April 2020

Togglr Web Services Pte Ltd. and its affiliates and subsidiaries (collectively “Togglr”) respect the privacy of our customers and users. Please take time to read this Privacy Policy (“Privacy Policy”) as we believe it is important for our customers and users to understand how we collect, process and use personal data.

By using the products and services, website or portals, you consent to the data we collect and how we use and share it in accordance with this Privacy Policy. If you do not agree with the data we collect and how we use and share it, you should not use the products and services, website, or portals.

What Data We Collect
and How We Use It

Togglr’s customers and users voluntarily provide us with data when they purchase or use our products and services (together, “Products and Services”) and access our website or portals (“Website” or “Portals”). Some of this data includes “Personal Data”, which is data that can be reasonably used to identify, either directly or indirectly, an individual or reasonably can be linked to a particular individual (“Personal Data”).

 

Categories of
Information
Collected

Purposes of
Use

Sources of Personal
Information

Account Registration Information:

Name
Address
Email & Contact information
Username & Password
Account Information

 

  • To communicate with you
  • To provide services
  • To personalize your experience
  • To secure our service and users
  • To prevent from fraud and legal purposes

 

  • Your personal data
  • Our affiliates
  • Secondary sources of information about you in connection with their use of the services

Financial and Transactional Information:

Credit Card / Debit Card Net Banking / Banking Payment Details / Sources

 

  • To provide services.
  • To secure our services and users
  • To prevent from fraud and legal purposes

 

  • Your personal data
  • Third-party payment processors who collect this information on our behalf and who also have an independent relationship with you

Customer Content:

Information provided by customers stored, processed, maintained or transmitted using our products and services in person / documents / files

 

  • To provide services.
  • To secure our services and users
  • To prevent from fraud and legal purposes

 

  • Your personal data
  • Secondary sources of information about you in connection with their use of the services

Device Information and
Identifiers:

The configuration of any device registered for use in connection with the products and services, including any hardware delivered as part of the products and services (each a “Device”); also IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifier

 

  • To communicate with you
  • To provide services.
  • To personalize your experience
  • To secure our service and users
  • To prevent from fraud and legal purposes

 

  • Your personal data
  • Analytics providers
  • Cookie and tracking technologies

Other information:

Any other information you choose to directly or indirectly provide to us in connection with your use of the products and services, website or portals

 

  • To communicate with you
  • To provide services.
  • To personalize your experience
  • To secure our service and users
  • To prevent from fraud and legal purposes

 

  • Your personal data
  • Secondary sources of information about you in connection with their use of the services
 

Automated Decisions: To the extent permitted by applicable law, Togglr may collect data in an automated manner and make and use automated decisions about customers, including using machine learning algorithms, in order to provide or optimize the products and services, for security or analytics purposes, to display advertisements and offers based on individual preferences and for any other lawful purpose.

Aggregate Information: To the extent permitted by law, Togglr may use, process, transfer and store customer and user data in a non-personally identifiable, anonymous (or pseudonymous) or aggregated manner. We may combine such data with other information collected, including information from third-party sources. By using the products and services, our customers and users agree that we may collect, use, share and store anonymized (or pseudonymized) aggregated data collected through the products and services for benchmarking, analytics, metrics, research, reporting, machine learning and other legitimate business purposes.

Purposes of Use of Data

Communication Purposes:

  • To respond to your requests for information and to provide you with effective and efficient customer service and technical support
  • To provide you with transactional updates and information about the services (e.g., inform you about updates to our services, information about your account, or information about transactions that you conduct on the services)
  • To provide you with marketing materials (in accordance with applicable law)
  • To reach out to you in accordance with applicable legal requirements (contacting you by email, postal mail, phone, or other means for marketing purposes)

Provision of Services:

  • To process and fulfill your requests for using the services.
  • To engage in analysis, research, and reports to understand how you use the services
  • To backup, restore, and archive of data.
  • To understand and resolve crashes and other issues being reported.
  • For recordkeeping and billing purposes

Personalize your Experience:

  • To customize the content on the services based on your usage.
 

Secure our Services and Users:

  • To monitor, prevent, and detect fraud
  • To combat spam or other malware or security risks.
  • To monitor, enforce, and improve the security of our services.

Fraud Detection and Prevention, Defending our Legal Rights and Compliance with the Law:

  • To comply with any applicable procedures, laws, and regulations where it is necessary for our legitimate interests or the legitimate interests of others.
  • To establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others (e.g., to enforce compliance with our Terms of Use, Privacy Policies, or to protect our services, users, or others).

The Legal Basis for Collecting and Using the Personal Data Described Above will Depend on the Personal Data Concerned and Specific Context in Which We Collect it, such as:

  • With customer or user consent, e.g., to receive marketing materials if necessary under applicable law.
  • Where the processing is necessary for the performance of a contract, e.g., to facilitate backing-up and restoring data, for archiving purposes, or to provide technical support.
  • Where necessary to comply with law.
  • Where the processing is necessary for the purposes of our legitimate interests, taking into account individual interests. Our legitimate interests include providing the products and services, internal record-keeping and administrative purposes and to operate, maintain and improve the website or portals.
How We Use Cookies and
other Technologies

We use certain automatic data collection technologies such as cookies, web beacons, pixel tags and other technologies to collect data, including personal data, when users or customers visit the website or portals, use the products and services or interact with us, and may share this data with our third-party marketing vendors (including for example, advertising networks and providers of external services like web traffic analysis services and analytics tools). We explain these technologies below:

Cookies: Cookies are small text files placed on a computer by a web server when browsing online and are used to store user preference data so a web server doesn't have to repeatedly request this information. A user may block cookies by activating the settings on the browser that blocks all or some cookies. However, if a user blocks all cookies (including strictly necessary cookies), a user may not be able to access all or parts of our website or portals.

We use the following types cookies:

  • Strictly Necessary Cookies: These cookies are required to operate our website and portals. They include, for example, cookies that enable a customer to log-in to secure areas of our website and portals and use e-commerce.
  • Analytical and Performance Cookies: These cookies allow us to recognize and count the number of users visiting our website and portals and see how those users navigate our website or portals. This helps us to improve our website and portals.
  • Functionality Cookies: These cookies recognize a user that returns to our website or portals. This enables us to personalize our content, greet the user by name and remember preferences, for example, choice of language or region.
  • Targeting Cookies: These cookies record visits to our website or portals and the links followed. We use this information to improve our website or portals and ensure the advertising displayed relates to users.

Web Beacons: A web beacon is a small pixel incorporated into a web page or email to keep track of activity on the page or email. A web beacon helps us better manage the content of our website by informing us of what content is effective.

Cross-device Tracking: We may use third-party cross-device tracking. For example, a user may use multiple browsers on a single device, or use various devices, which can cause the customer having multiple accounts or profiles across various devices. Cross-device tracking may connect these various accounts or profiles and the corresponding data from different devices.

Global Data Management

Togglr is a global organization and data collected by us, including personal data, may be transferred or accessed by Togglr’s subsidiaries and affiliates in other countries around the world regardless of a customer or user country of residence. By using the products and services, website or portals or by providing personal data to us, customers and users acknowledge and agree that personal data may be sent to and processed in countries outside your country of residence, including the Singapore. For individuals residing in the European Economic Area (“EEA”), and for personal data subject to European data protection laws, this includes transfers outside of the EEA. Some of these countries may not have data protection laws that provide an equivalent level of data protection as the laws in your country of residence, however, we will take steps to ensure personal data is handled in accordance with the EU-U.S. and Swiss Privacy Shield Frameworks and / or the General Data Protection Regulation, as applicable.

When and Why We Share
Your Personal Data

The Singapore Consumer Privacy Act sets forth obligations for businesses that “sell” personal information. Togglr does not engage in such activity based on our current understanding of the definition of sell. We may share certain personal information with other businesses or allow them to collect certain personal information through the use of website cookies, pixels, or other technologies in order to provide services to us such as analyzing our services and advertising and marketing our services on other sites or apps. You can control certain of these cookies through browser settings and other controls.

Under Nevada law or any specific country law, certain consumers may opt out of the “sale” of “personally identifiable information” as such terms are defined under Nevada law. However, we do not engage in such activity. If you have questions about this, you may contact us at info@togglr.com. We do not access customer stored data that is protected by our products and services for marketing purposes.

Togglr may share categories of information about you or your use of the products and services for the reasons set forth below. Such categories of information may include:

Identifiers: (such as name, address, email address); commercial information (such as transaction data); financial data (such as credit card information); internet or other network or device activity (such as browsing history or app usage); geolocation information, and other information that identifies or can reasonably be linked to you.

Service Providers: Togglr may share any category of data it collects, including personal data, with our contracted third-party service providers (“Service Providers”) in order to provide our products and services, website or portals. We may share personal data with service providers who administer surveys and perform user analysis to better understand user needs and preferences. These service providers include business partners, payment and delivery services, advertising networks, analytics providers, credit reference agencies, social media companies, email distributors, marketing automation partners, customer survey companies, data storage and hosting partners, IT specialists and product developers.

Legal Purposes: Togglr may share any category data it collects, including personal data, as necessary to comply with law, court orders, governmental agencies, for the administration of justice, to protect vital interests, to protect the security or integrity of Togglr’s databases, products and services, website or portals, or to take precautions against legal liability.

Sale: In the event of a merger, consolidation, or acquisition of all, substantially all or a portion of Togglr’s business or assets, Togglr may share data, including personal data. Customers and users acknowledge and agree that data, including encrypted stored data and personal data that Togglr has collected, may be securely shared, disclosed and transferred to such successor or assignee.

Opt-Out of Marketing

Customers and users can opt-out of receiving marketing and promotional communications from Togglr by emailing or contacting customer support at support@togglr.com or, mailing Togglr Web Services Pte Ltd, 1, Scott Road, #21-08 Shaw Center, Singapore - 228208.

We will continue to process personal data to deliver operational and service-related communications relating to purchases, changes to products and services or policies, and other purposes as permitted by law.

Retention of Data

We may retain data, including personal data, for as long as necessary to deliver the products and services or for other lawful purposes. We may retain anonymized or pseudonymized, aggregated data indefinitely or to the extent permitted under law.

Your Rights

Subject to data protection laws, customers and users may have the following rights regarding Togglr’s handling of personal data. Certain information may be exempt from such requests under applicable law.

We will take reasonable steps to verify your identity when exercising these rights. To exercise these rights, you or your agent may be required to authenticate to your account or provide information contained in your account profile. Please ensure that you keep your profile information up to date and accurate so that we may verify your requests.

Access: The right to access personal data held by Togglr. Customers in Singapore may request the categories of personal information we collect, disclose, or sell about you, the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Those users may also request access to or a copy of certain information we hold about you.

Rectification: The right to request correction of personal data that is incomplete, incorrect, unnecessary or outdated.

Right to be Forgotten: The right to request erasure of all personal data that is incomplete, incorrect, unnecessary or outdated within a reasonable period of time. Togglr will do everything possible to erase personal data if a user or customer so requests. However, Togglr cannot erase all personal data if it is technically impossible due to limitations of existing technology or for legal reasons, such as Togglr is mandated by law to retain personal data.

Restriction of Processing: The right to request restriction of processing personal data for certain reasons, provided Togglr does not have an overriding, legitimate interest to continue processing.

Data Portability: If requested, Togglr will provide personal data in a structured, secure, commonly used and machine-readable format.

Right to Withdraw Consent: If personal data is processed solely based on consent, and not based on any other legal basis, customers can withdraw consent at any time.

Data Protection Contact: The right to contact the relevant data protection regulator regarding Togglr’s handling of personal data.

To exercise any of the above listed rights, email Togglr at info@togglr.com, contact customer support or the appropriate or mail Togglr Web Services Pte Ltd, 1, Scott Road, #21-08 Shaw Center, Singapore – 228208. Togglr will process requests in accordance with applicable law and within a reasonable period of time.

Singapore law provides Singapore residents with the right to not be discriminated against (as provided for in applicable law) for exercising these rights or their right to opt-out of sales of personal information. Please note that certain information may be exempt from such requests under Singapore law.

Togglr as a Data Controller
and Processor

Togglr acts as a data controller when we collect and process personal data for Togglr’s legitimate interests, such as analyzing user interaction with our website or processing a customer credit card payment. Togglr acts as a data processor when we provide products and services to our customers, such as remote troubleshooting technical support. When acting as a data processor, Togglr will only process personal data in accordance with customer instructions and this Privacy Policy. Togglr’s affiliates or subsidiaries may also act as data controllers or processors to the extent customers purchase products and services from those entities or personal data is shared with those entities.

Do Not Track

Togglr belongs to advertising networks that may use browsing history across participating websites to show interest-based advertisements. Our products and services do not recognize if a browser sends a “do not track” signal or similar mechanism to indicate the wish not to be tracked or receive interest-based advertisements.

Security

Togglr and its global third-party cloud storage providers have reasonable and appropriate technical and organizational security measures in place to protect against unauthorized processing, loss, misuse and alteration of personal data under its control, including: (a) Pseudonymization (such as where data is separated from identifiers so that linkage to an identity is not possible without additional information that is stored separately) and encryption, (b) Ensuring the ongoing confidentiality, integrity, availability and resilience of systems and services used to process personal data, and (c) Ensuring a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational security measures. We cannot, and we do not believe that anyone can, genuinely guarantee or warrant absolute security of personal data disclosed or transmitted via the internet to us or a third-party. Absent Togglr’s gross negligence, customers and users agree to not hold Togglr responsible for the theft, destruction, loss, damage or inadvertent disclosure of personal data or other data provided to Togglr.

Linking

The website and portals may contain links to third-party websites that Togglr does not control or maintain. Togglr is not responsible for the privacy practices employed by these third-party websites. Togglr encourages users to read the privacy statements of such other websites before submitting any personal data.

Regarding Children

Togglr does not knowingly collect or distribute any personal data from children under 13 years old. If a child under 13 years has provided Togglr with personal data, the parent or guardian of that child should contact Togglr immediately at info@togglr.com to delete this personal data.

Changes to Togglr's
Privacy Policy

As laws and best practices evolve, this Privacy Policy will likely change. By continuing to access our website and portals or using our products and services, users and customers acknowledge and accept the Privacy Policy as revised. We encourage you to periodically review this policy to stay informed about how we collect, use and disclose personal data. If we update this statement, the new statement will be posted to the website ten (10) days prior to the changes taking effect. If we make a material change to the Privacy Policy, you will be provided with appropriate notice in accordance with legal requirements. At such time, your continued use of the services after notice of posting or notice of such changes constitutes Your agreement to this latest version of this policy and any future revisions.

Contact Togglr

To contact Togglr’s Data Privacy Officer, or for questions related specifically to the EU-U.S. or Swiss Privacy Shield Frameworks or the General Data Protection Regulation, or for questions related to this Privacy Policy generally, please email info@togglr.com.

 
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