Introduction

Purpose of this privacy notice
This privacy notice informs you as to how we collect, process and look after your personal data in the course of interacting with us, whether by visiting this website, signing up for an account or otherwise, and tells you about your privacy rights and how the law protects you.

This website is not intended for children and we do not knowingly collect data relating to children.

Data Controller
We are Mobyware Pte Ltd, based in Singapore, henceforth referred to as "we", "us" or "our" in this privacy policy. In respect of your personal data, we are the data controller, in accordance with the provisions of SG regarding collection and circulation of personal data and SG Regulation regarding the protection of personal data.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact mobyware@gmail.com. This is your email contact in respect of all queries relating to your data protection rights and we aim to respond promptly to all such emails.

Changes to the privacy policy and your duty to inform us of changes
This version was last updated on 7th of September 2023. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, which you can do through your account.

Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or anonymized data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Contact Data: Name and email address
Communications Data: includes name, emails and notes of conversations, if you choose contact us and provide information for us to reply

If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to deliver the product you have ordered but we will notify you if this is the case.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions: you may give us contact information when submitting information through the website or by corresponding with us email or otherwise.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Your data is never used for marketing purposes or transferred to a third party, unless you provide explicit consent. Your data is never sold to a third party, under any circumstances except the acquisition of Mobyware Pte Ltd by another company.

Purposes for which we will use your personal data
A description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so can be found below. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

1. To manage our relationship with you (for example, sending you notifications about applications saved in your watchlist, if and only if you choose to receive them)
Data processed: Contact Data
Lawful basis: performance of a contract, legitimate interest

Opting out
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You can ask us to stop sending you email notifications about applications on your watchlist by accessing your account and unchecking the corresponding box. Note that these notifications are not commercial by nature as they only contain a link to the application�s page on this website and are only send when applications receive updates.

Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.

Cookies
You can set your browser to refuse all or some of the browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Disclosures of your personal data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see "request erasure" below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Specific legal rights for users located in the EEA region (GDPR)

You may contact our data protection officer at mobyware@gmail.com for more information or to exercise any of these rights:

1. Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Exercising these rights
Use our DSR (data subject request) form or send an email to mobyware@gmail.com

You also have the right to make a complaint at any time to the Singapore supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns about data protection before you approach the authority so please contact us in the first instance.

No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.