Effective date: June 1st, 2021.
Smulie Pte. Ltd. (“us”, “we”, or “our”) operates the smulie.io website and the Smulie’s applications mobile application (hereinafter referred to as the “Service”).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Service: Service means the smulie.io website and the Smulie’s applications mobile application operated by Smulie Pte. Ltd.
Personal Data: Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data: Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies: Cookies are small files stored on your device (computer or mobile device).
Data Controller: Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers): Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User): Data Subject is any living individual who is using our Service and is the subject of Personal Data.
We collect several different types of information for various purposes to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
Email address
Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.
You can enable or disable location services when you use our Service at any time by way of your device settings.
We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies: We use Session Cookies to operate our Service.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
Security Cookies: We use Security Cookies for security purposes.
Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Smulie Pte. Ltd. uses the collected data for various purposes:
To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
If you are from the European Economic Area (EEA), Smulie Pte. Ltd. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Smulie Pte. Ltd. may process your Personal Data because:
We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
For payment processing purposes
To comply with the law
Smulie Pte. Ltd. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.
Smulie Pte. Ltd. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside Singapore and choose to provide information to us, please note that we transfer the data, including Personal Data, to Singapore and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Smulie Pte. Ltd. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
If Smulie Pte. Ltd. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Under certain circumstances, Smulie Pte. Ltd. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Smulie Pte. Ltd. may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Smulie Pte. Ltd.
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Smulie Pte. Ltd. aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Smulie Pte. Ltd. relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Learn more about the login process with an email or Facebook connect at Accounts paragraph in Terms and Conditions.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Firebase. Firebase is an analytics service provided by Google Inc.You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: LINK. We also encourage you to review the Google’s policy for safeguarding your data: LINK. For more information on what type of information Firebase collects, please visit the Google Privacy & Terms web page: LINK.
Unity Analytics. Unity Analytics is provided by Unity Technologies. For more information on what type of information Unity Analytics collects, please visit their Privacy Policy page: LINK.
We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.
AdMob by Google. AdMob by Google is provided by Google Inc.You can opt-out from the AdMob by Google service by following the instructions described by Google: LINK. For more information on how Google uses the collected information, please visit the “How Google uses data when you use our partners’ sites or app” page: LINK or visit the Privacy Policy of Google: LINK.
AdColony. AdColony is provided by Jirbo Inc.You can opt-out from the AdColony service by visiting the AdColony Opt-out page: LINK. You can also opt-out from AdColony through the Digital Advertising Alliance in the USA: LINK or opt-out using your mobile device settings. For more information AdColony, please visit the Privacy Policy of AdColony: LINK.
AppLovin. AppLovin is provided by the AppLovin Corporation. If you’d like to opt-out from the AppLovin service, please visit the AppLovin Opt-out page: LINK. If you’d like to learn more about AppLovin, please visit the Privacy Policy page of AppLovin: LINK.
Vungle. Vungle is provided by Vungle Inc.You can opt-out from Vungle service by following the instructions as described by Vungle on their Privacy Policy page: LINK. For more information about Vungle, please visit Vungle Privacy Policy: LINK.
Unity Ads. Unity Ads is provided by Unity Technologies. You can opt-out from the Unity Ads service by following the instructions as described by Unity Technologies on their Privacy Policy page: LINK. For more information about Unity Technologies, please visit Unity Technologies Privacy Policy: LINK.
Smulie Pte. Ltd. uses remarketing services to advertise on third-party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.
Google Ads (AdWords). Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: LINK. Google also recommends installing the Google Analytics Opt-out Browser Add-on – LINK – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: LINK.
Facebook. Facebook remarketing service is provided by Facebook Inc.You can learn more about interest-based advertising from Facebook by visiting this page: LINK. To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: LINK. Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA: LINK, the Digital Advertising Alliance of Canada in Canada: LINK, or the European Interactive Digital Advertising Alliance in Europe: LINK, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: LINK
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These paymen
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