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Data Request Policy

 

Last modified: 12 April 2021

Effective Date: 12 April 2021

Ringl Technologies Pte. Ltd., a private company registered in the Republic of Singapore with its registered office at 84 Genting Lane #07-01 Axxel Innovation Centre Singapore 349854 (together with Ringl Technologies Pte. Ltd.’s current and future subsidiaries and affiliates, “RINGL,” “we,” “us,” or “our”) provides inter alia voice, video and chat messaging, and Internet calling services on and through our RINGL Application, which is designed to operate on mobile devices and personal computers with the use of Internet.

This Data Request Policy is part of, and incorporated into, our [Privacy Policy]. Please review this Data Request Policy in conjunction with our [Privacy Policy] and other posted policies carefully, before you create an Account with us or before you use or access our Services. By installing, creating an Account, accessing or using any of our Services, you hereby confirm that you accept the terms of this Data Request Policy (which shall constitute a binding agreement between you and us) and agree to comply with them. Capitalised or other terms used herein but not defined or given interpretation in this Data Request Policy shall have the meanings set forth in our [Terms] and [Privacy Policy].

1. INTRODUCTION

We may receive formal requests from RINGL users and third parties who wish to exercise their rights to (i) have a copy of certain personal data that we hold and/or (ii) transfer a copy of certain personal data to another organisation. This Data Request Policy addresses our access request procedures.

Singapore’s Personal Data Protection Act (No. 26 of 2012) (“PDPA“) grants you, inter alia, the following rights:

Data Access Request. You have the right to request for access to a copy of your personal data that is in our possession or under our control, and to know how your requested personal data has been used or disclosed over the past year with us.

For more information on your other rights under the PDPA, please read our [Privacy Policy].

 

2. PROCEDURE FOR SUBMITTING YOUR REQUEST

We require you to submit your request(s) via our contact form.

We will respond to your request within [thirty (30) calendar days] after receiving a fully completed form and verifying your identity (and the RINGL user’s identity in the event of a third party’s request). We may contact you for additional information if the scope of your request is unclear or does not provide sufficient information for us to act on it. If you are a third party making a request on behalf of a RINGL user, we may request additional information to confirm the RINGL user’s identity, your identity, and evidence of your legal right to act on behalf of the RINGL user. We reserve the right to refuse to act on your request if we are unable to verify your legal authority to act on behalf of a RINGL user.

We will begin reviewing your request as soon as we have all of the information required to locate the requested personal data. Occasionally it could take us longer than thirty (30) calendar days if your request is particularly complex or you have made a number of requests. In this case, we will inform you of the additional time we require to respond to your request and any reasons for delay.

 

3. GENERAL CIRCUMSTANCES WE MAY DECLINE YOUR REQUEST

Applicable law may allow or require us to refuse your request to provide you with access to some or all of the requested personal data that we hold about you, or we may have destroyed, erased or made your personal data anonymous in accordance with our data retention obligations and practices. If we cannot provide you with access to your requested personal data or if we cannot transfer your personal data to another organisation, we will inform you of the reasons why, subject to any legal or regulatory restrictions. Under the PDPA, there may be certain exceptions where we may decline a request, including:

  1. where it may threaten the safety or physical health of another person (other than you who made the request);
  2. where it may cause immediate or grave harm to the safety or physical or mental health (to whom the personal data relates);
  3. where it could reveal confidential commercial information that could, in the opinion of a reasonable person, harm our competitive position;
  4. where it may be contrary to national interests;
  5. where the personal data is subject to legal privilege;
  6. where the personal data is opinion data that we keep solely for an evaluative purpose;
  7. where the personal data relates to a prosecution if all proceedings related to the prosecution have not been completed; or
  8. any request –

    8.1 that would unreasonably interfere with our operations because of its repetitive or systematic character;
    8.2 if the burden or expense of providing access or transmitting the data would be unreasonable or 8.3 disproportionate to your interests;
    8.4 for information that is trivial; or
    8.5 that is frivolous or vexatious.

If the information you request reveals personal data about a third party or another RINGL user, we will either (i) seek that individual’s consent before responding to your request, or (ii) redact or remove such third party’s personal data before responding to your request. If we are unable to either transmit data to an organisation or provide you with access to the requested personal data as disclosure would violate a third party’s rights, we will notify you of this decision.

Please also note that we may only transfer your personal data to another organisation where it is technically feasible. We are not responsible for the security of the personal data or its processing once received by the recipient organisation.

 

4. RETENTION OF YOUR DATA

Generally, we will preserve the personal data that is specified in your Data Access Request or Data Porting Request, while we are processing your request(s). We will also continue to preserve the personal data for a period of at least thirty (30) calendar days after declining a request, or for as long as required for a review by relevant data commission, whichever is later.

 

5. FEES

We do not charge a fee to provide you access to your personal data. However, we may charge a reasonable fee if your request is complex, unfounded, repetitive or excessive.

 

6. APPLICABLE LOCAL LAWS

Nothing in this Data Request Policy shall limit your rights under Singapore’s PDPA, the General Data Protection Regulation or any other data protection or local privacy related law that is applicable to you in your jurisdiction. This Data Request Policy shall be governed by the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Singapore courts.

 

7. CONTACT US

We have appointed a data protection officer who is responsible for overseeing questions in relation to this Data Request Policy. If you have any questions about this Data Request Policy, including any requests to exercise your data access rights, please contact the data protection officer using the details set out below:

Contact Details:

Address
84 Genting Lane #07-01 Axxel Innovation Centre Singapore 349854

E-mail address
privacy@ringl.im