PRIVACY STATEMENT (updated March 2024)

  1. INTRODUCTION

HIFILOFI Pte. Ltd. (also trading as CXposé.tech) and all its subsidiaries and affiliates globally (“HIFILOFI”, “CXposé”, “Us, “We”, “Our”) is committed to collecting, using, storing, sharing and disposing your Personal Data in a fair, ethical, transparent, secure and legitimate way, in accordance with Singapore PDPA (Personal Data Protection Act) of Singapore and other applicable Data Protection and Privacy acts, standards or regulations.

Our Privacy Statement is applicable to our use of your Personal Data when interacting with our websites, social media sites, applications and other platforms (“Sites”), and describes what Personal Data we use about you, how we use it, and your rights in relation to your Personal Data.

The Privacy Statement forms part of our Terms of Use governing the use of our Sites.

  1. WHAT INFORMATION DO WE COLLECT

Personal Data is any information that is related to you and can be used to identify you. For specific definitions, please refer to the PDPA and other applicable standards.

Personal Data that we collect directly from you:

  • When you use our Sites, access or download any white papers or reports in print and other media formats, subscribe to our mailing lists or newsletters, we will collect any information that you submit through that Site, including but not limited to, your First and Last Name, Email, Contact Info, Industry, Job-title/Role, Country of Residence or Work, and your Company.
  • When you post or respond to our social media pages, we may collect information about you from your post.
  • When you register and attend our events, workshops, or seminars, we will collect any information that you submit for registration, including but not limited to your Name, Email, Industry, Role, Country of Residence or Work, Company, and any additional information in our forms, video and/or audio recordings.
  • When you request information from us, we may collect, including but not limited to, your Name, Email, Industry, Role, Country of Residence or Work, Company, and any additional information and Inquiry Information.

Personal Data that we automatically collect.

  • We, and our Service Providers, may automatically collect about your use of our Sites through website cookies, web beacons, and other technologies, , including but not limited to, your domain name, your browser/operating system, webpage views, links you have accessed, language preferences, marketing preferences, IP addresses, time and length of access to our Sites, referring links that led you to our Sites, approximate locations.

Personal Data we collect from other sources.

  • We may collect Personal Data about you from our subsidiaries and affiliated entities, from our business partners (with whom we offer our services and solutions and joint marketing programs), from public sources and databases, from our 3rd party service providers (where you have provided your Personal Data and agreed to your data being shared and used)

We will not ask for Special Categories of Personal Data covering information relating to your health, biometric or genetic information, religion, political beliefs, union membership, race or sexual orientation.

You can choose not to provide your Personal Data to us. However, if your Personal Data is required to provide our products, services and solutions to you as required by our contract, we may not be able to provide these to you without your Personal Data.

  1. WHAT IS OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA

We may rely on the following legal bases to use your Personal Data in connection with the purposes in this Privacy Statement.

  • Applicable laws and regulations
  • Performance of contracts
  • Your consent to the use of your Personal Data
  • Legitimate business interest
  1. WHAT WE USE YOUR PERSONAL DATA FOR

Products, services, and solutions improvements. For example,

  • To carry out administrative and business tasks and internal reporting, we will send administrative information to you and manage our business relationship.
  • We will request feedback from you regarding our products, services, and solutions, using your Personal Data solely for assessing website performance and improving operations.
  • Processing your orders and delivering our products, services, and solutions to you.
  • Providing timely updates about our products, services, and solutions.
  • Addressing your inquiries and fulfilling any requests you make.
  • Maintaining updated records and ensuring the accuracy of your contact details.

Provide you with marketing materials and to personalize your experience. For example to:

  • Distribute marketing communications to you.
  • Enhance your interaction with us by offering a tailored experience.
  • Facilitate your subscription to our newsletters and mailing lists.
  • Empower you to manage your marketing and cookie preferences.
  • Enable you to register for events, workshops, and seminars organized by us.

Achieving our business purposes and analyse information. For example, to:

  • Establish, oversee, and sustain our business association with you.
  • Furnish you with details about our products, services, and solutions that might interest you.
  • Aggregate usage data for our Sites.
  • Handle and address privacy inquiries, questions, worries, and grievances.
  • Fulfill our contractual commitments.

Research and analytical purposes. For example, to:

  • Gain insights into your usage patterns on our Sites.
  • Enhance the quality of our products, services, and solutions.
  • Assess the demand for our products, services, and solutions.
  • Conduct surveys and questionnaires, including those for market research or to meet client satisfaction needs.
  • Fulfill our legal obligations, such as:
    • Investigating, preventing, or addressing illegal activities or suspected fraud.
    • Investigating violations of our Terms of Use or this Privacy Statement.
  1. HOW WE SHARE YOUR PERSONAL DATA

We may share your Personal Data with the following parties for the purposes set out in this Privacy Statement (as applicable):

Our subsidiary companies and affiliated entities: We might disclose your information to our subsidiary companies and affiliated entities to support the operation of our business, facilitate the delivery, analysis, enhancement, security, and customization of our products, services, and solutions, send marketing and other relevant communications regarding our business, and for other lawful purposes as allowed by applicable laws or with your consent.

Authorized personnel and advisors: We may disclose information about you to authorized HIFILOFI staff, agents, and professional advisors, including legal advisors, auditors, and consultants working with HIFILOFI, as necessary.

Our Service Providers: We might disclose information about you to our service providers in instances where we have subcontracted parts of our products, services, and solutions, engaged third-party applications, services, or products, or tasked third parties with administering internal business processes at HIFILOFI. Examples include order processing and credit card transactions, website hosting, seminar registration hosting, assistance with sales-related activities or post-sales support, and provision of customer support.

Our business partners: Information about you may be shared with our business partners, with whom we collaborate to offer our products, services, and solutions jointly. This collaboration includes providing additional technical assistance in resolving any issues reported.

We also may share Personal Data in the following circumstances:

  • As part of the contractual terms agreed upon for the Service provided.
  • In connection with any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition involving all or a portion of our business, to our advisors and the advisors of the other company participating in such transactions.
  • To safeguard the rights, property, or safety of HIFILOFI, its business partners, you, or others, or as otherwise mandated by applicable law.
  • To comply with a request for information from a competent authority in accordance with, or mandated by, any applicable law, regulation, or legal process; or as necessary to adhere to judicial proceedings, court orders, or government directives.
  • In aggregated, anonymized, and/or de-identified form that cannot reasonably identify you.

Any Service Providers or other parties with whom we share Personal Data are contractually obligated to institute suitable physical, administrative, and technical measures to safeguard Personal Data. They are expressly prohibited from utilizing Personal Data for any purpose other than the specific purpose for which they are provided with or granted access to Personal Data by us.

  1. HOW WE SAFEGUARD YOUR PERSONAL DATA

We are deeply committed to protecting your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorized access, or disclosure. This dedication is maintained through a comprehensive approach encompassing physical, administrative, and technical safeguards. Furthermore, we require our service providers, to whom we disclose your Personal Data, to uphold similar levels of protection.

However, it’s important to acknowledge that despite our stringent security measures, we cannot guarantee 100% security of your Personal Data. Therefore, we encourage you to take reasonable precautions to safeguard your Personal Data, such as refraining from sharing your passwords, selecting strong passwords, and implementing other appropriate measures to enhance security.

  1. HOW WE KEEP YOUR PERSONAL DATA

We retain information about you for the duration necessary to fulfill the purpose for which it was collected, unless extended retention is mandated by legal obligations, dispute resolution, asset protection, or enforcement of rights. We retain your Personal Data under the following circumstances:

  • When obligated by law, contract, or other legal obligations, or as part of an investigation for litigation purposes.
  • When your Personal Data is necessary to maintain accurate business and financial records.
  • If automated means are available, allowing you to access and delete your Personal Data at any time.
  • When you have provided consent for us to retain your Personal Data for an extended period, aligning with your consent.
  • If Personal Data is present in backups or archived copies and its removal, deletion, or destruction is infeasible for any reason, HIFILOFI will retain such Personal Data in accordance with applicable Data Protection Laws.
  • We may anonymize your information following our policies and retain these anonymized records for longer durations in some cases.
  1. CROSS-BORDER TRANSFERS

We may transfer your Personal Data to countries where we, our Service Providers or Business Partners do business or to international organizations in connection with the purposes identified above and in accordance with this Privacy Statement.

When we transfer your Personal Data outside of the country from where it was originally collected to a third country or international organization we ensure that appropriate safeguards are in place, in line with applicable law, to ensure that your Personal Data is protected. You may obtain a copy of these safeguards by contacting us in accordance with the ‘How to contact us’ section below.

  1. YOUR PERSONAL DATA RIGHTS

You possess rights under diverse data protection laws across different countries concerning your Personal Data, and we extend these rights regardless of your location.

We are committed to upholding and respecting your rights, which include:

  • Right to be informed: You have the right to know what Personal Data we have about you, how we use it, its source, whom we share it with, how long we retain it, and the reasons for its necessity.
  • Right of access: You have the right to access your Personal Data and obtain a copy from us.
  • Right to rectification: You have the right to correct inaccurate or incomplete Personal Data about you.
  • Right to be forgotten: You have the right to request the erasure, deletion, or destruction of your Personal Data.
  • Right to data portability: You have the right to securely move, copy, or transfer your Personal Data for your own purposes.
  • Right to withdraw consent: You have the right to withdraw consent regarding the use of your Personal Data or in relation to direct marketing activities at any time.
  • Right to restrict use: You have the right to limit how we use your Personal Data.
  • Right to object: You have the right to stop or prevent us from using your Personal Data, including objecting to its use for direct marketing or sale.
  • Right to challenge automated decisions: You have the right to question and review decisions made about you using purely automated means.
  • Right to complain: You have the right to lodge a complaint or raise concerns about how we use your Personal Data. Complaints can be directed to us or a relevant Data Protection Authority.
  • When you contact us, we may request specific information from you to verify your identity, enabling us to search for and provide access to or a copy of your Personal Data, as permitted by applicable law. If allowed by law, we may charge a reasonable fee for access to your Personal Data; however, we will inform you of any fees in advance.
  • Individuals may hold additional rights in certain countries, which must be recognized and upheld.

In some situations, we may not be required to enforce these rights, where permitted under applicable law. We may also have a legitimate business interest to decline a request to action your rights.

  1. COOKIES AND SIMILAR TECHNOLOGIES

When you access our Sites, we and our service providers may use cookies (small text files containing a unique identification number which are placed on your PC, laptop, tablet or mobile phone) and similar technologies including scripts, embedded web links, web beacons, Local Shared Objects and Local Storage.

  1. LINKS TO THIRD PARTY WEBSITES AND APPLICATIONS

Our websites may contain links to third-party websites and applications. You can also engage with us through various third-party applications, including those owned by our company or other entities like LinkedIn, WhatsApp, Slack, Microsoft Teams, Facebook, Twitter, Google+, and other social media platforms.

We want to emphasize that we do not assume responsibility for the security, privacy practices, or content of these third-party websites and applications. It’s important that you review their privacy and cookie policies before sharing any personal data. Your decision to use such websites and applications is entirely at your own discretion and risk.

  1. CHANGING YOUR CONSENT PREFERENCES

In certain instances, you may grant HIFILOFI consent to process your Personal Data, such as when you opt in to receive direct marketing communications from us. You have the flexibility to change your consent preferences at any time and manage your communication settings where available by unsubscribing from our communications or updating your preferences via email at [email protected] . Once we receive and confirm your request, we will promptly adhere to your preferences to the best of our ability.

Even if you choose to opt out of receiving marketing-related communications from us, you may still receive administrative messages or other essential communications necessary for your continued use of our products, services, and solutions, which cannot be opted out of.

We do not share your Personal Data with unrelated parties for their own direct marketing purposes, nor do we sell, rent, distribute, or otherwise make Personal Data commercially available to any third party.

  1. CHILDREN’S PRIVACY

We urge parents and guardians to actively monitor their children’s online activities. Our websites are not intended for children. If you suspect that we have inadvertently collected Personal Data about an individual who is under the applicable age of consent in your country without the proper consent of the child’s parent or guardian, please reach out to us.

  1. UPDATES TO OUR PRIVACY STATEMENT

We reserve the right to update our Privacy Statement at any time. In the event of updates, we will revise the “Version” and “Updated” details on the Privacy Statement. We encourage you to check our Privacy Statement periodically to stay informed about how we utilize your Personal Data and our privacy practices.

  1. OTHER PRIVACY STATEMENTS

Further details regarding our Privacy Statement pertaining to Products, Services, Solutions, Human Resources, Finance, and other relevant aspects, as well as local territorial jurisdiction requirements, might be incorporated into distinct Privacy Terms and Conditions or other statements and notifications delivered to you. In cases of conflict, these separate statements and notifications will hold precedence for the specified situations.

  1. HOW TO CONTACT US

If you have any inquiries regarding our Privacy Statement, how we utilize your Personal Data, concerns about privacy, or if you wish to make a request or file a complaint regarding your Personal Data, please don’t hesitate to contact us at [email protected] . We are here to assist you.