Introduction
Welcome to glitsy, an entertainment service that provides an interactive service amongst fans and celebrities affiliated with the Z-POP Dream Project (the “Z-POP Artists”). glitsy allows you to interact with and support your favourite Z-POP Artists. glitsy is made available by Divtone Entertainment Pte Ltd and/or one of its worldwide related entities (all, together, “our Company”, “we”, “us” and “our”). We are committed to safeguarding the personal data that you provide to us or that we collect through the glitsy entertainment service and its services and features(all, together, “our Services”).
This Privacy Policy explains how we treat the information we collect when you access or use our Services, how you can manage your personal data and how you can contact us if you have any questions about this Privacy Policy. By accepting this Privacy Policy or by accessing or using our Services, you:
- acknowledge that you have the right, capacity and authority to accept this Privacy Policy or, if you are under 18 years of age or below the minimum legal age under applicable law to give consent for the purposes of this Privacy Policy, you have obtained the consent of your parent or guardian to accept this Privacy Policy;
- acknowledge that you have read and understand this Privacy Policy; and
- agree that we may collect, use, process and share your personal data in accordance with this Privacy Policy.
If you do not agree to this Privacy Policy, do not accept it and do not access or use our Services.
1. Application of this Privacy Policy
1.1 This Privacy Policy applies to your access and use of our Services.
1.2 Our Services may provide links to third-party applications, websites or other services, including those which can be used to register an account with or log-in to our Services. For example, we allow you to register an account with our Services using Facebook. This Privacy Policy does not apply to your access or use of those third-party applications, websites or other services, as they are provided by independent third parties (that is, parties that are not related to us or who do not process personal data on our behalf).
1.3 You:
- acknowledge that we have no control over third-party applications, websites and services or how their operators (and other persons acting on their behalf) deal with your information (including any content);
- agree that we are not responsible or liable in any way in connection with the processing of your personal data by third-party applications, websites and services; and
- agree that you are responsible for reviewing the privacy policies of third-party applications, websites and services to understand how their operators may use your information.
If you are using a third-party application, website or service, you do so at your own risk.
2. Child Safety
Protecting the safety of children when they use the Internet is very important to us. If you are under 18 years of age or below the minimum legal age under applicable law, you may use our Services only with the consent and involvement of your parent or guardian. If you are under 13 years of age or below the minimum age in your country to use our services, please do not access or use our Services at any time.
3. Information We Collect
- We collect and process information about you in the following ways:
3.1 Information You Provide or Share
(a) When you access or use our Services, we collect information that you provide to us or share on our Services, such as:
- your full name
- your birthdate
- your gender
- your nationality
- your country of residence
- your email address
- your telephone number
- your government-issued identification number (for example, a national ID number or passport number)
- your billing information (including mailing addresses, billing addresses and credit card numbers, security codes and expiry dates) and digital wallet information (including username and account passwords for independent third-party payment processors and e-wallet addresses) for purchases or redemptions at the online store within our Services
- your username, profile picture and password for our Services
- your username/handle and account password for independent third-party applications, websites and services
- any content you upload to or share on our Services, such as photos, videos, live videos, comments, links and other materials (collectively, “Content”)
- details of your purchases, transactions or other activities on our Services, including surveys
- details of your communications with us (for example, to report a problem or to submit queries, concerns or comments regarding our Services).
(b) You are not required to provide any of the information above to us. However, if you don’t provide such information, you may not be able to access or use certain features of our Services.
(c) Many features of our Services require us to have access to your photos, videos and other information from your device’s camera and microphone. You will not be able to upload photos or videos from your device unless you allow us to access them.
(d) We may collect any of the information above through:
- any of our service providers who we use to collect and process information on our behalf;
- other users of our Services that upload or share Content about you on our Services; and
- independent third-party applications, websites or other services (for example, if you register an account with our Services using Facebook, we may collect your full name and birthday from them).
Reminder:
If you register an account with our Services, your username, profile picture and Content posted on our Services will automatically be publicly available to, and may be seen or shared by anyone who accesses or uses our Services. You won’t be able to change your privacy settings to keep this information private. Keep in mind that anyone can create screenshots of information that you post on our Services and can keep and share a copy of it even if you delete that information later. So please do not provide or share any information to us or for our Services that you do not want other people to see, save or share.
3.2 Automatically Collected Information
(a) We use cookies, pixel tags, local storage objects and similar technologies on our Services. These technologies are used to collect certain device and technical information about you through our Services, such as:
- your internet protocol address
- your device information, including unique device identifiers, operating system type and version and hardware model
- your connection information, including browser type and version, mobile platform, mobile network information and Wi-Fi network information
- your log information, including uniform resource locator, visited pages, viewed Content, voting records, metadata related to Content, items viewed and purchased on our Services, information related to transactions on our Services, including those involving digital tokens that may be used with or on our Services, user preferences (including language settings), system activity (including frequency and duration of activities) and crash reports
- your location information.
For example, we may know what videos you prefer to watch, or where you are or what device you use when you watch them, or the time, date and frequency of your messages to other users of our Services.
(b) Your browser or device may offer settings relating to these technologies, and you should check your browser or device manual for information on these settings. If you choose to adjust the settings on your browser or device relating to these technologies, please note that such adjustments may affect your experience of our Services.
4. How We Use the Information We Collect
4.1 We collect and process your information to operate our Services and provide you an incredible experience in a secure and lawful manner. So, we may use the information you provide to:
- verify your identity when you log-in to our Services
- deliver our Services, including enabling you to post Content, play live or replay videos, vote for Z-POP Artists and make purchases
- provide you with the products, services and information you request
- administer your account with us and communicate with you
- verify and carry out financial transactions for purchases you make on our Services, including to verify the balance in your electronic wallet in our Services
- monitor and analyse trends and usage of our Services
- improve the layout and/or content of our Services and personalise the content shown to you
- develop, operate, improve, deliver and maintain our current and future products and services
- where you agreed to us doing so, contact you and send you marketing information by email and notifications through the glitsy entertainment service regarding our Services and any third party or our other events, products, services, surveys and promotions
- notify you of any updates or changes to our Services, including its Terms of Use, this Privacy Policy and other policies and guidelines
- detect, diagnose, address and fix problems, and to prevent, detect, investigate and prosecute security threats, fraud, misconduct or other unlawful or malicious activity, affecting our Services
- review the performance of professional advisers and third-party service providers, vendors and agents that help us operate and develop our Services
- assist our internal business, operational and administrative needs, including quality control and training purposes, research, analysis, testing and auditing
- enforce our Terms of Use and other user policies and guidelines
- resolve disagreements involving our Services and manage our risk
- protect the rights, property, or safety of any person, including ours
- assess whether to continue with a proposed business transaction (for example, a purchase, sale, lease, merger or any other acquisition, disposal or financing) involving us, our Services or our business or assets
- for purposes set out in our Terms of Use
- comply with our legal obligations, codes of practice and other non-legal standards.
4.2 We may use and share information that is not personal data (that is, information that cannot be used to identify anyone, including aggregated or de-identified information) for any purpose, except where we are prevented by applicable law from doing so. If we combine any automatically collected information with personal data or other information that may be used to identify anyone, we will treat the combined information as personal data in accordance with this Privacy Policy.
4.3 We will get your consent before we process your personal data for purposes not described above, unless we are required or authorised under applicable law to process any personal data without such consent.
5. Who We Share Your Information With; Transfers of Information Outside Singapore
Our Services are provided from Singapore. In the course of providing our Services, we may share information about you with any of the following persons, who may be located in or outside Singapore:
5.1 Sharing Information with Third Parties
(a) We may share information about you with the following recipients, who may be located in or outside of Singapore:
- our affiliates, professional advisers and third-party service providers, vendors and agents
- operators of independent third-party applications, websites or other services that you connect to through our Services
- any person that wishes to enter into a proposed business transaction (for example, a purchase, sale, lease, merger or any other acquisition, disposal or financing) involving us, our Services or our business or assets.
(b) We will only share information with a recipient above on a need-to-know basis and for the purposes described in this Privacy Policy (see How We Use the Information We Collect above).
(c) We may also share your information with other third parties if you have agreed to such disclosure. In such case, any information we share with those recipients will be used for the purposes described when we obtained your consent.
(d) Before sharing your personal data with a recipient above, we will ensure that such recipient is required to protect and secure your personal data in a way that complies with and is comparable with this Privacy Policy and the standard of protection required under applicable law. By accessing or using our Services, you agree to the transfer of your personal data.
5.2 Sharing Information Required by Law
We may share your information with any other person, including competent government and regulatory agencies (whether located in or outside of Singapore) where we are required under applicable law to do so. Please note that we may be prevented from getting your consent for, and informing you of, such disclosure. Any information that we share in this case will be used for the purposes required under applicable law.
5.3 Sharing Information with Other Users of Our Services
Our Services may allow users to support and vote for Z-POP Artists, comment on Content shared by other users and communicate with other users, or upload Content on our Service. Your user profile and uploaded Content will be posted on our Services and will be public information. You should be careful when communicating with other users or uploaded Content and never share your personal information. We will not be liable for any personal information that you voluntarily share with other users of our Services (see also our Reminder above).
6. Managing Your Information
6.1 You may access, review, correct or delete the information that you have provided to us through our Services by opening your account and using the tools within our Services. Keep in mind that you will not be able to recover from us any information that you delete through our Services.
6.2 In addition, unless there are exceptions under applicable law, you may request information about how we have used and shared your personal data within a year before your request. We may charge a reasonable fee to cover our costs in processing this request.
6.3 You may decide at any time to withdraw your consent to our use of your personal data in any way or for a particular purpose. However, please note that any withdrawal of consent may have consequences. For example, you might not be able to access or use certain features of our Services or we might not be able to provide you with any service update notifications or other support services available through our Services from time to time. Also keep in mind that even if you withdraw your consent, we may keep your personal data for as long as is necessary for legal or business reasons.
6.4 Any request for information about your personal data and any notice to withdraw your consent to use personal data should be sent to our data protection officer (see Contacting Us below). To protect your privacy and security, we will take reasonable steps to verify your identity before acting on any information request or withdrawal notice. You may also withdraw consent to the use of your personal data by deleting your account in our Services.
6.5 You may be able to manage your information in other ways, depending on where you are from.
7. How We Secure and Keep Personal Data
7.1 We have reasonable and appropriate security measures in place intended to protect personal data in our possession or control against unauthorised access, collection, loss, use, disclosure, copying, alteration or other similar risks, including storing all the personal data you provide to us on our secured servers, protecting the security of your information during transmission by using Secure Sockets Layer software, which encrypts information you input. However, there is no guarantee that malicious actors will not attempt to breach any security measure that we have in place.
7.2 You understand that sending information through the Internet is never completely secure. We cannot guarantee the security of the information you send through our Services while it is in transit over the Internet. Any information you send through the Internet is sent at your own risk.
7.3 Except for information you delete through the tools on our Services, we keep your information at all times while your account in our Services exists and we may keep your personal data at any time after that, if required for legal or business reasons. We may also keep and use your information after you delete your account, if that information cannot be used to identify anyone.
8. Updates to this Privacy Policy
We may make changes to this Privacy Policy at any time. Any changes will be posted to our Services or otherwise communicated to you via email. You agree to refer to this Privacy Policy on a regular basis to check for changes and review the revised Privacy Policy so that you are aware of the changes. Any changes to this Privacy Policy will take effect from the time they are posted to our Services. Your continuous accessing or use of our Services will be taken as your acceptance and agreement to the revised Privacy Policy. If you do not agree with the changes, please stop accessing or using our Services and delete your account in our Services.
9. Contacting Us
If you have any questions about this Privacy Policy or our processing of your personal data, please contact us at:
Divtone Entertainment Pte. Ltd.
Email: dpo@divtone.com
83 Clemenceau Avenue #17-01 Singapore 239920
Last Updated: 20 December 2019
