This Privacy Policy (“Policy”) sets out the basis on which Chocolate Technologies Pte Ltd of 6 Irving Place #09-01, Singapore 369551 (UEN 202010925W) (together with our subsidiaries and/or related companies, collectively called “the Company,” or "Canvas," or "we," or “our” or “us”) collects, uses and processes Personal Data (as defined below) from you in compliance with Singapore’s Personal Data Protection Act 2012.
This Policy applies to the Personal Data collected in the Company’s properties at www.yourcanvas.co, the Company’s social media and customer communication channels, the Company’s mobile application, and any services accessed by you through other properties we own (collectively our “Properties”).
By accessing any of our Properties, you accept and consent to the practices set out in this Policy and authorise the Company to act in accordance with this Policy. If you do not agree with the terms of this Policy, please cease to interact with the Properties, clear all Cookies and refrain from future visits. If you have any queries pertaining to this Privacy Policy, you may contact the Canvas Data Protection Officer at support@yourcanvas.co
Collection of Personal Data
In this Policy, “Personal Data” means data, whether true or not, about a person who can be identified from that data or from that data and other information to which we have or are likely to have access. Personal Data may include (without limitation):
Information that you provide us (which may include your name, address, email address, telephone number, nationality, gender, identification numbers and other personal descriptions) by filling in forms on our Properties, or by corresponding with us (by phone, email or otherwise), for example:
when you report any problem to us;
when you use certain features on our Properties;
when you request any support from us; or
when you complete any survey or questionnaire we send you.
Bank transaction information such as your bank account details, the merchant or ATMs location (when overseas) and additional details about them; date, time and transaction amount, payment instrument, details of currency, details of cross-border transactions and detailed information of any electronic money exchange between the sender and the receiver such as name, date, time, location, IP address and information about the device used to process the transaction;
Information automatically collected when you visit our Properties, such as technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information that can enhance your overall user experience and improve fraud management of our products, including information about your interaction with our Properties, such as the full Uniform Resource Locators (URLs), clickstream to, through and from our Properties (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, your device’s operating system and platform, browser type and version, plug-ins, device type, unique device identifier, GPS data, location data, web or mobile analytics such as clickstream and page interaction data and any phone number used to contact our customer service number.
The following information would only be accessed and become Personal Data if the Company obtained your permission to access it through the mobile application: content information stored on your mobile device, contact information from your address book, digital contents and login information.
We retain Personal Data only for as long as the applicable Purpose still exists, and will use our best endeavours to expunge it within a reasonable time of that Purpose elapsing.
Uses made of Personal Data
We may use Personal Data for the following Purposes:
Processing your application, including but not limited to verifying your identity and evaluating your financial and legal track record, for our goods or services;
Administering and/or managing your relationship or account with us;
Processing and/or dealing with any of your requests and any necessary investigations relating to your requests;
Carrying out due diligence or other screening activities in accordance with legal or regulatory obligations or risk management procedures that may be required by law or by us;
Requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to improve and design our products, understand customer preferences and market trends, and to review, develop and improve the quality of our products and services;
Providing media announcements and responses;
Dealing with any matters relating to the services and/or products which you are applying for or have already applied for, including mailing to you correspondences statements, invoices, reports or notices, processes which involve disclosing certain Personal Data about you in order to carry out the aforementioned delivery, as well as disclosing certain Personal Data on the cover of envelopes/mail packages);
Investigating fraud, misconduct, unlawful action or omission, and any suspicion of the aforementioned;
Complying with applicable law in administering and managing your relationship with us;
Providing, improving and developing our services or researching, designing and launching new features or products;
Presenting content and information in our Properties in the most effective manner for you and for the device you use;
Providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
Carrying out your instructions, communicating with you and/or responding to your questions or requests;
Verifying your identity and any information you provide to us;
Personalising the appearance or user experience of our customer portal, or to provide targeted advertising on our Properties or through other channels;
Maintaining the quality of our services (including customer services), further to which, all communications between you and the Company, whether made via telephone calls, e-mails and/or text-based modality may be monitored and recorded;
Meeting the requirements imposed by any law, rules, regulations, agreements or schemes imposed by any government regulators, law enforcement agencies, government authorities, dispute resolution or industry bodies or in connection with any investigations;
Responding to or taking part in legal proceedings, including seeking professional advice;
Fulfilling legal purposes such as enforcing obligations owed to us or seeking professional advice (including legal advice); and/or
Any other purposes directly related or incidental to the above.
Subject to your prior approval, we may also use and process your Personal Data for other marketing and promotional related purposes listed below (“Additional Purposes”):
Providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
Sending you details of products, services, special offers and rewards, either to our users generally, or which we have identified may be of interest to you;
Notifying you on events or activities organized by Canvas and/or its partners, sponsors or advertisers, and the processing the registration for such events or activities; and/or
Matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Chocolate or other third parties.
The Purposes and Additional Purposes may continue to apply for a reasonable period thereafter even in situations where your relationship with us has been terminated or altered in any way.
Personal Data may at any time be processed by persons who operate outside Singapore.
For research or statistical purposes, we may use and disclose to others anonymised or aggregated Personal Data.
Disclosure of Personal Data
We will take reasonable steps to protect your Personal Data against unauthorised disclosure. To the extent permitted by law, we may transfer or disclose your Personal Data for the Purposes and Additional Purposes to the following entities or parties, whether they are located overseas or in Singapore:
Counterparties and their respective financial institutions in relation to payments and other transactions;
The issuer of the stored value facility;
Agents, contractors or third party service providers who provide operational services to Canvas, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services;
Vendors or other third party service providers, including but not limited to advertisers and event management companies, in connection with promotions and services offered by Chocolate;
Professional advisors and external auditors, including legal advisors, financial advisors and consultants;
Co-branded and other business partners;
Any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act (Chapter 50);
Personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the provision of support services);
Our overseas offices, affiliates, business partners and counterparts;
Persons under a duty of confidentiality to us;
Persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world (including law enforcement agencies, lawyers, auditors government regulators or authorities and, dispute resolution or industry bodies;
Actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world; and/or
Any other party to whom you authorise us to disclose your Personal Data to.
Cookies
A cookie is a small file of letters and numbers that, if permitted by your local browser settings, we store on a computer or mobile device to collect and retain information about visitor behaviour to our Properties, such as user preferences and session information. The information contained in cookies is transferred to your computer's hard drive and shared with us.
Cookies are used to distinguish you from other users of the Properties, which helps us to improve our Properties and your experience of it.
We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Properties or a partner Properties that uses our services. Session cookies only last for as long as the session (usually the current visit to the Properties or a browser session).
We may use third-party web services on our Properties. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Properties and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.
Third-party Properties
Our Properties (and/or our communication with you) may contain links to third party web properties for your convenience and information, and social media features such as the Facebook “Like” button. These properties and features operate independently from us, and may have their own privacy notices or policies. If you choose to access these properties and/or use these features, you should review their privacy notices or policies to understand their privacy practices. We will not be responsible for your access or use of these properties and/or features.
Security
All Personal Data you provide to us is stored on our secure servers or on the servers of partner companies that owe to us strict data management responsibilities. In all cases, reasonable security measures are applied to prevent the unauthorised access, collection, use, disclosure, copying, modification, disposal, erasure, or loss of Personal Data, including both physical and technical measures such as up-to-date antivirus protection. We also review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
Please note, however, that the transmission of information via the Internet is not completely secure. We cannot completely guarantee the security of any Personal Data and we cannot be responsible for any unauthorized use of Personal Data by third parties that is attributable to factors beyond our reasonable control.
Accessing Your Personal Data and Correction Requests
Should you wish to access a copy of or request correction of your Personal Data held by us, you can submit your request to our Data Protection Officer using the address details provided in this Policy.
Please note that:
we may need to ask for your identification number and other necessary details during the process to verify your identity;
we reserve the right to refuse your requests to access and/or correct your Personal Data for reasons permitted by law; and
we reserve the right to charge a reasonable fee for processing your request to access or retrieve your Personal Data.
Changes to this Policy
We may update this Policy from time to time. Any changes or updates we make to this Policy will be posted on this page, and your continued use and/or access to our Properties or services following such posting shall constitute your acknowledgement and acceptance of the updated Policy.
Withdrawing Your Consent
The consent that you provide for the collection, use and disclosure of your Personal Data in connection with the Purposes will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the Purposes listed above by submitting your request by letter or via email to our Data Protection Officer using the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable 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 us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Please note that:
the withdrawal of your consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws; and
depending on the nature and specifics of your objection, as a result of your withdrawal of consent we may not be able to continue to provide our products or services to you or perform on any contract we have with you.
Contacting us
If you have any questions, comments, notices or requests regarding Personal Data, please address them to the Company at:
