Thank you for choosing Particle!
We are committed to protecting your privacy! Since we provide our services on a worldwide basis, we must comply with many data protection laws. Given that we are based in Singapore, the Personal Data Protection Act (PDPA) is of primary importance; however, other regulations may apply, such as the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) if you are based in the EU or the California Consumer Privacy Act (CCPA), if you are a California resident.
According to the definition of “data controller” under the GDPR – namely: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law – Particle Pte. Ltd., with registered office in 111 SOMERSET ROAD, #08-10A - SINGAPORE (238164), Company number 202022783N, is the Data Controller.
If you have any questions or concerns regarding your personal information, please contact us at firstname.lastname@example.org.
1. Processing of information (purposes and legal bases)
We collect personal information that you provide to us when you register on the App, when you contact us and, more generally, when you use our Services.
In order to provide you with the Services, we collect information from you, including the following:
· Identifiers (such as name, surname, e-mail address, postal address, postal code, phone number, IP address, payment information, identifiers from the devices you use to connect);
· Commercial information (such as products or services considered or purchased, as well as payment information; this may include commercial choices, preferences or habits);
· Activity information (such as your interactions with the App);
· Geolocation data (such as IP address).
We use your personal information for several purposes linked to our App and, more generally, to the provision of our Services. You have no obligation to provide us with your personal data. However, without your personal information, we would not be able to provide you with our Services.
For each of the following purposes, the GDPR requires a legal basis.
Such purposes are the following:
a) To create and let you access your account on the App, as well as to process your purchases and respond to any requests you may direct to us. For the present purposes, the processing of your personal data is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
b) To send you commercial communications by e-mail regarding products or services similar to those you have already purchased (“soft spam”). For the present purpose, the processing of your personal data is necessary to achieve our legitimate interests;
c) To send you commercial communications. For the present purpose, the processing of your personal data is solely based on your consent;
d) To send you customised commercial communications based on the analysis of your interactions with the App and, more generally, with our Services. For the present purpose, the processing of your personal data is solely based on your consent;
e) To communicate your personal data to the Creators for their own marketing purposes. For the present purpose, the processing of your personal data is solely based on your consent;
f) To comply with applicable law and legal process and to respond to requests from public and government authorities, including those outside your country of residence. For the present purposes, the processing of your personal data is based on the legal obligations to which we are subject;
g) To protect our Services, i.e. to keep our App safe and secure, to prevent fraud, and to analyze and develop internal aggregated statistics to improve our Services. For the present purposes, the processing of your personal data is based on our legitimate interests.
In relation to all the processing operations based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
2. Disclosure of information
Your personal data will not be disseminated. We may disclose your information to third parties to perform Services on our behalf or to help us provide our Services to you (i.e.: consultants and professionals; IT, administrative and business support providers; public bodies or authorities; credit or insurance institutions).
We do not authorise third parties to use information for their own purposes, unless you give us your consent. We may share or transfer your information in connection with any merger, sale, financing or acquisition of our business to another company. We may allow third parties to use tracking technology on the App, which will enable them to collect data on our behalf about how you interact with our App over time.
Such third parties might act as independent data controllers or data processors, pursuant to the relevant GDPR definitions. For an updated list of our data processors, please contact email@example.com
Moreover, both the aforementioned data processors and other recipients, such as those acting under our authority, have received detailed instructions regarding the processing of your personal data.
3. International data transfers
In case we transfer personal information to countries outside of the EEA, in the course of sharing information, we will ensure that such personal information is transferred in accordance with the GDPR and with the applicable data protection laws. More specifically, we ensure that, in case of a transfer of personal data to a third country which is not considered to be adequate pursuant to Article 45 GDPR, we will adopt the measures enshrined in the following articles of Chapter V of the GDPR, including appropriate contractual, technical and organisational measures.
4. How long do we keep your information?
Your personal data will be kept as long as necessary to fulfill the purposes indicated above, without prejudice to the cases in which the retention for a longer period is necessary to comply with the applicable legislation or with requests received by competent authorities. The personal data that we process on the basis of your consent are retained until your consent is withdrawn.
5. Your privacy rights
You can request access to your personal information or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.
You can object to processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information; if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You also have the right to lodge a complaint with a Data Protection Authority about our collection and use of your personal information, in particular in the Member State in which you habitually live or work or in the place where the alleged violation took place.
To exercise your rights, please contact us at firstname.lastname@example.org
You have the right to complain to a data protection authority about our collection and use of your personal information.
6. CCPA Privacy Notice
This privacy notice applies to California residents. According to the CCPA, “residents” are:
· Every individual who is in the State of California for other than a temporary or transitory purpose; and
· Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.
If the definition of “resident” suits you, we must adhere to certain rights and obligations regarding your personal information.
Your rights under the CCPA
You have the right to request that we disclose: what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, or disclosing CCPA personal information; the categories of third parties with whom we share CCPA personal information; the categories of CCPA personal information we have disclosed about you for a business purpose. We do not sell your personal information unless you give us your consent (opt-in).
You have a right to receive a copy of the specific CCPA personal information we have collected about you.
You have a right to deletion of your CCPA personal information, subject to exceptions under the CCPA.
We will not discriminate against you if you exercise your privacy rights.
If you are a consumer under the CCPA and wish to contact us through an authorised agent, the authorised agent can submit a request on your behalf at email@example.com. Please, make sure that such request comprises a statement signed by you certifying that the agent is authorised to act on your behalf.
In order to verify the request and your identity, we may ask you to verify your identity by providing us additional information. We will delete such additionally provided information as soon as we finish verifying you.