Privacy | Millipede.Sg

Millipede Platform Privacy Policy

Updated 30 August 2023

Millipede Pte Ltd (“Millipede”, “we” or “us”) is committed to protecting and respecting your privacy. This document (“Privacy Policy”) governs Millipede’s collection, use, processing, disclosure and transfer of your personal data in connection with your use of the Millipede Platform. This Privacy Policy forms an integral part of our Terms of Use which can be accessed at https://www.millipede.sg/terms-of-use. Capitalised terms used but not defined herein shall have the same meaning given to them in the Terms of Use unless the context requires otherwise. Please carefully read this Privacy Policy so that you are fully aware of how and why we are using your personal data. By accessing and using the Millipede, you consent to the collection, use, processing, disclosure and transfer of your personal data under this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Millipede Platform.

We reserve the right to modify, alter, add to or otherwise vary this Privacy Policy at any time, at our sole discretion. We will use commercially reasonable efforts to generally notify you of any material modifications to this Privacy Policy, and your acknowledgment of such notification shall constitute your acceptance of the modified Privacy Policy in full, the terms of which shall be binding on you. If you do not acknowledge the modified Privacy Policy, you will not be able to use the Millipede Platform. We will also post the modified Privacy policy online so that it is readily accessible to Users, and update the “Last Updated” date at the top-right corner hereof to reflect the effective date of this Privacy Policy. Please check this Privacy Policy regularly to ensure you are aware of this Privacy Policy in force at any point of time.

This Privacy Policy applies only to information we collect through our Millipede Platform and in email, text and other electronic communications in connection with our Millipede Platform. This Privacy Policy does not apply to information collected by any third party. When you click on links on our Millipede Platform, you may leave our interface. We are not responsible for the privacy practices of other interfaces, and we encourage you to read their privacy policies carefully.

1. Personal data that we may collect from you

“Personal data” means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which Millipede has or is likely to have access. This may include your full name, government identification number (NRIC or passport), photograph or video image of you, mobile telephone number, email address, residential address, and any other similar information about you which may be used to identify you. It does not include data where the data has been anonymised such that you can no longer be identified.

Such personal data about you may be collected and processed when you:

(a) are registered as a User by the Client who provides us with your profile information;

(b) exchange emails, telephone conversations or other electronic communications with our employees and other staff members. Our information technology systems may record details of those conversations, sometimes including their content for service improvement or other purposes;

(d) visit our physical premises which may have in place closed circuit television systems and other similar security and access management systems for security and safety purposes;

(e) visit any links on the Millipede Platform to websites of third parties that are not affiliated to Millipede. In such instances, we will not be responsible for the way such third parties collect and process your personal data and the types of personal data collected and processed;

(f) participate in surveys or fill in forms on the Millipede Platform;

(g) provide feedback to Millipede; and

(h) submit your personal data to us for any reason other than as set out above.

We generally also collect personal data from the Client. Please ensure that such personal data is accurate and complete.

As you use our Millipede Platform, certain non-personally identifiable information about yourself may be collected:

(i) Real-time Location: Information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data;

(ii) Videos, Images and Audio: Information about the videos, images and audio that you may upload or otherwise provide to the Millipede Platform; and

(iii) Application Activity Information: Actions that you take on our Millipede Platform.

Please note that we may also collect your personal data from third party data providers who may have obtained your personal data from you and who are permitted to share your personal data with us or via publicly available sources for the purposes of conducting any anti-money laundering, import and export control, credit rating background checks and for other similar legal and regulatory purposes.

2. How we use your personal data

We use the information we receive and collect generally for the purposes of: (a) providing, promoting, maintaining, personalizing and improving our services relating to the Millipede Platform; (b) developing new services; and (c) protecting Millipede, the Millipede Platform and other platforms of Millipede.

We may collect, use and/or disclose your personal data for the following purposes:

(a) to verify your identity and ensure that you are eligible to access and use the Millipede Platform;

(b) to evaluate whether to, temporarily or permanently, suspend, revoke, or terminate your account;

(d) to convert such personal data to anonymised data for the purposes of analytics, business intelligence and statistical research;

(e) to provide support and information for internal operations in connection with the Millipede Platform, including troubleshooting, data analysis, testing, research, statistical analysis, and survey purposes;

(f) to provide services offered by us or perform obligations under any contracts entered into with you or the Client;

(g) to support the functions of the Millipede Platform;

(h) to operate, maintain and improve the Millipede Platform, including but not limited to its content, appearance, design, functions, features and/or utility;

(i) to conduct record keeping, including but not limited to for audit, accounting, administration and risk management purposes;

(j) to facilitate accounting, billing and payment services;

(k) to market and promote the Millipede Platform;

(l) to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);

(m) to enforce our Terms of Use, and other guidelines and policies applicable to the Millipede Platform;

(n) to understand how you use the Millipede Platform and improve or customise your experience on the Millipede Platform;

(o) to keep you informed and updated on updates to the Millipede Platform, the Terms of Use, this Privacy Policy, and/or other relevant services you may be interested in;

(p) to solicit your feedback;

(q) to manage your relationship with us;

(r) to find out your emergency contact;

(s) to respond to, handle and/or process enquiries, requests, complaints, and feedback;

(t) to help us detect and combat abuse, harmful activity, fraud, spam and illegal activity on the Millipede Platform;

(u)to protect Millipede from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes;

(v) to conduct investigations and proceedings in the event of any disputes, possible fraud, misconduct, unlawful action or omission;

(w) to respond to requests for information from government or public agencies, ministries, statutory boards or other similar authorities or non-government agencies authorised to carry out specific government or regulatory services or duties;

(x) to comply with our legal and regulatory obligations and bring and defend legal claims and assert legal rights;

(y) any other incidental business purposes related to or in connection with the above; and

(z) any other specific purposes which we may inform you of in writing from time to time, but for which we will seek your separate consent.

The above mentioned purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

We may from time to time review your information held by us for compliance and business-protection purposes as set out above and for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. These disclosures and/or reviews will be conducted in a reasonable and lawful manner and approved by the relevant management committee within Millipede. In this regard, information may be disclosed to governmental agencies and litigation counterparties to the extent reasonably required and where necessary, such information may be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes.

We will only process your personal data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal data, as further set out in Paragraph 6 of this Privacy Policy.

3. Protection of personal data

We have put in place appropriate and reasonable security measures (including where appropriate, physical, administrative, procedural and information and communications technology measures) to prevent:

unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of personal data, or other similar risks; and

the loss of any storage medium or device on which personal data is stored.

That being said, we cannot guarantee the security of your personal data transmitted vi a the Millipede Platform and any transmission is made at your own risk. Millipede is also not responsible in any way for the security and/or management of personal data shared by you with third party websites accessible via links on the Millipede Platform.

4. Retention of personal data

We retain your personal data for as long as reasonably necessary to operate the Millipede Platform and for the purposes described in Paragraph 2 of this Privacy Policy, unless a longer retention period is required or permitted by law. After such time, we shall take reasonable effort to destroy or anonymise documents containing your personal data, or remove the means by which your Personal Data can be associated with particular individuals. Without prejudice to the foregoing, we retain your personal data:

as long as your account is active and for a reasonable period thereafter in case you decide to reactivate your account;

as long as necessary to allow other Users to make full use of the Millipede Platform;

as long as required by the Client;

as long as needed in order to comply with our legal and contractual obligations; and

where retaining your personal data is advisable to safeguard or improve our legal position (for instance in relation to statutes of limitations, security, litigation or regulatory investigations).

The retention periods for your personal data may be different depending on the applicable criteria, such as the type of personal data in question and the purposes for which such data is used. The appropriate and reasonable retention period of your personal data will be determined by Millipede and may be revised from time to time. Where such retention period expires, we will dispose of or destroy your personal data (in physical or electronic form) in a proper and secure manner.

5. Sharing and transfer of personal data

We may from time to time, share your personal data with related entities of Millipede and other third parties, including but not limited to business partners, suppliers, vendors, consultants, agencies, customers, consumers, governmental bodies, courts, supply and service providers. We will only share personal data that is relevant and necessary for the purposes described in Paragraph 2 of this Privacy Policy.

We may from time to time transfer your personal data to the related entities of Millipede for the purposes described in Paragraph 2 of this Privacy Policy, as well as to contractors and sub-contractors for storage and service purposes. Your personal data will not be disclosed to any such persons or entities unless permitted or otherwise required under applicable laws, and where necessary, your personal data will be disclosed with the appropriate written assurances from the relevant third parties who guarantee that they will protect your personal data with an adequate level of protection that is no less stringent than the level of protection afforded under data protection laws applicable to us in Singapore.

We may, in the course of providing services to you, disclose, transfer, store, process and/ or deal with your personal data outside of Singapore. In doing so, we will take step s to ensure that your personal data continues to receive adequate protection that is no less stringent than the level of protection under data protection laws applicable to us in Singapore.

6. Disclosure of personal data

Without prejudice to the foregoing, we may also disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

(a) the disclosure is required based on the applicable laws and/or regulations, which can include providing information as required by a court order;

(b) the purpose of such disclosure is clearly in your interests and consent cannot be obtained in a timely way;

(c) the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;

(d) there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practical, notify you of the disclosure and the purposes of the disclosure;

(e) the disclosure is necessary for any investigation or proceedings;

(f) the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the office;

(g) the disclosure is to a public agency and such disclosure is necessary in the public interest; and

(h ) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Millipede’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data maintained on our Millipede Platform is among the assets transferred.

7. Accuracy and correction of personal data

We generally rely on personal data provided by you or the Client. Please ensure that such personal data is accurate and complete.

You have the right to request for corrections to your personal data if you find that your personal data held by us is inaccurate or incomplete. In order to process your correction request expeditiously, please kindly include the necessary identification details with your correction request together with any other information that may be necessary to facilitate the correction.

Please update us of changes and/or corrections to your personal data by submitting your updated particulars to our Data Protection Officer at privacy@millipede.sg.

8. Withdrawal of consent

You have the right to withdraw your consent and restrict us from collecting and/or processing your personal data for certain purposes or in certain ways (e.g., sharing and/or transferring your personal data to related entities of Millipede, other third parties, and contractors and sub-contractors), subject to applicable laws. If you wish to withdraw consent, you should give us reasonable advance notice (depending on the complexity of the request and its impact on our relationship with you). Your request for withdrawal of consent can take the form of an email to our Data Protection Officer at privacy@millipede.sg.

Please note that there are consequences flowing from your request for withdrawal of consent. Accordingly, following the submission of your request for withdrawal, we will advise you on the likely consequences or effect of your request.

9. Exercise of rights

In addition to this Privacy Policy and subject to applicable local laws, you have the following rights in relation to the personal data that we hold about you:

to access your personal data;

to obtain information about the ways in which your personal data held by us has been or may have been used or disclosed by us in the year preceding the request;

to update or make corrections to your personal data held by us;

to object to our use of your personal data for the purposes described in Paragraph 2 of this Privacy Policy; and

to require us to transmit your personal data directly to another person or organisation where it is technically and reasonably feasible to do so.

If you wish to exercise any of these rights (subject to applicable local laws), or have feedback relating to our collection, use and/or disclosure of your personal data, please write to our Data Protection Officer at privacy@millipede.sg.

Please note that to respond to your request, we may need to verify your identity by checking your legal identification document (e.g., NRIC). We will endeavour to respond to your request as soon as possible. If we are unable to respond to you within thirty (30) days from the date of your request, we will inform you accordingly and provide an estimate of how much longer we require to process your request. We reserve the right to charge a reasonable fee for the handling and/or processing of access requests.

Should you have any questions about this Privacy Policy, please feel free to write to our Data Protection Officer at privacy@millipede.sg. Thank you for all that you do!