Last updated: 2020.04.02
We, ATLASV SINGAPORE PTE. LTD. and its affiliates, are committed to protecting your privacy. We limit the collection of your data. We only collect data that is required to maintain PinkBird.
1. COLLECTION OF DATA
1.1 Data we do not collect
We do not collect the following data:
1. Names (including subscriber names, user names, and screen names);
2. Addresses (including mailing addresses, residential addresses, and business addresses);
3. Telephone numbers;
4. Payment details: We do not collect your payment details for PinkBird. We do not collect or store credit card numbers, bank account numbers, or billing records.
1.2 Data we collect
We limit the collection of your data. We only collect data that is required to maintain PinkBird.
1.2.1 Data that you give us
We collect the data that you give us through your interaction with PinkBird. The amount of data you give us depends on your privacy settings.
If you contact us directly, we may receive data such as your name, email address, phone number, the contents of the message and/or attachments you may send us, and any other personal data you may choose to provide to us in your communication to us.
We use your email to:
1. Communicate with you;
2. Send you updates and announcements;
3. Send marketing information, such as our offers, surveys, invitations, and other content.
You may withdraw your consent to our use of your email address for the above purposes.
1.2.2. Data necessary for us to maintain the quality of PinkBird
We collect the following data related to your use of PinkBird:
(1) Data related to versions of PinkBird: we collect data related to your version of PinkBird. This allows us to efficiently identify and eliminate technical issues that you may face.
(2) Health and sensitive data related to app services: We store health data, such as your body measurements, dates of your past and current periods, and symptoms or events you track in the app (e.g. sex, levels of productivity, pain, or cravings). PinkBird uses this data for the purpose of providing our services to you.
(4) Anonymous data for network diagnostics, study and analysis: We collect anonymized data to operate PinkBird, including diagnostic data service failures, network failures, and crash reports.
2. USE OF DATA
We use, combine, and process your data for the following purposes:
We authenticate your use of PinkBird by assigning a unique identifier to you. This unique identifier identifies you through your device identification code without reference to other data. The purpose of the unique identifier is for us to determine the level of service you have signed up for before we establish your PinkBird connection.
We do not use other forms of your data to verify your identity.
2.2 System diagnostics
We use your data related to your PinkBird usage to perform internal operations necessary to maintain PinkBird. This includes troubleshooting operational problems, conducting data analysis, and analysing activity trends.
2.3 Customer support
We use your data to resolve customer support issues. For example, we may investigate and address concerns, monitor and improve our customer support responses, respond to your questions and feedback, and inform you of steps taken to resolve customer support issues.
We may communicate with you to provide you with updates relating to PinkBird, and for marketing and promotional purposes.
2.4 Research and development
We use your data to understand and analyze your use of PinkBird to develop new products, services, features, and functionality.
3. SECURITY MEASURES
We implement robust security measures to protect your data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. We ensure that our computer networks are secure. We adopt access control measures. Our staff's access to your data is restricted to a need-to-know basis.
We do not collect or store any traffic data or personal data in our data centers.
4. DATA RETENTION
We retain your data when we have an ongoing legitimate business need to do so, such as providing you with a service you requested, or complying with applicable legal, tax, or accounting requirements.
When we have no ongoing legitimate business need to process your data, we will delete or anonymize it. If it is not possible to delete or anonymize your data (for example, because it has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.
5. RIGHT TO BE FORGOTTEN
We will erase your data when:
1. Your data is no longer necessary for the purpose which we originally collected or processed it for;
2. You withdraw your consent to us holding your data, and we are relying on your consent as the lawful basis for holding on to your data;
3. You object to our processing of your data, and there is no overriding legitimate interest for us to continue such processing;
4. We are processing your data for direct marketing purposes and you object to that processing.
6. ORDERS COMPELLING THE DISCLOSURE OF YOUR DATA
Our collection of your data is limited. We collect your device identification code, and other data you may volunteer to us when you voluntarily contact us by way of email, phone, or interactions on PinkBird's application page on Google Play or App Store. We do not collect IP addresses, browsing history, traffic data, or DNS queries that could be used to identify you. As such, the extent of any disclosure of your data is limited.
We are committed to safeguarding your data. Nonetheless, we may be compelled to disclose your data where we are served with a valid court order that is enforceable in Singapore, an order from law enforcement agencies, or where we are legally obligated to disclose your data. We will require the recipient of your data to undertake to protect your data, to a standard that is at least comparable to the protection required under Singapore's Personal Data Protection Act ("PDPA").
(1) For the purposes of fulfilling our contractual obligations to users, including:
- Providing users with the PinkBird services they have requested.
- Managing user subscriptions and processing payments.
- Providing customer support.
(2) For a legitimate interest associated with the operation of our business, including:
- Enhancing the quality, reliability, and effectiveness of our PinkBird services, and Apps.
- Communicating with customers to provide information and seek feedback related to our PinkBird services and Apps.
You can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. As well, you have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you.
You can exercise your rights under the GDPR to access, transfer, correct, delete, or object to the processing of your personal information by contacting us at firstname.lastname@example.org.
7. CHILDREN'S PRIVACY
We do not offer PinkBird to children. If you are under 13 years old, you may use PinkBird only with the consent, involvement, and supervision of a parent or guardian.
When you become a user of PinkBird, you may request to access your data that is associated only with you by emailing email@example.com.
To protect your privacy and security, we may take reasonable steps to verify your identity before acceding to your request. Upon our approval of your access request, we will provide you with your data that is in our possession or under our control. Where applicable, we will provide you with information about the ways in which your data has been or may have been used or disclosed by us within a year of your request.
You may make a request to correct an error or omission about your data that is in our possession or control, by emailing firstname.lastname@example.org.
We will consider whether the correction should be made. If such correction is to be made, we shall correct your data as soon as practicable and send the corrected data to every other organization to which your data was disclosed by us within a year before the date the correction request was made, unless that other organization does not need the corrected data for any legal or business purpose.
To protect your privacy and security, we may take reasonable steps to verify your identity before correcting your data. Your data may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes.
10. BREACH NOTIFICATION
We will report serious breaches of your data to the relevant supervisory authority to ensure your data is protected.
If we materially change the ways in which we use or share your data previously collected through PinkBird, we will notify you through PinkBird, email, or other communication.
12. GOVERNING LAW
13. DATA PROTECTION OFFICER
Jenny is our Data Protection Officer ("DPO"). The DPO may be contacted at email@example.com.