2. Your personal data belongs to you
We carefully analyse what types of information we need in order to provide our services, and we try to limit the information we collect to only what is strictly necessary. Where possible, we delete or anonymize this information when we no longer need it. When building and improving our services, our engineers work closely with our privacy and security teams to build with privacy and security of your personal data in mind. In all of this work our guiding principle is that your information belongs to you, and we aim to only use your information to your benefit.
3. We share only what you publish
We only share the personal data that that you provided during your account registration and content which you publish. We will not share your financial information or information that you provide for payments made within the JAM application, except in order to facilitate authorised transactions made by you.
4. Why we process your personal data
We generally process your personal data when we need to do so in order to:
- create a user account for the purposes of providing the Services to you;
- maintain and administer your user account;
- improve or optimise the Services and your user experience on the JAM Application;
- facilitate payment between a buyer and a seller via third party payment platforms and/or applications;
- generate invoices, accounting and/or auditing purposes;
- to inform you of service outages and send to you promotional information and materials;
- any other purpose which we may notify you of from time to time and after obtaining your consent; and
- where we or someone we work with needs to use your personal data for a reason related to their business (for example, to provide you with a service). European law calls these reasons “legitimate interests.” These “legitimate interests” include:
- preventing risk and fraud;
- answering questions or providing other types of support;
- helping members post, match and rate through our app;
- providing and improving our products and services;
- providing reporting and analytics;
- testing out features or additional services;
- assisting with marketing, advertising, or other communications.
We only process personal data for these “legitimate interests” after considering the potential risks to your privacy – for example, by providing clear transparency into our privacy practices, offering you control over your personal data where appropriate, limiting the personal data we keep, limiting what we do with your personal data, who we send your personal to, how long we keep your personal data, or the technical measures we use to protect your personal data.
One of the ways in which we are able to help our users is by potentially using techniques like “machine learning” (European law refers to this as “automated decision-making”) to help us improve our services. When we use machine learning, we either: (1) still have a human being involved in the process (and so are not fully automated); or (2) use machine learning in ways that don’t have significant privacy implications.
5. Your rights over your personal data
We believe you should be able to access and control your personal data no matter where you live. Depending on how you use the Services, you may have the right to request access to your personal data, to correct, amend, delete, port to another service provider or restrict access to your personal data, or object to certain uses of your personal data (for example, direct marketing). We will not charge you more or provide you with a different level of service if you elect to exercise any of these rights.
Please note that if you send us a request relating to your personal data, we have to make sure that it is you before we can respond. In order to do so, we may ask to see documentation verifying your identity, which we will discard after verification.
If you would like to designate an authorised agent to exercise your rights for you, please email us from the email address registered under your user account. If you email us from a different email address, we will be unable to determine if the request is coming from you and will not be able to accommodate your request. In your email, please include the name and email address of your authorized agent.
If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.
Finally, because there is no common understanding about what a “Do Not Track” signal is supposed to mean, we don’t respond to those signals in any particular way.
6. Where we send your personal data
We are a Singapore based company, but we work with and process data about individuals across the world. To operate our business, we may send your personal data outside of your state, province, or country. This data may be subject to the laws of the countries in which such data is sent. When we send your personal data across borders, we take steps to protect your personal data, and we shall try to only send your personal data to countries that have strong data protection laws.
7. Transfers outside of Europe and Switzerland
If you are in Europe or Switzerland, your personal data is controlled by Jadeways Solution Pte. Ltd. Your information could then be sent to other JAM locations and to service providers who may be located in other regions. When we send your personal data outside of Europe, we do so in accordance with European law.
If you are in Europe or Switzerland, when we send your personal data to Singapore it is protected under Singapore law, which the European Commission has found will adequately protect your personal data. If we then send this personal data outside of Singapore, such personal data is protected by contractual commitments that are comparable to those provided in standard clauses.
Finally, while we do what we can to protect your personal data, we may at times be legally required to disclose your personal data (for example, if we receive a valid court order).
8. How we protect your personal data
Our teams work tirelessly to protect your personal data and to ensure the security and integrity of our platform. However, we all know that no method of transmission over the Internet, and method of electronic storage can be 100% secure. This means we cannot guarantee the absolute security of your personal data.
9. How we use “cookies” and other tracking technologies
How you can reach us
If you would like to ask about, make a request relating to, or complain about how we process your personal data, you can contact us at:
Jadeways Solutions Pte. Ltd.
UEN No: 201706757H