EXPLORE PLATFORM PRIVACY POLICY

This privacy policy (“Explore Platform Privacy Policy”) is an integral part of the “Explore by CIALFO” Platform’s Terms of Services (“Terms of Services”).

Cialfo (“Cialfo”, “we”, “us” or “our”) respects your privacy and is committed to transparent privacy practices.

This Explore Platform Privacy Policy explains how Cialfo collects, uses and shares your and Customers’ personal information in connection with your use of the “Explore by CIALFO” Platform and the Services therein (hereinafter, the “Services”) as a Customer (as defined in the Terms of Services), and explains your choices for how we handle your and Customers’ personal information. In this Explore Platform Privacy Policy, references to “personal information” are equivalent to “personal data” governed by European Data Protection regulations.

We also have a core privacy policy for our general privacy practices. Please consult our Privacy Policy

1. Data Controller

Cialfo acts as a data controller when processing personal data of Customers using the Services.

2. Contact Us

If you have any questions about this Explore Platform Privacy Policy or want to exercise any rights you may have with respect to your personal data, as set out in this Explore Platform Privacy Policy, please contact us at: legal@cialfo.com.sg . Our mailing address is 52 Joo Chiat Rd, #02-01, Singapore 427374. Please mark all correspondence to us for the attention of the Data Protection Officer.

3. Information We Collect

Personal information about Customers can be collected in the following ways:

3.1 INFORMATION THAT CUSTOMERS GIVE US

Account and profile information: We collect information about Customers when they register for an account, create or modify their profile, set preferences, or sign up for our Services. Customers also have the option to add their phone number, job title, country of residence, and other details to their profile information. We keep track of Customers’ preferences when Customer selects settings within our Services.

Content that Customers provide through the Services: When Customers use our Services, we collect, store and process information and content that Customers post, send, receive, or share. We collect feedback that Customers provide directly to us through the Services and we collect clickstream data about how Customers interact with and use features in our Services.

Information that Customers provide through our support channels: Customers may choose to submit information to our customer support channels about any problems with our Services. Whether Customers designate themselves as a technical contact, open a support ticket, speak to one of our representatives directly, or otherwise engage with our support team, Customers will be asked to provide a summary of the problem and other documentation, screenshots, or any other information that our representative or our support team would consider to be helpful in resolving the issue.

3.2 INFORMATION WE COLLECT AUTOMATICALLY

Customers’ use of the Services: We keep track of certain information about Customers when they use our Services. This information includes: the features used; the links clicked on; the type, size, and file names of attachments uploaded to the Services; and how Customers interact with others on our Services.
Customers’ device information: We collect information about a Customer’s computer phone, tablet, or other devices used to access our Services. This device information includes a Customer’s connection type and settings when Customers install, access, update, or use our Services. We also collect information through Customers’ devices regarding the operating system, browser type, Internet Protocol (IP) address, URLs of referring/exit pages, device identifiers, and crash data. We use Customers’ IP address and/or country preference in order to approximate Customers’ location to provide Customers with a better experience. How much of this information we collect depends on the type and settings of the device used to access the Services.
Cookies and similar third-party tracking technologies: Cialfo and our third-party partners, such as our advertising and analytics partners, use cookies and other similar tracking technologies to provide functionality, analyze trends, track users’ movements around the website, and to recognize Customers across different devices. Most Web browsers are set to accept cookies by default. If Customers prefer, they can set Customers’ browser to remove cookies and to reject cookies. The removal or rejection of cookies could affect certain features of the Services. For further information, please visit our Cookies Policy.
Pixel tags: In addition, we also use ‘pixel tags’, also referred to as clear gifs, web beacons, or web bugs. Pixel tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel tags are embedded invisibly in Web pages. Pixel tags also allow us to send e-mail messages and determine whether those e-mails have been opened, to ensure that we are only sending messages that are of interest to our Customers. We may use this information to reduce or eliminate messages sent to a Customer.

3.3 INFORMATION WE RECEIVE FROM OTHER SOURCES

Other Customers of Cialfo: Other Customers may provide information about you when they use our Services. For example, we receive your email address from other Customers when they invite you to join Cialfo.
Integrations and partners of Cialfo: We may obtain additional information about Customers from our third party partners to enrich Customers experience on our Services.

4. How We Use Your Personal Information

4.1 TO PROVIDE THE SERVICES

If you have a Cialfo account, we use your personal information to:

Facilitate the creation of and securing of Customers’ Account; Identify you as a Customer of our Services;
Operate, maintain, administer and improve the Services; Provide and deliver the Services;
Manage and communicate with you regarding your Customer account, if you have one, including by providing the Customer with service announcements, technical notices, updates, security alerts, and support and administrative messages;
Communicate with Customers about promotions, upcoming events, and news about products and services offered by Cialfo, and for other marketing purposes of Cialfo;
Better understand Customers´ needs and interests, and personalize their experience with our Services;
Link or combine it with other information we get from third parties, to help understand Customers’ needs and provide Customers with better services; Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
Respond to Customers’ requests, questions and feedback.

The legal grounds under which we carry the above into effect are the fulfillment by us of the contractual relationship with you.

4.2 TO COMMUNICATE WITH CUSTOMERS

If Customers request information from us, sign up for Cialfo or participate in our surveys, promotions or events, we may send Customers, Cialfo-related marketing communications, if permitted by law, but will also provide you with the ability to opt out.

The legal grounds for carrying the above into effect are both the consent that you give us and the legitimate interests of Cialfo.

4.3 TO COMPLY WITH LAW

We use Customers’ personal information where we believe it necessary or appropriate in order to comply with applicable laws (of the relevant jurisdiction where the subsidiaries, holding companies or the group companies of Cialfo and/or the Customer operates/ is registered), lawful requests and legal processes, such as to respond to subpoenas or requests from government authorities.

The legal grounds for carrying the above into effect are the compliance purposes necessary for the fulfilment of legal obligations.

4.4 TO CREATE DATA FOR ANALYTICS

We may create data from Customers’ personal information and other individuals whose personal information we collect. This data is used to improve our Services and to conduct research and statistical and behavioral analysis.

The legal grounds for carrying the above into effect are both the consent that you give us and the legitimate interests of Cialfo.

4.5 TO CREATE ANONYMIZED DATA FOR CERTAIN FEATURES

We may create anonymized data records from personal information by excluding information that makes the data personally linked to Customers. We use this anonymous data to power certain Cialfo features, such as scattergrams. We reserve the right to use anonymous data for any purpose and to disclose anonymous data to third parties at our sole discretion.

The legal grounds for carrying the above into effect are the legitimate interests of Cialfo.

4.6 FOR COMPLIANCE, FRAUD PREVENTION AND SAFETY

We use Customers’ personal information where we believe it necessary or appropriate:

(a) to enforce the terms and conditions that govern our Services; (b) to protect our rights, privacy, safety or property, and/or that of you or others; and (c) to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

The legal grounds for carrying the above into effect are the legitimate interests of Cialfo.

5. Who We Share your Personal Information With

Our Explore Platform Privacy Policy does not cover any third party services. To learn about those third parties’ privacy practices, Customers should read the privacy policies of those parties.

We do not share or sell Customers’ personal information to or with other organizations without your express consent, except as described in this Explore Platform Privacy Policy. We disclose personal information to third parties under the following circumstances:

Educational Institutions. We may share personal information belonging to Customers, with Educational Institutions expressly selected by the Customer who will process them for the reported purposes and in accordance with their respective privacy policies. Actions by Customers can subscribe them to the Educational Institution where we may share personal information, these actions can include: participating in events, downloading brochures, subscribing, and applying to the Educational Institution. Educational Institutions receiving personal information may use it to contact Customers via email, SMS and other mediums; in case the Student applies and is accepted by the Educational Institution, the processing of such personal information will be undertaken by the Educational Institution and according to its own Privacy Policy; in case the Student is rejected/not accepted, the Educational Institution will no longer process the Student´s personal information.
Services Providers. We may employ third party companies and individuals to administer and provide the service on our behalf (such as customer support, hosting, email delivery and database management services). These third parties are permitted to use Customers’ personal information only to perform these tasks in a manner consistent with this Explore Platform Privacy Policy and are obligated not to disclose or use it for any other purpose.
Professional advisors. We may disclose Customers’ personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Lawful requests. Cialfo may disclose information about Customers to government or law enforcement officials or private parties as required by law of the relevant jurisdiction where the subsidiaries, holding companies or the group companies of Cialfo and/or the Customer operates/ is registered, and disclose and use such information where we believe it necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the service; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Business Transfers. Cialfo may sell, transfer or otherwise share some or all of its business or assets, including Customers’ personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Explore Platform Privacy Policy against fraudulent, harmful, unauthorized, unethical or illegal activity.

6. Rights

Customers may exercise the rights recognized in the current data protection regulations by sending a written notification to the Data Controller through the contact details indicated above. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

6.1 ACCESS, UPDATE, CORRECTION OR DELETION OF YOUR INFORMATION

Customers may review, update, correct or delete the personal information in their registration profile by logging into their account. Cialfo retains Customers’ data while they are “customers” and will delete the personal information upon written request.

6.2 MARKETING COMMUNICATIONS

If Customers do not wish to receive commercial communications from Cialfo, they can request the withdrawal of their consent to such communications at any time, by sending a request to the contact details set out in Section 2 of this Explore Platform Privacy Policy. Likewise, Customers will be able to unsubscribe or cancel their subscription by using the mechanism included within each commercial communication they may receive.

Customers have the right to file a complaint before the relevant Data Protection Authority should they consider that the processing of their personal information violates the applicable regulations.

6.3 TESTIMONIALS

If you gave us consent to post a testimonial to our site, but wish to update or delete it, please contact us using the contact details set out in Section 2.

6.4 TRACKING AND TARGETED ADVERTISING

We may allow service providers and other third parties to use cookies and other tracking technologies to track Customers´ browsing activity over time and across our Services.

In some of our communications, we use tracking means, such as a “click-through URL” linked to content on the site. We track this data to help us measure the effectiveness of our customer communications.

6.5 CHOOSING NOT TO SHARE YOUR PERSONAL INFORMATION

We may not be able to provide Customers with Services and may need to close a Customer’s account when required by law, or where the Customer fails to provide required information when requested, or where we are requested by Customer to delete required information.

7. Miscellaneous

7.1 SENSITIVE PERSONAL INFORMATION

We ask Customers to not send or disclose to Cialfo any sensitive personal information (e.g. credit card or debit card details, bank account numbers social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, sexual orientation, health (including physical/physiological/mental health), biometrics or genetic characteristics, criminal background or union membership) on or through our Services or otherwise.

If Customers send or disclose any sensitive personal information to us, it shall be deemed to have been so sent or disclosed with the Customer’s consent to our processing and use thereof in accordance with this Explore Platform Privacy Policy. Otherwise, Customers should not provide the same.

7.2 UPDATING OF CUSTOMERS’ PERSONAL INFORMATION

It is important that personal information is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your account or contacting us through the contact details set out in Section 2.

7.3 INFORMATION SECURITY

The security of personal information is important to us. We take a number of commercially reasonable organizational, technical and physical measures designed to protect the personal information that we collect, both during transmission and once we receive it.

However, no security safeguards are 100% effective. It is the Customers’ responsibility to protect their usernames and passwords to prevent anyone from accessing or abusing the Customers’ accounts and services. Customers should not use or reuse the same passwords that they use with other accounts or services.

7.4 INTERNATIONAL DATA TRANSFER

Cialfo is headquartered in Singapore and has affiliates and service providers in other countries. Customers’ personal information may be transferred to Singapore, Japan, or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

In addition, Cialfo personnel may need access to data stored in the EU from a non-EU country (e.g., U.S, Singapore, China or India) for technical and support related reasons.

7.5 OTHER THIRD-PARTY SITES AND SERVICES

The Services may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information that Customers submit to them. We encourage Customers to read the privacy policies of the other websites visited and services they may use.

7.6 USER GENERATED CONTENT

We may make available on our Services, or link to, features that allow Customers to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever Customers voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, Customers may receive unsolicited messages from other parties.

7.7 CHILDREN

We do not knowingly acquire or receive personal information from children under the age of thirteen (13). If you are under the age of thirteen (13), you are not permitted to submit any personal information to us. If we later learn that any user of our Services is under the age of thirteen (13), we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Services.

If you believe that we might have any personal information from a child under thirteen (13), please contact us using the contact details at Section 2.

7.8 CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Explore Platform Privacy Policy at any time. We encourage Customers to periodically review this page for the latest information on our privacy practices. Any material changes to this Explore Platform Privacy Policywill be announced via our website or other appropriate means.

Any modifications to this Explore Platform Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting).

In all cases, the continued use of the Services, by Customers, after the posting of any modified Explore Platform Privacy Policy indicates Customers’ acceptance of the terms of the modified Explore Platform Privacy Policy.