This policy sets out:
- the 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, “5x” or “we” refers to 5X PTE. LTD. of 68 Circular Road #02-01 Singapore 049422 (together with our subsidiaries, our holding company, and subsidiaries of our holding company from time to time) and “Platform” means our website at https://5x.co and our software, namely 5x Platform, app.5x.co
1. WHAT INFORMATION WE COLLECT ABOUT YOU
1 . 1 We collect the following types of information about you:
- account and profile information that you provide when you register for an account or sign up for our products or services, for example Personal Information You Provide: Identification Information: we may collect your name, email address, company name, job title, and phone number through the Site or through our social media platforms. Business Information: we may collect your business use case, company size, cloud provider, data vendors, etc to allow us to serve your use case. This would be stored as you provide information to our platform to seek recommendations. We may also store user credentials of your data vendors after due consent from your end. However, if do it only if you wish to store it at our end. Communication Information: we may collect any information included in your communications with us. Internet Activity Information: When you visit the Site, the following information we may automatically log the following information: Device Information: the manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the Site. The information we collect may vary based on your device type and settings. Usage Information: information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We may use Google Analytics, a web analytics service provided by Google LLC (“Google”) to help collect and analyse Usage Information. For more information on how Google uses this information, click here. We may also use another analytics service called Microsoft Clarity and that tool permits Microsoft to collect and use your personal information, including for advertising. Learn more about how Microsoft uses information here. Device Information: the manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the Site. The information we collect may vary based on your device type and settings. Usage Information: information about how you use our Site, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We may use Google Analytics, a web analytics service provided by Google LLC (“Google”) to help collect and analyze Usage Information. For more information on how Google uses this information, click here. We may also use another analytics service called Microsoft Clarity and that tool permits Microsoft to collect and use your personal information, including for advertising. Learn more about how Microsoft uses information here. (collectively, “Account Data”)
- information you provide through 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”);
- communication, marketing, and other preferences that you set when you set up your account or profile, or 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 We will not collect financial information on our website or 5x Platform. Any financial information would be delegated to the Stripe application. (collectively, “Financial Data”);
- information about your device or connection, for example Device Information: The manufacturer and model, operating system, IP address, and unique identifiers of the device, as well as the browser you use to access the site or app. The information we collect may vary based on your device type and settings. Usage Information:Information about how you use our site or app, such as the type of content that you view or engage with, the features you use, the actions you take, and the time,frequency, and duration of your activities. We may use Google Analytics, a web analytics service provided by Google LLC ("Google") to help collect and analyse usage information. For more information on how Google uses this information, click here. We may also use another analytics service called Microsoft Clarity and that tool permits Microsoft to collect and use your personal information, including for advertising. Learn more about how Microsoft uses information here. 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 click stream to, through, and from our Platform, products you viewed, used, or searched for, page response times, download errors, 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 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, bio-metrics, health, or sexual orientation.
2. HOW WE USE INFORMATION WE COLLECT
2 . 1 We only use your personal information where the law allows us to. We use your personal information only where:
- we need to perform the contract we have entered into (or are about to enter into)with you, including to operate our products or services, to provide customer support and personalized features, and to protect the safety and security of our Platform;
- it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests;
- you've given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
- we need to comply with a legal or regulatory obligation.
2 . 2 If you have given us consent to use your personal information for a specific purpose, youhave the right to withdraw your consent any time by contacting us (please refer toparagraph 9. for contact information), but please note this will not affect any use of yourinformation that has already taken place.
2 . 3 We do not share your personal information with any company outside our group formarketing purpose, unless with your express specific consent to do so.
2 . 4 For visitors to or users of our Platform 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 share information with other companies in our group in order to operate our Platformand to offer and improve our products and services.
3 . 2 We share information with third parties that help us operate, provide, support, improve,and market our products and services, for example third-party service providers who provide In certain circumstances we may share your personal formation with: Service Providers, including hosting services, cloud services, and other information technology services, email communication software and email newsletter services, advertising and marketing services, customer relationship management and customer support services,and analytics services. Pursuant to our instructions, these parties will access, process, or store personal information in the course of performing their duties to us. Professional Advisors: such as lawyers and accountants where doing so is necessary to facilitate the services they render to us. Business Transaction Recipients: such as counter-parties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy,receivership, dissolution, asset sale, or similar transaction, and with a successor or affiliateas part of or following that transaction. Government Authorities: we do not volunteer your personal information to government authorities or regulators, but we may disclose your personal information where required to do so for the Compliance and Protection purposes described above.
3 . 3 Third-party service providers have access to your personal information only for thepurpose of performing their services and in compliance with applicable laws andregulations. We require these third-party service providers to maintain confidentiality andsecurity of all personal information that they process on our behalf and to implement andmaintain reasonable security measures to protect the confidentiality, integrity, andavailability of your personal information.
3 . 4 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.
3 . 5 We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our product-sand services.
3 . 6 If you use any third-party software in connection with our products or services, for example any third-party software that our Platform 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.
3 . 7 Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.
3 . 8 We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
3 . 9 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 use data hosting service providers based in AWS is based in US - EAST- 1 to host the information we collect.
4 . 2 We have adopted the following measures to protect the security and integrity of your personal information:
- Data at rest is encrypted using AES-256 technology.
- information when transferred is encrypted using TLS/SSL technology.
- your account is password-protected;
- access to your personal information is restricted to personnel or service provider son 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 . 3 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 . 4 While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.
4 . 5 We only retain personal information for so long as it is reasonably necessary to fulfill the purpose we collected it for, including for the purposes of satisfying any legal, accounting,or reporting requirements. 5X might retain data as long as the company has a need for its use, or to meet regulatory or contractual requirements. Once data is no longer needed, it will be securely disposed of or archived. Data owners, in consultation with legal counsel,may determine retention periods for their data. Personally identifiable information (PII) will be deleted or de-identified as soon as it no longer has a business use. We periodically review the basis and appropriateness of our data retention policy
5. HOW WE TRANSFER INFORMATION INTERNATIONALLY
5 . 1 We collect information globally and primarily store that information in AWS is based in US- EAST- 1. 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. YOUR RIGHTS
6 . 1 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;
- your account is password-protected;
- 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 for record keeping purposes, to complete transactions, or to comply with our legal obligations);
- 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).
6 . 2 Our Platform enables you to update certain information about yourself, for example To update this information, users are able to access their respective profile sections and proceed with the necessary steps to modify their personal details.
6 . 3 You may opt out of receiving marketing materials from us Users have the option to unsubscribe via email. 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.
6 . 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.
6 . 5 Any request under paragraph 6.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded,repetitive, or excessive.
6 . 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.
7. CHANGES TO THIS POLICY
- We may amend this policy from time to time by posting the updated policy on our Platform.By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.
8. POLICY TOWARDS CHILDREN
- 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. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 16
9. CONTACT US
9 . 1 Please contact us at email@example.com or submit any written request to:
5X PTE. LTD.
68 Circular Road #02-01 Singapore 049422
5X PTE. LTD.
68 Circular Road #02-01 Singapore 049422
9 . 2 Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed
Last updated: 29th May 2023
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LEGAL BASES TABLE