Hmlet | App Privacy Policy
Privacy Policy
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE/APPLICATION.
PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE/APPLICATION.
1.1HMLET PTE. LTD. is a Private Limited Company incorporated under the laws of the Territory with registration number 201723163W (“Hmlet”).
1.2HMLET PTE. LTD.'s registered address is 7C Boon Tat Street Singapore 069614.
1.3HMLET PTE. LTD. is committed to protecting and respecting your privacy when you use our website at hmlet.com (the “Site”) and/or any application made by HMLET PTE. LTD. (the “Online Tools”).
2.WHO WE ARE2.WHO WE ARE
2.1The Hmlet Group is made up of a mix of companies set up as different legal entities.
2.2We will let you know with which entity you have a relationship with when you engage with a particular entity.
2.3You can find out more about the Hmlet Group at hmlet.com.
3.SCOPE OF PRIVACY POLICY3.SCOPE OF PRIVACY POLICY
3.1This privacy policy (the "Privacy Policy") applies to:
a.any users of the Online Tools;
b.any users of HMLET PTE. LTD.’s services; and
c.anyone who contacts or otherwise submits information to HMLET PTE. LTD. via the Online Tools.
4.PRIVACY POLICY4.PRIVACY POLICY
4.1This Privacy Policy sets out the basis upon which HMLET PTE. LTD. will process any Personal Information that HMLET PTE. LTD. collects from you, or that you provide to HMLET PTE. LTD..
4.2Please read this Privacy Policy carefully to understand HMLET PTE. LTD.’s views and practices regarding your Personal Information and how HMLET PTE. LTD. will treat it.
4.3By accessing and using the Online Tools and/or providing us with Personal Information, you acknowledge and agree that you:
a.understand and unconditionally accept and agree to this Privacy Policy; and
b.consent to HMLET PTE. LTD. processing / using your Personal Information in the manner set out in this Privacy Policy.
4.4If you do not accept and agree to this Privacy Policy, please do not provide your Personal Information to HMLET PTE. LTD. and do not interact with or use the Online Tools.
4.5HMLET PTE. LTD. recommends that you print a copy of this Privacy Policy for future reference.
5.OUR PROMISE5.OUR PROMISE
5.1We promise:
a.to keep your Personal Information safe and private;
b.unless otherwise agreed with you, not to sell your Personal Information; and
c.to give you ways to manage and review your choices regarding Personal Information usage restrictions at any time.
6.PERSONAL INFORMATION WE COLLECT6.PERSONAL INFORMATION WE COLLECT
6.1HMLET PTE. LTD. may collect Personal Information including:
a.your full name;
b.your email address;
c.your phone number and/or mobile number;
d.your birthdate;
e.ID / Passport Details;
f.any other information we may request from you from time to time.
7.WHERE WE COLLECT PERSONAL INFORMATION FROM7.WHERE WE COLLECT PERSONAL INFORMATION FROM
7.1HMLET PTE. LTD. may collect Personal Information when:
You give us data, including:
a.when you talk to us on the phone;
b.when you send us emails or letters;
c.when you take part in our competitions or promotions;
d.when you create or update your account with HMLET PTE. LTD.;
e.when we conduct background checks;
f.when you request services through the Online Tools;
g.when you access third party products and services through the Online Tools;
h.when you contact HMLET PTE. LTD., for example to provide feedback or to request for assistance;
i.when you contact other users through HMLET PTE. LTD.’s services;
j.when you complete surveys sent to you by HMLET PTE. LTD. or on its behalf;
k.when you enable features that require HMLET PTE. LTD.’s access to your address book or calendar;
l.when you provide HMLET PTE. LTD. with payment information;
m.when you provide HMLET PTE. LTD. with a crypto-currency wallet address(es);
n.when you provide HMLET PTE. LTD. with access to your public profiles (e.g. Facebook);
o.when you enable features or utilise services requesting location data;
You use Our services / Online Tools, including
q.your precise or approximate location information as determined through data such as GPS, IP address, Wifi and any other location-based technology we may use;
r.information about transactions made via use of the Online Tools;
s.information about how you interact with our services and third party products and services through our Online Tools, including preferences expressed and settings chosen;
t.Access Device Information;
u.Usage Information;
We receive data from other sources, including
v.payment service providers;
w.financial service providers;
x.insurance providers;
y.analytics providers;
z.search information providers;
aa.other users of our services and/or third party products and services provided through the Online Tools; and/or
bb.other third parties.
8.YOUR PROTECTIONS UNDER THE LAW8.YOUR PROTECTIONS UNDER THE LAW
8.1As well as under this Privacy Policy, the privacy of your Personal Information is protected by law in relevant jurisdictions. This Clause 8 explains generally how that works.
8.2The EU General Data Protection Regulation (“GDPR”) specifies that a data controller is only allowed to use your Personal Information if it has a proper reason to do so. This includes sharing it outside of the data controller’s organisation.
8.3Whilst we may operate outside of the European Union, we have chosen to generally align with the standards of the GDPR.
9.HOW WE USE DATA / INFORMATION9.HOW WE USE DATA / INFORMATION
9.1HMLET PTE. LTD. may use information held about you in the following ways:
a.to carry out HMLET PTE. LTD.’s obligations and to provide you with the information and/or services that you request from HMLET PTE. LTD.;
b.to provide you, or permit selected third parties to provide you with information about services HMLET PTE. LTD. offers or feels may interest you;
c.to notify you about changes to HMLET PTE. LTD.’s services;
d.to ensure that content from the Online Tools is presented in the most effective manner for you and for your device;
e.to administer the Online Tools and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
f.to allow you to participate in interactive features of the Online Tools, when you choose to do so;
g.as part of HMLET PTE. LTD.'s efforts to maintain the safety, security and integrity of HMLET PTE. LTD.’s Online Tools and services;
h.to deliver relevant advertising to you and measure or understand the effectiveness of the same;
i.to provide appropriate assistance to you when you contact HMLET PTE. LTD.’s customer support;
j.for testing, research, analysis and product development;
k.to comply with our legal and regulatory obligations;
l.to verify information you have provided to us for our “Know Your Client” purposes;
m.where we have a Legitimate Interest; and
n.to investigate or address claims or disputes relating to your use of HMLET PTE. LTD.’s services and/or the Online Tools in accordance with Applicable Law.
9.2If you have any questions or want more details about how we use your Personal Information, you can ask us via email at hello@hmlet.com.
10.LEGITIMATE INTEREST10.LEGITIMATE INTEREST
10.1In relation to Clause 10, our reasons for which we may use your Personal Information include where:
a.we have your consent;
b.we are fulfilling a contract with you;
c.we are under a legal duty to do so (e.g. KYC); and/or
d.we have a Legitimate Interest to do so.
10.2For the purposes of this Privacy Policy, “Legitimate Interest” means where we believe that processing your Personal Information is necessary for:
a.keeping our records up to date;
b.working out which of our products and services may interest you and telling you about them;
c.developing products and services, and what we charge for them;
d.defining types of customers for new products or services;
e.seeking your consent when we need it to contact you; or
f.complying with Applicable Law and rules and guidance from regulators.
11.DISCLOSURE OF YOUR DATA / INFORMATION11.DISCLOSURE OF YOUR DATA / INFORMATION
11.1HMLET PTE. LTD. may share/disclose your information with selected third parties and in certain circumstances, including:
a.people who HMLET PTE. LTD. works with, including affiliates, employees, suppliers and sub-contractors to deliver your services and for the performance of any contract HMLET PTE. LTD. enters into with you;
b.advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
c.analytics and search engine providers that assist HMLET PTE. LTD. in the improvement and optimisation of the Online Tools;
d.where HMLET PTE. LTD. sells or buys any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets;.
e.complying with Applicable Law and rules and guidance from regulators.
f.in order to enforce or apply any of HMLET PTE. LTD.’s terms and conditions; and/or
g.to protect the rights, property or safety of any of HMLET PTE. LTD.’s employees or customers.
12.WHERE WE STORE YOUR PERSONAL DATA / INFORMATION12.WHERE WE STORE YOUR PERSONAL DATA / INFORMATION
12.1The information that we collect from you may be transferred to, and stored at, a destination outside of the Territory.
12.2Your information may be processed by people outside of the Territory who work for HMLET PTE. LTD. or for one of our suppliers, pursuant to a data processing agreement entered into with us, which is compliant with this Privacy Policy.
12.3Such staff may be engaged in, among other things:
a.the provision of services;
b.the processing of your payment details; and/or
c.the provision of support services.
12.4By submitting your information, you agree to the information transfer, storing or processing referred to in this Privacy Policy.
12.5Unfortunately, the transmission of information via the internet is not completely secure and any transmission of data/information is at your own risk.
12.6HMLET PTE. LTD. will use reasonable efforts to ensure that your information is treated securely and in accordance with this Privacy Policy.
12.7Notwithstanding Clause 12.5, HMLET PTE. LTD. cannot guarantee the security of your information transmitted to the Online Tools.
12.8Where you have a password which enables you to access certain parts of the Online Tools, you are responsible for keeping that password confidential and agree not to disclose it to anyone.
13.HOW LONG WE KEEP YOUR PERSONAL INFORMATION13.HOW LONG WE KEEP YOUR PERSONAL INFORMATION
13.1We will keep your Personal Information for as long as you maintain an account with HMLET PTE. LTD. or such other period as may be required by Applicable Law.
13.2After you terminate your account with HMLET PTE. LTD., we may keep your Personal Information for up to 10 years (the “Retention Period”) for one of these reasons:
a.to respond to any questions or complaints;
b.to show that we treated you fairly; and/or
c.to maintain records according to rules that apply to us.
13.3We may keep your Personal Information for longer than the Retention Period if we cannot delete it for legal, regulatory, or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure your privacy is protected and only use it for those purposes.
14.IF YOU CHOOSE NOT TO GIVE US PERSONAL INFORMATION14.IF YOU CHOOSE NOT TO GIVE US PERSONAL INFORMATION
14.1We may need to collect Personal Information as required by Applicable Law, or to enter into or fulfil a contract we have with you.
14.2If you choose not to give us this Personal Information, it may:
a.delay or prevent us from fulfilling a contract we have with you;
b.delay or prevent us from doing what we must do by Applicable Law;
c.mean that we cannot run your accounts and/or policies; and/or
d.mean that we decide to cancel any account you have with us.
14.3We sometimes ask for information that is useful, but not required by Applicable Law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won't affect the products or services you have with us.
15.HOW TO GET A COPY OF YOUR PERSONAL INFORMATION15.HOW TO GET A COPY OF YOUR PERSONAL INFORMATION
15.1You can obtain a copy of your Personal Information that we hold by writing to us at hello@hmlet.com.
16.HOW TO CORRECT YOUR PERSONAL INFORMATION16.HOW TO CORRECT YOUR PERSONAL INFORMATION
16.1You have the right to question any Personal Information that we have about you, which you think is wrong or incomplete. Please contact us at hello@hmlet.com if you want to do this.
16.2Where you submit a request pursuant to Clause 16.1, we will take reasonable steps to check the accuracy of your Personal Information and make any necessary corrections.
17.REQUESTING THAT WE CEASE USING YOUR PERSONAL INFORMATION17.REQUESTING THAT WE CEASE USING YOUR PERSONAL INFORMATION
17.1You have the right to object to our use of your Personal Information, or to ask us to delete, remove or stop using your Personal Information.
17.2We want you to tell us if you think that we should not be using your Personal Information. But please note there may be legal or other official reasons why we need to still retain and/or use your Personal Information and that we reserve our rights as per Clause 13.
17.3We may sometimes be able to restrict the use of your Personal Information. This means that the Personal Information would only be used for certain things, such as legal claims or to exercise legal rights.
17.4Where Clause 17.3 applies, we would not use or share your Personal Information in other ways while it is restricted.
17.5You can ask that we restrict the use of your Personal Information if:
a.it is not accurate;
b.it has been used unlawfully but you do not want us to delete it;
c.it is not relevant anymore, but you want us to keep it for use in legal claims; or
d.you have already asked us to stop using your Personal Information but you are waiting for us to tell you if we are allowed to keep on using it.
17.6HMLET PTE. LTD. will usually inform you (before collecting your information) where it intends to:
a.use your data for marketing purposes; or
b.disclose your information to others for marketing purposes.
17.7If you want to object to how we use your Personal Information or ask us to delete it or restrict how we use it, please contact us at hello@hmlet.com.
18.THIRD PARTY WEBSITES18.THIRD PARTY WEBSITES
18.1The Online Tools may, from time to time, contain links to and from third party websites.
18.2If you follow a link to/from any third party websites, you do so at your own risk, and subject to whatever privacy policy/website terms that govern the use of such websites.
18.3HMLET PTE. LTD. does not accept responsibility or liability for the content of third party websites, or any information you provide to them.
19.CHANGES TO OUR PRIVACY POLICY AND YOUR ACCEPTANCE19.CHANGES TO OUR PRIVACY POLICY AND YOUR ACCEPTANCE
19.1Any changes HMLET PTE. LTD. may make to this Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes.
19.2Your continued use of the Online Tools will confirm your understanding and acceptance of this Privacy Policy and any changes made to it from time to time.
20.HOW TO WITHDRAW YOUR CONSENT20.HOW TO WITHDRAW YOUR CONSENT
20.1You can withdraw your consent to this Privacy Policy at any time. Please contact us if you wish to do so. You can contact us at hello@hmlet.com.
20.2If you withdraw your consent, you acknowledge and agree that you are required to cease using the Online Tools and that we may no longer be able to provide or enable the provision of any certain products or services to you.
21.HOW TO COMPLAIN21.HOW TO COMPLAIN
21.1Please let us know if you are unhappy with how we have used your Personal Information. You can contact us at hello@hmlet.com.
22.CONTACT22.CONTACT
22.1You also have the right to complain to a relevant privacy regulator, and to potentially lodge an appeal if you are not happy with the outcome of a complaint. We hope that that won’t be ever required though.
22.2Any other questions, comments and requests regarding this Privacy Policy should also be sent to hello@hmlet.com.
23.DEFINITIONS23.DEFINITIONS
23.1For the purposes of this Privacy Policy, the following terms shall have the following meanings:
Access Device Informationmeans technical information about the devices you use to access HMLET PTE. LTD.’s services, including hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information and mobile network information;
Applicable Lawmeans all national, state, local, municipal legislation, regulations, statutes, by-laws, approvals and/or other laws and any other instrument having the force of law as may be issued and in force from time to time (and any amendment or subordinate provisions) relating to, or connected with, the activities contemplated under this Privacy Policy wherever so located or performed;
Personal Informationmeans data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, HMLET PTE. LTD.’s possession;
Usage Informationmeans information about your use of the Online Tools, including your device IP address, access dates and times, app features or pages viewed, application crashes and other system activity, type of browser, and the third party site or service you were using before interacting with the Online Tools; and
Territorymeans Singapore.
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HMLET
Hmlet HQ
7C, Boon Tat Street,
Singapore 069614
© 2019 Hmlet. All Rights Reserved.

"Supported by Global Legal Solutions - the Start-Ups' Law Firm"

HMLET
Hmlet HQ
7C, Boon Tat Street,
Singapore 069614
Privacy. Terms & Conditions. © 2019 Hmlet. All Rights Reserved.

"Supported by Global Legal Solutions - the Start-Ups' Law Firm"