DejaVoo Privacy Policy
Welcome to the Dejavoo Privacy Policy (“Policy”)! This document outlines how we collect, store, and share your information while using our App (“App”), websites, and digital services (collectively referred to in this Policy as the “Sites”). Please review this in conjunction with our Terms and Conditions.
If you’re accessing the app or site from Singapore, please go to DATA PROTECTION NOTICE FOR DATA COLLECTED IN SINGAPORE.
Collection of Information
Registration Information
When you create an account on the App, we collect Registration Information, including your name, username, email address, cell phone number, gender identity, birth details, sexual preference, photographs, location, ethnicity, religion, height, weight, marital status, interests, videos, whether you have kids and login information for connected social media accounts. You can manage most information by logging into Dejavoo, except for date of birth and location
Profile Information
Exercise caution when sharing personal details on your profile. Avoid sharing sensitive information prone to misuse.
Profile Verification Information
To enhance safety, we may request phone number verification and, in some cases, photo verification using facial recognition technology. Verification photos are not added to your profile, and scans are retained for verification purposes.
Purchases Information
If you purchase credits, we'll handle your payment details using our third-party payment processors (Apple, Google, and Stripe) and keep records connected to your buying history for fraud prevention and auditing. Automated decisions may block transactions breaching our Terms and Conditions of Use.
Geolocation Information
When location access is granted, we collect WiFi and longitude/latitude data. This information enhances user interaction by displaying general locality to others and suggesting profiles of nearby users. Your precise coordinates will always remain undisclosed to any user. You can disable location access in app settings
Device and Photo Information
When you use the App, we may gather details about your device, such as its unique identifier, model, and operating system. If you grant permission, the App may access your device's address book to add contacts. Additionally, we analyze data related to your photos, including user engagement and lighting quality. This information is used to optimize the arrangement of your profile photos, and you can choose to opt-out through our app settings.
Links
We track your interaction with links on Dejavoo, including third-party services, by redirecting clicks or other means. Aggregate click statistics, such as the number of clicks on a particular link, may be shared.
Messages
We review message content within the App to identify topics, sentiments, and trends among our Users. We do not share the content of User messages or derived information with any third party.
Success Stories, Surveys, and Contributions
Occasionally, we conduct surveys for research purposes and may contact you for participation. We might also reach out for feedback, testimonials, or involvement in marketing campaigns. These initiatives are optional, and details will be provided at the point of contact. If you prefer not to be contacted, please inform our Customer Support Team.
Contacting Customer Support
When you contact our Customer Support team through our support page on the web or Contact us on the app, we receive your email address and may track your IP address. Communication records, including any complaints received about Users, are retained for 6 years after account deletion.
Cookies and Similar Technologies
During your visit to our Sites or when using our App, we automatically collect personal data through cookies or similar technologies. Kindly explore our Cookie Policy to gain a deeper understanding of how we utilize cookies and similar technologies.
Inferred Information
We might deduce specific details about you (like your income) from the information we gather.
Third-Party Information
When you utilize a third-party account, like Facebook, to log in or connect it to your account, we may obtain information (such as your name, birthday, handle, and profile photos) from that third party.
Use of Your Information
Our primary goal is to ensure your enjoyable experience on Dejavoo. To achieve this, we use your Registration and other information to:
Offer services and features
Provide App updates and new features information
Personalize the App/Sites and delivered content
Conduct research and analytics on App/Sites usage
Test new technologies for enhancement
Resolve disputes, troubleshoot issues, and enforce Terms & Conditions
Investigate fraud and protect legal rights
Send promotional information via direct marketing
Protect Users and third parties from harm
Create, maintain, and authenticate your account;
Process your payments (through third-party vendors) and complete transactions with you;
Communicate with you, including by sending announcements, updates, security alerts, and support and administrative messages;
Syncing Algorithms:
Our syncing algorithms predict compatibility based on the information you provide, app activity, photo verification, and device coordinates. The legal basis for processing this data is contractual necessity and legitimate interests.
Moderation Practices:
Automated systems and a moderation team monitor accounts and messages for content breaching Terms and Conditions. If an account or message meets specific criteria indicating a breach, actions may be taken, including warnings, access restrictions, or blocks. Users affected can contest the decision. Violations of Terms and Conditions may result in account termination or restricted access.
Research and Development:
We may anonymize personal information to be used in research and development initiatives, focusing on the analysis and improvement of the Sites while promoting our business.
Marketing and Advertising:
Direct Marketing: Either we or our advertising partners may forward direct marketing offers and communications in accordance with the law. This may include notifying you of special promotions, offers, and events through in-app messages, email, text messages, telephone, and, if you provide your address, postal mail.
Interest-Based Advertising: Collaborating with advertising partners, such as third-party advertising firms and social media companies, we may display ads on the App and other online services. These entities may use cookies and similar technologies to gather information about your interactions across the Sites, our communications, and other online services. This information is utilized to deliver online ads tailored to your interests, commonly referred to as interest-based advertising. Additionally, we may share anonymized user information with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
Compliance and Protection:
We may utilize your personal information for the following compliance and protection purposes:
Adherence to applicable laws, lawful requests, and legal processes, such as responding to subpoenas or requests from government authorities.
Safeguarding our, your, or others' rights, privacy, safety, or property, including making and defending legal claims.
Auditing our internal processes for compliance with legal and contractual requirements and internal policies.
Enforcement of the terms and conditions governing the Sites.
Prevention, identification, investigation, and deterrence of fraudulent, harmful, unauthorized, unethical, or illegal activities, including cyberattacks and identity theft.
Legal Basis
In compliance with EU and UK data protection laws, we are required to provide information on the legal grounds for using your data. The table below details the purpose, data, source, and legal basis for our data usage. If the legal basis is consent, you retain the right to withdraw it at any time. In cases where legitimate interests serve as the basis, you have the right to object, and instructions for withdrawal or opting out are explained in the relevant sections of this policy. Withdrawing consent may lead to service termination, loss of credits, loyalty benefits, missed promotions, and order fulfillment disruptions; you will not hold us responsible in such instances.
Purpose | Data | Source | Legal Basis |
---|---|---|---|
Provide Dejavoo Social Networking Service | Name, email, date of birth, location | User input and device location | Contractual necessity |
Facilitate Networking Opportunities on Dejavoo App | Optional profile information (e.g., sexual preferences, religion, ethnicity) | User input | Contractual necessity, Legitimate interests |
Verify Identity, Prevent Fraud, Ensure Safety | Phone number, photo, geolocation, device information | User input and device | Legitimate interests |
Take Payment for Premium Services | Payment card details | User input | Contractual necessity |
Send Marketing Information | Name, email, address, Instagram handle, phone number | User input | Consent, Legitimate interests |
Research and Analysis for App Improvement | Log and usage data, IP address, browser info | User input and device | Legitimate interests |
Respond to Queries | Email, IP address, social media name, phone number | User input and device | Legitimate interests |
Investigate and Block Users for Breaches | Name, registration details, profile info, messages, photos, usage and device data | User input and device | Legitimate interests |
Improve User Experience on the App | Data about profile photos | User interactions with App | Legitimate interests |
Enable Profile Creation via Third-Party Accounts | Data from Facebook and other third-party accounts | Third-party providers | Legitimate interests |
Block Payment Transactions for Anti-Fraud | Name, email, mobile number, card details | User input and device | Legitimate interests |
Serve Promo Cards and Advertisements on the App | Location, gender, age, profile info | User input and device location | Legitimate interests |
Serve Advertisements on Third-Party Networks | Data about App visit, IP address, age, gender, device ID | User input and device | Consent |
Contact for Surveys, Feedback, and Marketing Campaigns | Email address, cell phone number | User input | Legitimate interests |
Enable Video and Audio Call Functions | Video and audio call data, images, and video | Device | Legitimate interests |
Defend Legal Claims and Protect Rights | Relevant information to the issue | User, device, or third parties | Legitimate interests |
Processing payments for premium services (not applicable for users making payments via the App Store) | Collection of payment card details | Users provide this information | Contractual necessity |
SHARING OF INFORMATION
Neither do we sell nor have we ever sold your personal information. Our commitment is to uphold the confidentiality of your Registration Information and personal data, with only specific instances allowing disclosure:
Circumstances where data may be disclosed | Disclosed data |
Service Providers | We enlist certain trusted third parties to execute functions and deliver services. Your Registration Information or personal data may be shared with these entities, exclusively for the purpose of executing functions and providing services. |
Moderators | For the supervision of App activity and approval of content. Name and user registration details, profile information, content of messages, and photographs. |
Payment Processing and Telecommunications Companies | To facilitate payments for our premium services. Cardholder name, cardholder address, card number, payment amount, transaction date/time. |
Law and Cooperation | We work with third parties to uphold intellectual property rights and respond to law enforcement investigations. We may disclose information, including Registration Information, in good faith: - To comply with a court order or lawful request. - To ensure the safety of individuals. - To address fraud, security, or technical issues (e.g., through anti-spam providers). - To protect our rights, property, or those of third parties. In such cases, we may raise or waive legal objections or rights, potentially involving personal data held by Dejavoo based on the request or issue's nature. |
Business Transfers | In the event of a business transition or change of ownership within App Brewery Private Limited or its affiliates, such as a merger, acquisition, re-organization, or asset sale, or in the case of insolvency or administration, your personal data may need to be disclosed. This may involve all personal data held by Dejavoo about you |
Marketing Services Providers | We use advertising identifiers (Device ID), estimated location (from your IP address), age, gender, and data related to your visit and actions on our Sites or App for marketing and advertising on third-party platforms. This may include hashed email addresses for 'custom audiences' only. |
Anti-Spam and Anti-Fraud | We may share your data with other App Brewery Private Limited entities to prevent account abuse and fraudulent transactions. This includes email address, phone number, IP address, session information, social network ID, username, user agent string, and transaction/payment data. |
Aggregated Information | We may share aggregated information with third parties, incorporating your personal data (without direct identification) along with other data, including log data, for industry analysis and demographic profiling. |
MORE INFORMATION ABOUT DISCLOSURES
Service Providers
We enlist trusted third parties ("Service Providers") to execute functions and offer services. The selection of suppliers with whom Dejavoo shares user personal data depends on factors like the engaged App, Sites, and services. For instance:
Billing services - Facilitating the purchase of paid App features, such as Google Play.
Authentication services - Enabling account authentication, for example, through Firebase.
Social media providers - Allowing users to link their Dejavoo account with platforms like Facebook, Instagram, or Spotify.
Product improvement and market research - Employing third-party platforms and agencies for customer surveys and market research.
We conduct due diligence on Service Providers to ensure data protection and information security measures. The shared data is made non-attributable whenever possible, and suppliers adhere to stringent obligations under contractual arrangements.
Marketing Services Providers
Collaboration with marketing services providers (e.g., Facebook) aids in marketing the App and services on third-party platforms. Examples include:
Excluding users from campaigns targeting new users if they already have a Dejavoo account.
Displaying Dejavoo ads to users who visited the App/Sites but haven't created an account yet.
Creating custom audiences based on user characteristics for targeted advertising.
Limited personal data is shared, including advertising identifiers, estimated location, age, gender, visit data, and a hashed version of the email address. Hashing encrypts information, and hashed email addresses are matched with the provider's list for ad targeting.
In some cases, these third parties may use collected data for their own purposes, aggregating it for advertising-related services.
In instances where we share data with Facebook, including through the utilization of the Facebook "Like" function, it is essential to note that we function as Joint Data Controllers alongside Facebook in managing this processing. This collaborative arrangement necessitates us to provide you with this notice. However, if you intend to exercise your data protection rights, we recommend reaching out to Facebook directly.
For comprehensive details on how Facebook facilitates the exercise of your data protection rights and subsequently manages your information as an autonomous data controller, you can refer to the Facebook Data Policy.
The data mentioned above encompasses your actions on our website, encompassing interactions with our Sites, and additional information gathered through cookies or analogous technologies, such as the Facebook pixel. This framework enables us to gauge the effectiveness of our advertising efforts, refine our marketing strategies, and ensures the delivery of more pertinent advertisements to you and individuals with similar preferences, including on social media platforms like Facebook.
The shared data includes actions on the website, interactions with Sites, and information collected from cookies, facilitating effective advertising and improving marketing practices.
5. INFORMATION VISIBILITY
Dejavoo encourages users to showcase their awesomeness but advises caution as posted content may be publicly viewable. Sensitive details, including religious and health information, should be shared carefully. Users may voluntarily add sensitive information, consenting to its processing and public visibility.
Profiles and information may be viewed and shared by App users and non-users. Users are reminded to log out on shared devices and exercise care in certain countries where downloading conversation history is allowed.
6. AGE POLICY
Dejavoo is designed for users aged 18 and above. No information is knowingly collected from or marketed to individuals under 18. Steps are taken to terminate registrations if such instances are identified.
7. SECURITY
Dejavoo prioritizes security measures to protect against unauthorized access. While no system is entirely foolproof, users are advised to log out, keep passwords secure, and promptly address any suspected breaches.
8. LINKING ACCOUNTS TO Dejavoo
Using Social Media Details:
Signing in with Facebook or Apple ID permits data sharing, including name, profile picture, email, and more. This data forms the Dejavoo account but can be removed by adjusting Facebook or Apple ID settings.
Linking Social Media Accounts:
Linking Instagram, Facebook, or Spotify accounts allows sharing specific information. Users can control access permissions and remove links via social media settings.
Please note that information added to the Dejavoo account from linked platforms won't be deleted unless removed within the Dejavoo account.
10. YOUR PRIVACY RIGHTS
The privacy laws applicable in your country may afford you the following rights:
Right to be Informed: You have the right to know what personal data an organization is processing and why, as detailed in this Privacy Policy.
Right of Access: You can request a copy of your data.
Right of Rectification: If the held data is inaccurate, you have the right to request correction.
Right to Erasure: In certain circumstances, you can request the deletion of your data.
Right to Restrict Processing: In limited cases, you can request that processing is halted while retaining the data.
Right to Data Portability: You can request a machine-readable copy of specific data for transfer to another provider.
Right to Object: In certain situations, including data processed on legitimate interests or for marketing, you may object to the processing.
Rights related to Automated Decision-Making: If solely automated processing leads to legal or significant effects, you have the right to ensure human intervention in the decision-making process.
The specific rights applicable to you may vary based on your country. Familiarize yourself with your rights under applicable privacy laws.
DATA LOCATIONS
Data is stored in servers in the US. Data collected by Advertising Partners and Service Providers may be stored outside the UK and EEA. Your personal information may undergo processing within the United States or be transferred to other jurisdictions where privacy laws may not provide a commensurate level of protection as those prevailing in your state, province, or country.
DATA RETENTION AND DELETION
We retain personal information as long as needed for legal and permitted purposes. Deactivated accounts are not viewable in the App after 28 days. However, data may be retained for legal compliance, evidentiary purposes, dispute resolution, or legitimate business interests.
In order to mitigate the potential for misuse or abuse of Dejavoo by a user post-termination or profile/account deletion, we will retain information deemed, at our sole discretion, necessary. This retention aims to prevent the user from creating a new account and profile in violation of our Terms of Service and to ensure adherence to all pertinent laws and regulations.
Even after removal, copies of information may be accessible if shared previously. We disclaim liability for this. Third-party applications or websites may retain information as per their terms.
CHANGES TO THIS POLICY
As Dejavoo evolves, this Privacy Policy may be revised. The most current version of the policy will govern our use of your information and will be available at Dejavoo.date/privacy. Material changes will be notified, for instance, via email or notices within Dejavoo, or posted here.
DATA PROTECTION NOTICE FOR DATA COLLECTED IN SINGAPORE
This Data Protection Notice (“Notice”) sets out the basis on which App Brewery Private Limited. (“we”, “us”, or “our”) may collect, use, disclose, or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose, or process personal data for our purposes.
PERSONAL DATA
As used in this Notice:
“User” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us by creating an account on Dejavoo for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a user who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, billing address, shipping address, audio recordings, video recordings, and bank account number.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written/digital consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Here are information that we collect about you:
Registration Information:
Name
Username
Email address
Cell phone number
Gender identity
Date, time, and location of birth
Sexual preference
Photographs
Location
Login information for linked social media accounts (e.g., Facebook)
Profile Information:
Details about yourself
Information shared in messages with other users
Profile Verification Information:
Phone number
Photo verification (may involve facial recognition technology)
Purchases Information:
Payment information for premium services
Geolocation Information:
Longitude and latitude
WiFi access points
Device coordinates (if location access is granted)
Device and Photos Information:
Unique device identifier
Device model and operating system
Access to device's address book (with user permission)
Data about user photos (e.g., user interactions, lighting preferences)
Links:
Tracking of user interaction with links on the app
Messages:
Review of message content for analysis
Dejavoo Success Stories, Surveys, and Contributions:
Survey responses
Feedback
Testimonials
Participation in marketing campaigns
When You Contact Customer Support:
Email address
IP address
Information provided in communications with the Customer Support team
Cookies and Similar Technologies:
Automatically collected personal data using cookies or similar technologies when visiting the app or website.
We may collect and use your personal data for any or all of the following purposes:
Offering Services and Features:
Providing Dejavoo services and features to users.
Communication:
Contacting users with information about the app (e.g., updates and new features).
Personalization:
Personalizing the app/sites and content delivery to users.
Research and Analytics:
Conducting research and analytics on user interaction with the app/site, as well as to improve the app and test new technologies.
Testing New Technologies:
Testing new technologies and processes to enhance and improve the app/sites.
Dispute Resolution:
Resolving disputes, troubleshooting problems, and enforcing Terms & Conditions.
Fraud Prevention:
Investigating fraud, protecting legal rights, and enforcing Terms & Conditions.
Marketing:
Sending information about promotions and offers through direct marketing or other communication modes.
Periodically sending you marketing or promotional details regarding products and services offered by us or our third-party sellers on our Platform.
User Protection:
Protecting users and third parties from harm.
Syncing Algorithms:
Using syncing algorithms to predict compatibility with other users and show relevant profiles.
Moderation Practices:
Monitoring and reviewing accounts and messages for compliance with Terms and Conditions.
Improving User Experience:
Analyzing user interactions to improve the overall user experience.
Profile Verification and Safety:
Verifying user identity, preventing fraud, and ensuring the safety and security of users.
Payment Processing:
Taking payment for premium services (not applicable for Apple App Store payments).
Customer Support:
Responding to user correspondence and queries submitted to customer support.
Terms and Conditions Enforcement:
Investigating and blocking users for reported infringements of Terms and Conditions.
Profile Enhancement:
Improving user profiles and facilitating access to the app via third-party accounts.
Anti-Fraud Procedures:
Blocking payment transactions as part of anti-fraud procedures.
Ad Serving:
Serving promotional cards and advertisements on the app.
Ad Serving on Third-Party Networks:
Serving advertisements on third-party networks and measuring their effectiveness.
Surveys and Feedback:
Contacting users for research surveys, feedback, and marketing campaigns.
Video and Audio Call Functions:
Enabling video and audio call functions, and the sending of images and video.
Legal Defense and Protection:
Defending legal claims, protecting legal rights, and protecting people from harm.
Performing Obligations:
Performing obligations in the course of or in connection with the provision of requested goods and/or services.
Verifying Identity:
Verifying the identity of users.
Handling Queries and Requests:
Responding to, handling, and processing queries, requests, applications, complaints, and feedback.
Managing Relationship:
Managing the relationship between users and the app.
Processing Payment Transactions:
Processing payment or credit transactions.
Compliance with Laws:
Complying with applicable laws, regulations, codes of practice, guidelines, or rules, and assisting in law enforcement and investigations conducted by governmental and/or regulatory authorities.
Other User-Provided Purposes:
Any other purposes for which users have provided information.
Transmitting Information:
Transmitting information to unaffiliated third parties, including third-party service providers, agents, and relevant governmental and/or regulatory authorities, for the aforementioned purposes.
Incidental Business Purposes:
Any other incidental business purposes related to or in connection with the above.
Disclosure of Personal Data:
Service Providers:
Disclosed Data: All data, including information listed above.
We share Registration Information or personal data with trusted third parties for specific functions and services.
Moderators:
Disclosed Data: Name, user registration details, profile information, content of messages, and photographs.
Moderators monitor App activity and approve content.
Payment Processing and Telecommunications Companies:
Disclosed Data: Cardholder name, cardholder address, card number, payment amount, transaction date/time.
Shared to facilitate payments for premium services.
Law and Harm:
Disclosed Data: Any personal data that Dejavoo holds about you, depending on the nature of the request or issue.
Cooperation with law enforcement requests and disclosure in cases of criminal behavior or to protect vital interests.
Business Transfers:
Disclosed Data: All personal data that Dejavoo holds about you.
Disclosure in the event of business transitions, change of ownership, merger, acquisition, or sale of assets.
Marketing Services Providers:
Disclosed Data: Advertising identifier, estimated location, age, gender, data about visit/actions on Sites or App, hashed email address (for 'custom audiences').
Shared to serve marketing and advertising on third-party platforms and measure campaign effectiveness.
Anti-Spam and Anti-Fraud:
Disclosed Data: Email address, phone number, IP address, IP session information, social network ID, username, user agent string, transaction and payment data.
Data sharing with App Brewery Pte. Ltd. and its affiliates for anti-spam and anti-fraud procedures.
Aggregated Information:
Disclosed Data: Aggregated information that includes personal data (non-identifiable) and other information for industry analysis and demographic profiling.
Service Providers:
Dejavoo engages trusted third-party Service Providers for various functions such as billing services, authentication services, social media integration, and product improvement.
Due diligence is conducted on Service Providers to ensure data protection measures, non-attribution, and compliance with contractual obligations.
Marketing Services Providers:
Marketing Services Providers assist in marketing and advertising Dejavoo on third-party platforms.
Limited personal data, such as advertising identifier, estimated location, age, gender, and visit/action data, is shared with Marketing Services Providers.
Data is used for targeted advertising, creating custom audiences, and measuring campaign effectiveness.
Cookies and Tracking Technologies:
Dejavoo uses cookies and tracking technologies.
Third-Party Use of Data:
Third party service providers, agents and other organisations may use collected data for their purposes, including aggregation with other data for advertising-related services provided to other clients.
Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
DEEMED CONSENT BY NOTIFICATION
We may collect or use your personal data or disclose existing personal data for secondary purposes that differ from the primary purpose for which it was originally collected. If we intend to rely on deemed consent by notification for such secondary purposes, we will notify you of the proposed collection, use or disclosure of the personal data by updating our Privacy Policy
In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
i. last visit details;
ii. IP address;
iii. approximate location; and
iv. browser.
You will be given 7 calendar days to inform us if you wish to opt-out of the collection, use, and disclosure of your personal data for such purposes after their information is updated on this Notice.
After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes. It will take at least 14 working days for your request to take effect
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of us or another person. In relying on the legitimate interests exception of the PDPA, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a. Fraud detection and prevention;
b. Detection and prevention of misuse of services;
c. Network analysis to prevent fraud and financial crime, and perform credit analysis; and
d. Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws and it might lead to this might lead to service termination, loss of credits, loyalty benefits, promotion opportunities, and fulfillment of orders.
ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Requests for access or correction incur a fee, and fulfillment of certain conditions is required. Failing to meet both the fee and specified conditions, we are not obligated to respond to such requests.
We will respond to your request as soon as reasonably possible. In general, our response will be within 7 business days. Should we not be able to respond to your request within 30 calendar days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as:
Minimized collection of personal data
Authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.)
Encryption of data
Regular patching of operating system and other software
Securely erase storage media in devices before disposal
Web security measures against risks
Usage of one-time password (OTP)/2-factor authentication (2FA)/multi-factor authentication (MFA) to secure access
Security review and testing performed regularly
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Even after deletion, others may still access or view your information if shared or stored previously. We are not liable for this. Third-party applications or websites with access to your data may retain it according to their terms or privacy policies.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
By using the App or site, you acknowledge that Dejavoo can operate through servers in multiple countries, including the United States. You agree to the transfer, storage, and processing of your personal information in these countries. The list of countries involved may be updated periodically. We will inform users of any changes to this country list by posting updates on this privacy policy.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, at [email protected]
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
Last Updated date: 15 December 2023