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Your privacy is important to us. The purpose of this privacy policy (the “Privacy Policy”) is to inform you of how Rev21 Pte. Ltd. manages personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data (as defined below).

By interacting with us, submitting information to us or signing up for any services offered by us, you agree and consent to Rev21 Pte. Ltd. and its affiliates, (collectively referred to herein as “Rev21”, “us”, “we” or “our”), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to authorised service providers of Rev 1 in the manner contemplated and set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to REV21 (where applicable) nor does it affect any rights which REV21 may have at law in connection with the collection, use or disclosure of your Personal Data.

REV21 may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our website(s). The onus is on you to check regularly for updated information on the handling of your Personal Data. For avoidance of doubt, REV21 holds no responsibility in informing you of the changes or updates to our Privacy Policy as may be updated from time to time.

For avoidance of doubt, this Privacy Policy forms a part of the Website Terms and Conditions (“Website Terms and Conditions”). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, the Privacy Policy shall prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1. Your Personal Data

1.1. In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include:

1.1.1. your name, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

1.1.2. information about your use of our website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that we may identify you from such information; and

1.1.3. your corporate information, [including financial information and profit and loss statements.

2. Collection of Personal Data

2.1. We collect your Personal Data in the following ways:

2.1.1. when you submit forms relating to any of our services;

2.1.2. when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;

2.1.3. when you use some of our services;

2.1.4. when you establish any online accounts with us;

2.1.5. when you request that we contact you;

2.1.6. when you ask to be included in an email or other mailing list; and/or

2.1.7. when you submit your Personal Data to us for any other reason.

2.2. When you browse our website, you generally do so anonymously but please see the section below on cookies policy.

2.3. If you provide us with any Personal Data relating to a third party by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1. We use and disclose your Personal Data for the following purposes:

3.1.1. responding to your queries and requests and responding to complaints;

3.1.2. managing the infrastructure and business operations of REV21 and complying with internal policies and procedures;

3.1.3. matching any Personal Data held which relates to you for any of the purposes listed herein;

3.1.4. verifying your identity;

3.1.5. preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;

3.1.6. protecting and enforcing our contractual and legal rights and obligations;

3.1.7. conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;

3.1.8. compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

3.1.9. any other purpose related to the above.

3.2. REV21 may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

3.2.1. If you have an account with us: to maintain your account with us; to verify your personal particulars and payment in connection with the services pursuant to your membership account; to provide you with the services which you have signed up for; communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the services offered to you; resolving complaints and handling requests and enquiries; and/or the processing of your Personal Data in relation to any of the purposes stated above.

3.3. In addition, where permitted under the Act, REV21 may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

3.4. In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1. We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

4.1.1. Our affiliates;

4.1.2. Our agents, contractors or third party service providers who provide operational services to us;

4.1.3. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;

4.1.4. anyone to whom we transfer or may transfer our rights and duties;

4.1.5. banks and credit companies;

4.1.6. our professional advisors;

4.1.7. relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

4.1.8. any other party whom you authorise us to disclose your personal data.

5. Cookies Policy

5.1. When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.

5.2. We use “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

5.3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

6. Withdrawal, Access and Correction of your Personal Data

6.1. Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in Section 8 below.

6.2. Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.

6.3. Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with us and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.

7. Personal Data Protection Officer

7.1. Thibault Catala –

8. Governing Law

8.1. This Privacy Policy shall be governed in all respects by the laws of Singapore.