not apply to information provided to TSBC as a result of a service or product purchase, warranty registration, product service experience or other transactions.
Accessing and Correcting Your Information
You may send us an e-mail at firstname.lastname@example.org to request access to, change, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
How Long We Store Your Personal Information
We will only retain your personal information, including your Photos, in a form that permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal information, we may anonymise it, delete it or take other appropriate steps. Personal information may persist in copies made for backup and business continuity purposes for additional time.
We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective and TSBC cannot ensure or warrant the security of your personal information. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Site and/or or the use of the Applications, the Photo Services or the other TSBC Services, you are responsible for creating a secure password and keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site and the Applications. The information you share in public areas may be viewed by any user of the Site or the Applications.
Last updated August 3, 2020