Privacy Policy

1. Definitions

1.1 In this Policy: “Vendor” means any person or entity accepted by us to list on the Platform; “user” or “you” means any individual who accesses or uses the Platform, or who has contacted us through any means; and “personal data” means data, whether true or not, about an individual who can be identified (a) from that data, or (b) from that data and other information to which we have or are likely to have access.

1.2 Other terms used in this Policy shall have the meanings given to them in the PDPA, where the context so permits.

2. Personal data we collect

2.1 We collect personal data directly from you when you register an Account, use the Platform, or contact us. The personal data we may collect includes:

• (a)Account registration data: name, username, gender, email address, date of birth, and race and religion (refer to the note at the end of this clause 2);
• (b)Usage data: listings and Content you view, listings you click on, searches you carry out, pages you visit, time spent on the Platform, and your other interactions with the Platform;
• (c)Device and technical data: device type and model, operating system and version, application version, unique device identifiers, Internet Protocol (IP) address, push notification tokens, and crash and error reports;
• (d)Location data: approximate location, which may be derived from your IP address or, where you have given permission, from your device, used to personalise locally relevant content and improve our geographic coverage;
• (e)Communications: messages, enquiries, reports and feedback you send to us;
• (f)Vendor data: where you register or act on behalf of a Vendor, we collect the Vendor’s business name, unique entity number or equivalent registration number, business and operating addresses, and the name, position, telephone number and email address of the Vendor’s contact person or authorised representative, together with such other information and documents as we may require from time to time to verify the Vendor;
• (g)Profile images: where the Platform makes available a feature allowing you to upload a profile image or other image, we collect the images you upload; and
• (h)Payment data: where the Platform offers any paid feature, we collect transaction records for purchases made on the Platform. We do not store your card details. All payment processing is carried out by Monetary Authority of Singapore (MAS) approved and regulated third party payment service providers.

Note on race and religion: providing your race and religion is entirely optional. We use this information solely to understand our community and users, and to deliver relevant services, content and communications. Where we share such information with third parties, we do so only in aggregated form as overall statistics, and no individual is ever identified. Providing this information will not affect your ability to use the Platform in any way, and you may update or remove it at any time in your account settings. Everyone is welcome to use the Platform.

3. Cookies and similar technologies

3.1 The Platform may use cookies and similar technologies which collect data, including personal data, in the ways described below. Please do not use the Platform if you do not wish to have your data collected through such means. You may also be able to disable the operation of these technologies on your device where it is possible to do so.

• (a)Cookies. Cookies allow your browser or device to be recognised. We may use cookies to store and track information such as the number of users, frequency of use, user profiles and online preferences. You may disable cookies through your device or browser settings. However, this may affect your use of the Platform.
• (b)Analytics and similar technologies. We may use analytics tools, tracking links and similar technologies to assess how the Platform is used. This includes analysis of traffic patterns, the frequency of visits to certain parts of the Platform, and which information and services users are most interested in.
• (c)Third party technologies. Certain content or applications on the Platform may be served by third parties. These third parties may use cookies alone or together with other tracking technologies to collect information about you when you use the Platform, and may use that information to provide interest-based or targeted content. We do not control these third parties, their technologies, or how they may use information. If you have any questions about content served by a third party, you should contact that provider directly.

3.2 You can choose to delete cookies at any time. However, you may lose information that enables you to access the Platform more quickly and efficiently, including personalisation settings.

4. Collection, use and disclosure of personal data

4.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly, or by a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”), after (i) you or your authorised representative have been notified of the purposes for which the data is collected, and (ii) you or your authorised representative have provided consent to the collection and use of your personal data for those purposes; or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data, and before using your personal data for a purpose which has not been notified to you, except where permitted or authorised by law.

4.2 We may collect and use your personal data for any or all of the following purposes:

• (a)operating, administering and improving the Platform and its activities;
• (b)communicating with users and with current and prospective Vendors on matters related to them;
• (c)updating your personal and contact information;
• (d)performing obligations in the course of or in connection with our provision of services requested by you;
• (e)verifying your identity, and verifying the identity, registration and eligibility of Vendors;
• (f)responding to, handling and processing queries, requests, applications, complaints, reports and feedback from you;
• (g)managing your relationship with us;
• (h)processing payment or credit transactions, where the Platform offers any paid feature;
• (i)analytics, statistics, planning and reporting, including understanding how the Platform is used and which listings and features are of most interest to users;
• (j)sending you marketing and promotional communications, where you have consented to receive them;
• (k)detecting, preventing and addressing fraud, abuse, security issues, and breaches of our Terms and Conditions, including preventing suspended or banned accounts from being re-created;
• (l)complying with any applicable laws, regulations, codes of practice, guidelines or rules, and assisting in law enforcement and investigations conducted by any governmental or regulatory authority;
• (m)any other purposes for which you have provided the information; and
• (n)any other incidental purposes related to or in connection with the above.

4.3 This Policy does not apply to aggregated information which summarises statistical information about groups of users and which does not include a name, contact information, or any other information that would allow any particular individual to be identified. We may compile, analyse, publish and share such aggregated and anonymised information, including user numbers, listing views, search activity and engagement statistics, with third parties including Vendors, prospective vendors, partners, advertisers, service providers and investors.

4.4 We may disclose your personal data, including but not limited to the following circumstances:

• (a)where necessary to enforce any agreements and terms between us;
• (b)where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you;
• (c)to third party service providers, agents and other organisations we have engaged to perform any of the functions referred to in the purposes above;
• (d)where required by law, or in the good faith belief that such action is necessary to conform to the requirements of the law or comply with legal process served on us or the Platform, to protect and defend our rights or property, or to act under exigent circumstances to protect the personal safety of users of the Platform; or
• (e)where your consent has been obtained for the disclosure.

4.5 Where your use of the Platform is concerned, you acknowledge and accept that certain functions, when activated or used by you, will operate to send or display information about yourself, including certain third parties, and you agree to the sharing of such information with those third parties. You acknowledge and agree that we shall not be held responsible or accountable for any loss, injury or damage sustained by you as a result of sharing such information arising out of your activation or use of such features.

4.6 Without prejudice to the foregoing, we may disclose personal data to any person or entity to whom we are under an obligation or otherwise required to make disclosure pursuant to any applicable laws and regulations, including disclosure to courts, tribunals, and legal, regulatory, tax and government authorities in Singapore or otherwise.

5. Marketing communications

5.1 We will only send you marketing and promotional communications where you have consented to receive them. Every marketing communication we send will include a means of unsubscribing. You may withdraw your consent to receive marketing communications at any time by using that means, by changing your settings on the Platform, or by contacting us at contact@pottu.com.sg.

6. Withdrawing your consent

6.1 The consent you provide for the collection, use and disclosure of your personal data will remain valid until it is withdrawn by you in writing. You may withdraw consent and request that we stop collecting, using or disclosing your personal data for any or all of the purposes listed above by submitting your request by email to our Data Protection Officer at the contact details provided below.

6.2 Upon receipt of your written request to withdraw your consent, we may require some time, depending on the complexity of the request and its impact on our relationship with you, for your request to be processed and for us to notify you of the consequences of acceding to it, including any legal consequences which may affect your rights and liabilities. In general, we shall seek to process your request within ten (10) to twenty (20) calendar days of receiving it.

6.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you, and we shall in such circumstances notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 6.1 above.

6.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

7. Deletion of your account and personal data

7.1 You may request the deletion of your Account and associated personal data by using the account deletion option in the Platform’s settings, or by contacting us at contact@pottu.com.sg.

7.2 Upon receipt of a valid deletion request, we will delete or anonymise your personal data within thirty (30) calendar days, subject to the following:

• (a)we may retain certain data where required by applicable law, including transaction records, which are retained for the period required under Singapore tax and accounting legislation;
• (b)we may retain data where necessary for the establishment, exercise or defence of legal claims; and
• (c)where your Account has been suspended or banned, we retain a record of that suspension or ban, together with the associated email address, in order to prevent the Account from being re-created and to protect the integrity of the Platform.

7.3 Please note that requesting deletion of your Account will result in the permanent loss of access to the Platform and all associated Content and data.

8. Access to and correction of personal data

8.1 If you wish to make (a) an access request for a copy of the personal data which we hold about you, or for information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or by email to our Data Protection Officer at the contact details provided below. Certain details may also be updated directly in your account settings.

8.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

8.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) calendar days. Should we not be able to respond to your request within thirty (30) calendar days after receiving it, we will inform you in writing, within thirty (30) calendar days, of the time by which we will be able to respond.

8.4 If we are unable to provide you with any personal data, or to make a correction requested by you, we shall generally inform you of the reasons why, except where we are not required to do so under the PDPA.

9. Protection of personal data

9.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures.

9.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

9.3 While we take reasonable precautions to safeguard personal data in our possession or under our control, we cannot be held responsible for unauthorised or unintended access that is beyond our control, such as hacking or cybercrime. We do not guarantee that the Platform is invulnerable to security breaches, nor do we make any warranty, guarantee or representation that your use of the Platform is safe and protected from viruses, worms, Trojan horses and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.

10. Data breaches

10.1 In the event of a data breach affecting your personal data, we will assess the breach and, where it is notifiable under the Personal Data Protection Act 2012, notify the Personal Data Protection Commission and affected individuals in accordance with the timeframes and requirements set out in that Act.

11. Accuracy of personal data

11.1 We generally rely on personal data provided by you or your authorised representative. In order to ensure that your personal data is current, complete and accurate, please update your details in your account settings, or inform our Data Protection Officer in writing or by email at the contact details provided below if there are changes to your personal data.

12. Retention of personal data

12.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

12.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.

12.3 Where you have made transactions through the Platform, records of those transactions are retained for the period required under Singapore tax and accounting legislation, notwithstanding the deletion of your Account.

13. Transfers of personal data outside Singapore

13.1 In the course of operating the Platform, your personal data may be transferred to and processed by our service providers and contractors located outside Singapore. These include cloud hosting and infrastructure providers, analytics providers, payment service providers, software development contractors, and other service providers we engage from time to time. Such transfers may involve countries including but not limited to the United States of America, India and Pakistan. We take steps to ensure that any such transfers comply with the PDPA and that your personal data is accorded a standard of protection comparable to that provided under Singapore law.

14. Children

14.1 The Platform is not intended for anyone under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will delete it. A parent or guardian who believes that their child has registered an Account may contact us at contact@pottu.com.sg and we will remove the Account.

14.2 Where the Platform offers any paid feature, you must be at least 18 years of age to make a payment or enter into any purchase.

15. External websites

15.1 The Platform may contain links to external websites and to the websites, social media accounts and messaging services of Vendors. We make no representations as to the quality, suitability, functionality or legality of the material on such external sites, or of any goods and services available from them. The material is provided only for your interest and convenience. We do not monitor or investigate such external sites and we accept no responsibility or liability for any loss arising from the content or accuracy of the material, and any opinion expressed in the material should not be taken as our endorsement, recommendation or opinion. This Policy does not extend to your use of such external sites. You are advised to read the privacy policy or statement of such external sites before using them.

15.2 Where you contact a Vendor directly or engage a Vendor’s goods or services, any personal data that Vendor collects from you is collected by that Vendor in its own right and for its own purposes. That Vendor is independently responsible for complying with the PDPA in respect of that personal data. This Policy does not apply to, and we have no responsibility for, a Vendor’s collection, use or disclosure of your personal data.

16. Language

16.1 This Policy is provided in English only. Where privacy notices, consent requests, settings or other information relating to your personal data are made available on the Platform in Tamil or any other language, that content is provided for convenience only, may be produced using automated or machine translation, and may be inaccurate, incomplete, outdated or misleading. The English version prevails in the event of any inconsistency. We give no warranty as to the accuracy of any translated content and accept no liability for any loss, including financial loss, arising from reliance on it.

17. Data Protection Officer

17.1 You may contact our Data Protection Officer by email if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, as follows:

To: contact@pottu.com.sg
Subject: Attention to Data Protection Officer (DPO)

18. Effect of policy and changes to policy

18.1 This Policy applies in conjunction with any other notices, contractual clauses and consent clauses, and with our Terms and Conditions, that apply in relation to the collection, use and disclosure of your personal data by us.

18.2 We reserve the right to amend this Policy at any time. We may notify you of material changes by posting the updated Policy on the Platform or by email. Your continued use of the Platform after such notice constitutes your acceptance of the updated Policy.