Blu5 View Pte Ltd is committed to protecting and respecting your privacy
This policy (together with any other documents referred to in it) sets out:
- what information we collect about you when you visit our website, use our products or services, or otherwise interact with us;
- how we use, share, store, and secure the information; and
- how you may access and control the information
In this policy:
“personal information” refers to any data, information, or combination of data and information that is provided by you to us, or through your use of our products or services, that relates to an identifiable individual;
“Platform” means our website (www.blu5group.com); and
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
If you are under 18, please do not send any personal data about yourself to us.
1. What information we collect about you
1.1. In order to provide a better service to you, we may collect and process the following data about you:
- Profile information that you provide when by filling in forms on our Platform. This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. For example your name, email address, physical address and telephone number (collectively, “Account Data“);
- information you provide through our support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data“);
- content you provide through use of our products or services (collectively, “User Content“);
- communication, marketing preferences that you set when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data“);
- details of any transactions, purchases, or orders that you’ve made with us (collectively, “Transaction Data“);
- payment information, for example your payment card information or bank account details (collectively, “Financial Data“), if any;
- information about your device or connection, for example your internet protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our products or services and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data“); and
- information about your use of or visit to our Platform, for example your clickstream to, through, and from our Platform, products you viewed, used, or searched for, download or other errors, page response times, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page (collectively, “Usage Data“).
1.2. We collect the above information when you provide it to us or when you use or visit our website. We may also receive information about you from other sources, including:
- our personnel, agents and consultants in connection with our operations or services, for example our staff engaged in the fulfilment of your order, processing of your payment, and provision of support services;
1.3. We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.
2. How we use information that we collect
2.1. We only use your personal information where the law allows us to. The purposes for which information may be used by us in and outside Singapore include:
- ensuring that content from our site is presented in the most effective manner for you and for your computer;
- providing you with alerts, newsletter, education materials or information that you requested or signed up to;
- carrying out our obligations arising from any contracts entered into between you and us;
- allowing you to participate in interactive features of our service, when you choose to do so;
- designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
- complying with laws and regulations applicable to us or any of our affiliates in or outside Singapore;
- legal proceedings, including collecting overdue amounts and seeking professional advices;
- researching, designing and launching services or products including seminars/events/forums;
- promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in clause 2.2 below); or
- purposes directly related or incidental to the above.
2.2. We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
- your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behavior, background and demographic data held by us from time to time may be used by us in direct marketing;
- the following classes of services, products and subjects may be marketed in direct marketing:
- services and products related to our site and/or our affiliates (including marketing affiliates programs we are a part of);
- reward, loyalty or privileges programs, promotional offers and related services; and
- invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
- We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
2.3. If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us directly or by unsubscribe or opt-out at any time by follow the instructions provided in any of the communications to unsubscribe, but please note this will not affect any use of your information that has already taken place.
2.4. We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.
2.5. For visitors to or users of our website who are located in the European Union, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this policy.
3. How we share information we collect
3.1. We will keep the personal data we hold confidential but may provide information to:
- personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;
- our overseas offices (if any);
- Third-party service providers have access to your personal information only for the purpose of performing their services and in compliance with applicable laws and regulations. We require these third-party service providers to maintain confidentiality and security of all personal information that they process on our behalf and to implement and maintain reasonable security measures to protect the confidentiality, integrity, and availability of your personal information.
- We take reasonable steps to confirm that all third-party service providers that we engage process personal information in the manner that provides at least the same level of protection as is provided under this policy. Where any third- party provider is unable to satisfy our requirements, we will require them to notify us immediately and we will take reasonable steps to prevent or stop non- compliant processing.
- If you use any third-party software in connection with our products or services, for example any third-party software that our website integrates with, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.
- persons to whom we are required to make disclosure under applicable laws and regulations in or outside Singapore;
If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.
4. How we store and secure information we collect
4.1. We have adopted the following measures to protect the security and integrity of your personal information:
- any information that you send through our Platform is securely transmitted with TLS/SSL encryption
- access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and
- our information collection, storage, and processing practices are reviewed regularly.
4.2. We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
4.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk and you agree not to hold us responsible for any breach of security while accessing the internet that is out of our control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
4.4. You have the legal right to ask for a copy of any of your personal data held by Blu5 (where such data is held). Please contact Blu5 for more details at firstname.lastname@example.org
5. How we transfer information internationally
5.1. We collect information globally. We transfer, process, and store your information outside your country of residence where we or our service providers operate for the purpose of providing our products and services to you.
5.2. Some of the countries in which our companies or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information.
6. Third party websites
Our website may contain links to other sites (“Linked Sites“). We are not responsible for the privacy policies or practices of such other Linked Sites. We encourage our users to be aware when leaving our website to read the privacy policies or statements of each Linked Site that collects your personal data. You agree to waive any claim against us with respect to the Linked Sites.
8. Your consent and rights
8.1. By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.
8.2. You have the right to:
- be informed of what we do with your personal information;
- request a copy of personal information we hold about you;
- require us to correct any inaccuracy or error in any personal information we hold about you;
- request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure if the personal information is still necessary for the purpose which we originally collected it for, or for record keeping or legal compliance purposes);
- object to or restrict the processing by us of your personal information (including for marketing purposes);
- request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
- withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).
8.3. You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications or by contacting us at email@example.com or submit any written request to:
Blu5 View Pte Ltd
10 Anson Road #12-14 – International Plaza – 079903 Singapore
+65 6270 2891
Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.
8.4. As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.
8.5. Any request under paragraph 8.2 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.
8.6. We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.
9. Policy towards children
9.1. Our products and services are not directed to individuals under 16. We do not knowingly collect personal information from individuals under 16. If we become aware that an individual under 16 has provided us with personal information, we will take steps to delete such information. If a parent or guardian becomes aware that his or her child has provided us with PII without their consent, he or she should contact us at firstname.lastname@example.org.
10.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
10.3. We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
10.5. Our website uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”). Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.
10.6. You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
10.7. Furthermore, you can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).
Legal basis table
|Processing purpose||Type of data processed||Legal basis|
|To enable you to use our products and services||Account Data, Transaction Data, Support Data, Technical Data and User Content||To perform our contract with you|
|To process your payments||Account Data, Transaction Data, Financial Data||To perform our contract with you|
|To collect overdue amounts||Account Data, Transaction Data, Financial Data||Legitimate interest to recover debts due to us|
|To notify you about changes to our products, services, or terms||Account Data||To perform our contract with you|
|To administer and maintain safety and security of our Platform||Technical Data||To perform our contract with you|
|To study usage of our products or services||Transaction Data, Support Data, Technical Data, Usage Data||Legitimate interest to improve our Platform, products, and services|
|To gather feedback on our products, services, or features||Account Data||Legitimate interest to improve our Platform, products, and services|
|To provide information on products or services that may be of interest to you||Account Data, Preference Data||Consent, which you may withdraw any time|
Last updated: 20 May 2018