EFFECTIVE DATE - October 1, 2021
1.2 When we refer to btw, we mean Adaface Pte Ltd, a company registered in Singapore with a registered address at 32 Carpenter Street, Singapore;
1.5 For the purposes of the General Data Protection Regulation (or any successor or equivalent legislation in the UK) ("GDPR"), btw is the controller of your personal data.
2.1 Here's the list of data we collect about you when you engage with btw's sites and services-
2.2 Cookie usage
Some device data, service data and third party source data is collected through the use of first or third party cookies and similar technologies. We do not collect, retain, or share data regarding a particular user's activity across multiple websites or applications that are not owned by btw or our customers. btw does assign each user a unique user ID within the scope of an individual website, but does not collect or retain IP or any information that would allow btw to identify the same particular user on more than one website.
Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
2.3 Children's privacy
If you're a child under the age of 13, you may not have an account on the btw Sites and Services. btw does not knowingly collect information from or direct any of our Website or content specifically to children under 13. If we learn or have reason to suspect that a user is under the age of 13, we will close the child’s account.
Other countries may have different minimum age limits. If you are below the minimum age for providing consent for data collection in your country, you may not use btw.
3.1 We collect and process your personal data for the following purposes and, if you are from the European Economic Area (EEA), the UK or Switzerland, on the following legal bases:
3.2 We process your personal data to perform our contract with you for use of our Services and Sites and to fulfill our obligations under applicable terms of service.
3.3 We may send you service, technical and other administrative messages in reliance on our legitimate interests in administering the btw Services. We process your personal data to provide customer care and support while using btw Sites and Services as website visitors or users. We also process your personal data to enable btw's customers provide customer care and support on domains where btw Services are enabled.
3.4 We process your personal data to improve and optimize the btw Services and Sites and btw customers Sites and Services where btw Services are enabled. This includes monitoring usage or traffic patterns, analyzing trends and developing new products, services, features and functionality in reliance on our legitimate interests.
3.5 We process your personal data to send you marketing communications via email or SMS about our products, services and upcoming events that might interest you in reliance on our legitimate interests or where we seek your consent. You can control your marketing preferences and choose to withdraw your consent at any time through the unsubscribe feature provided with each marketing email or by contacting us at email@example.com.
3.6 We process your personal data to control unauthorized use or abuse of the btw Services and Sites, or otherwise detect, investigate or prevent activities that may violate btw policies or applicable laws, in reliance on our legitimate interests to maintain and promote the safety and security of the btw Sites and Services.
3.7 Carrying out other legitimate business purposes including invoicing, audits, fraud monitoring and prevention. We process your personal data when cooperating or complying with public and government authorities, courts or regulators in accordance with our obligations under applicable laws and to protect against imminent harm to our rights, property or safety, or that of our users or the public, as required or permitted by law.
4.1 btw will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors, and affiliated organizations, btw discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when btw believes in good faith that disclosure is reasonably necessary to protect the property or rights of btw, third parties, or the public at large.
4.2 btw takes measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information.
4.3 btw at its sole discretion may make use of company logos where those companies are using the software that we provide. If you have concerns over the use of your logo, please email firstname.lastname@example.org.
4.4 btw may also share aggregated or anonymized information with third parties for other purposes. Such information does not identify you individually, but may include usage, viewing and technical information such as the websites you generally use, the configuration of your computer, and performance metrics related to the use of websites which we collect through our technology, products and services.
5.2 Note that content you post may remain on the Sites even if you cease using the Sites or we terminate access to the Sites.
5.4 Depending on the btw Service you opt for, certain recipients (our service providers and other companies) who process your personal data on our behalf may also transfer personal data outside the country in which you are resident. Where such transfers occur, we will make sure that an appropriate transfer agreement is put in place to protect your personal data.
5.5 You are entitled to the following with regard to your personal information and data:
To exercise your privacy rights, you can email us at email@example.com
6.1 You can contact us using our customer support services on btw Sites or write to us at firstname.lastname@example.org regarding any questions or concerns about your data. Please note, we will need to verify your identity to process your information, access, and deletion requests. Note that, in some instances, we may decline your request as permitted by law.