We, Gushcloud Pte Ltd (hereafter referred to as "gushcloud", "us", "we" or "our") take protection of your Personal Data (defined below) seriously.
What gushcloud collects
The types of personal data that we collect depend on the circumstances of collection and on the nature of the transaction undertaken with us.
The personal data that we may request includes but is not limited to (individually and collectively referred to as “Personal Data”):-
- personal identification information, including name, identification numbers, gender, date of birth, images, photographs, videos, voice recordings;
- contact information, including postal address, email address, phone number;
- payment information, namely credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
- demographic information such as academic qualifications, occupation, job details, preferences and interests;
- technical and statistical data, such as your IP address, browser type, domain names, access times and referring website addresses, which will automatically be collected by us to maintain quality of the service and to compile general statistics regarding use of our websites.
Separately, we encourage you to review the privacy statements of websites that you may link to from time to time through gush.co (www.gush.co) to understand how these websites collect, use and share your information.
What gushcloud does with your Personal Data
The Personal Data you provide helps us to understand your needs, maintain our relationship with you, process transactions, fulfil our delivery obligations for any goods, services or activities you undertake with us, and improve our service delivery. In particular, we collect your Personal Data for the following purposes, including without limitation:-
- to process relevant information including conducting analytics, for the provision of products, services or activities that best meet your preferences or needs;
- fulfilling instructions, sending postal mail and e-mails, providing marketing assistance, processing payments, and providing customer service;
- to respond to feedback from you;
- to provide updates on promotions and events;
- to improve our products and services and to customise our websites according to your interests;
- to develop content of our websites and our related network of websites;
- for safety, security and legal compliance;
- for record keeping;
- to market products, services and activities offered by us, our partners as well as our appointed agents, and to conduct product or customer satisfaction surveys and market research, which you will always have the option of opting out from receiving such information
(collectively referred to as "Purposes").
We may also use and disclose your Personal Data within gushcloud and its group of companies, and with and to third parties:-
In order to fulfil the Purposes listed above, in which case, we may:-
- Disclose, transfer, and jointly use your Personal Data to and with such third parties in Singapore and overseas, and your Personal Data may also be transmitted to data storage facilities or our offices and appointed agents in Singapore or other countries in connection with our performance of the transaction with you;
- Share your Personal Data with our trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your Personal Data except to provide these services to us, and they are required to maintain the confidentiality of your Personal Data;
- If required or authorised to do so by law or pursuant to a court order, including but not limited to circumstances where use and/or disclosure is:-
- necessary for any investigation or legal proceedings, including but not limited to fraud, intellectual property infringement or privacy;
- necessary for establishing, exercising or defending our legal rights, or obtaining legal services;
- necessary for responding to an emergency that threatens the life, health or safety of an individual;
- in connection with or forms part of any purchase, sale, lease, merger or amalgamation of gushcloud or its group of companies, including business or assets, or any other acquisition, disposal or financing of gushcloud or its group of companies, but otherwise it is not in our usual course of business to sell, rent or lease your Personal Data to third parties.
Your express consent will be sought when collecting your Personal Data. There will also be instances where your consent for the collection or use of your Personal Data will necessarily be implied from the circumstances by nature of the task or transaction, including your interaction with us or in the course of signing up for, or accepting, any of our products, services or activities you have requested.
Access to Personal Data
We will, upon your written request to our Data Protection Officer (see contact details and requirements below), allow you to enquire about the ways in which your personal data has been or may have been used or disclosed within a year before the request. Where required or authorised to do so by law, we reserve the right to charge a reasonable administrative fee for this service and/or deny your request for access to your Personal Data.
Accuracy of Personal Data
You should ensure that all Personal Data submitted to us is current, complete and accurate. Failure on your part to do so may result in our inability to provide you with the products, services and activities you have requested.
If you believe that any Personal Data we are holding on you is incorrect or incomplete, please write to or email our Data Protection Officer (see contact details and requirements below).
Retention of Personal
We will retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of gushcloud, or as required by relevant laws.
When destroying Personal Data, we will take commercially reasonable and technically possible measures to make the personal identifiable information irrecoverable or irreproducible.
Security of Personal Data
We are committed to ensuring the security and protection of your Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks.
We maintain physical, electronic and procedural safeguards to protect your Personal Data. For example:-
- We use industry-standard Secure Sockets Layer ("SSL") authentication to ensure the confidentiality of online transactions made on our site. SSL authentication and encryption of the information that you send to us over the Internet help protect your online transaction information from third party interception.
- We restrict the access of personally identifiable data to only specific authorised internal staff of gushcloud with dedicated login access and passwords.
- We ensure that our appointed IT service provider has the necessary security protocols in place to host and protect our data.
While we strive to protect your Personal Data, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter our websites or computer systems (for example viruses, bugs, trojan horses, spyware or adware). Despite all of our efforts, there is always a risk that third parties may unlawfully intercept transmissions. This reality is true of all Internet use. Further, we are not responsible for the privacy statements or content on websites not controlled by us.
If you access our website from a shared computer or a computer in an internet cafe, a library, or any public facility, certain information about you, such as your user ID, activity or reminders from our website, may also be visible to other individuals who use the computer after you. To protect your Personal Data or communication from being disclosed to others, you should log out, clear browsing data and close the web browser after using our website.
You should be aware of the risks associated with disclosing any information or transacting over the Internet or when using online portals, and we urge you to take every precaution when using the Internet to disclose your Personal Data to us, including using strong passwords, changing your password regularly, using a secure browser and not to share your password with anyone or via an unsolicited phone call or e-mail.
We will never ask for your password by phone or e-mail, so if you receive such an enquiry, please report the incident to our Data Protection Officer at email@example.com.
If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place.
We are not liable for any loss or damage resulting from your act or omission to safe-keep your username and password from unauthorised use, and also for any information you transmit over the Internet which you do so solely at your own risk.
Further rights of data subjects in the European Union ("EU")
In the event that we have existing access and consent to your Personal Data, and you are a data subject in the EU, please contact us should you wish to exercise any of the following further rights:-
- request for the erasure of your Personal Data;
- request for the restriction of processing of your Personal Data;
- object to the processing of your Personal Data; and/or
- request to transfer your personal Data to you or a third-party.
All requests made to us in exercising the rights above will be processed within a reasonable time except where we refuse such requests in accordance with any applicable laws or regulations.
Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
- would like to withdraw your consent to any use of your Personal Data;
- would like to obtain access and make corrections to your Personal Data; or
- report any security incident relating to your username, password or transaction with us that involves your Personal Data,
Data Protection Officer
Gushcloud Pte Ltd
Email address: firstname.lastname@example.org
To protect your privacy and security, we will also require you to verify your identity before we can respond substantially to your request.
Last updated on Jun 2019