This Privacy Policy applies to consumer information, including personal information, collected and used by S11 Granuity Management Pte Ltd (S11).

By using S11 websites and mobile applications or otherwise providing your personal information to S11, you agree to the collection, use and sharing of your information under this Policy. Please read this Privacy Policy carefully and contact us if you have any questions.

Personal information is information, or a combination of pieces of information, that could be used to identify you on an individual basis.

Information S11 Granuity Management Pte Ltd (S11) Collects

We may collect information about you from a variety of sources. This includes information we collect directly from you; information we collect when you visit our sites, view our online content or use our mobile applications or other services; and information we collect about you from other sources.

Information we collect directly from you

We collect information directly from you when you choose to participate in our offers and programs, create an account on our websites or in our mobile applications, call or email us, or otherwise provide information directly to us. The following are examples of information we may collect directly from you:

Name.

Email address.

Postal address.

Username and password.

Telephone and/or fax number.

Demographic information.

Payment information (such as a credit card).

Future communication preferences.

Contact information for friends you may wish us to contact.

Telephone number and recordings when you call our consumer line.

Information we collect when you visit our sites, view our online ads or promotions, or use our mobile applications or other services

We use cookies and other technologies to collect information when you visit our sites, view our online advertisements or promotions, or use our mobile applications or other services. The following are examples of information we may collect with these technologies:

Information about your device browser and operating system.

IP address.

Web pages you view.

Links you click.

S11 emails you open.

Information collected through Mobile Applications

When you download our mobile applications to your mobile device we may also collect information that you provide. We also automatically collect information through our applications.

The following are examples of the types of information we may automatically collect through our applications:

Advertising ID or similar identifier.

Information about your device's operating system.

Information about the way you use the application.

Your Choices about information collection through Mobile Applications

You can opt out of continued information collection by our mobile application by deleting the application from your device.

Precise Location Data

Our mobile applications may collect precise location information from your device if you consent to the collection of this information. We may use third-party service providers to provide location services using the location data you provide. You may opt out at any time to the continued collection of this information by adjusting the settings on your device.

Information S11 Granuity Manangement Pte Ltd (S11) collects from other sources

We may obtain information from other sources, including commercially available sources. Examples of information we may collect from other sources are:

Name.

Postal address.

Email address.

Consumer and market research data.

All of the information we collect about you may be combined to help us improve our communications with you and to develop world-class products and services.

How S11 Granuity Management Pte Ltd (S11) Uses This Information

S11 Business Purposes

We use the information we collect to provide you products, offers and services, to deliver to you advertisements, offers or other content tailored to your interests, and to conduct other S11 business operations.

The following are examples of how we may use the information we collect:

Answer your questions or respond to your requests.

Send samples, premiums, products and information.

Develop new products and services.

Create and manage your account.

Process payment for purchases or other services.

Protect against or identify possible fraudulent transactions.

Send you email and/or postal messages with information about S11 brands and other content we think may be of interest to you, including brand and service information from carefully selected business partners.

Develop and provide advertising tailored to your interests, including interest-based advertising.

Personalize your experience on our websites by presenting products and information tailored to you.

Allow you to participate in social sharing on our websites.

Analyze the use of our products, services and advertising.

Enforce our Terms and Conditions and otherwise manage our business.

Information Sharing

The success of our business depends on your trust, and we do not sell your personal information to marketers outside of S11. We share your personal information within S11 and as described in this Policy. We do not share personal information with marketers outside of S11 unless you consent to such sharing, or as described within this Policy.

Co-promotions with Carefully Selected Business Partners

S11 may collect personal and other information for a co-promotion or joint program with a business partner and share your information with that business partner. For these programs we will make clear at the point of collection that the information will be shared with S11 and the participating business partner and ask for your consent as required by applicable laws.

Third-party service providers

We rely on third-party service providers to perform a variety of business operations on our behalf. In so doing, we may need to share your personal information with them. We provide our service providers with only the personal information they need to perform the services we request, and we require that they protect this information and not use it for any other purpose.

For example, we may rely on a service provider to:

Fulfill your product and service requests and answer your questions.

Host our sites and deliver our email or other communications.

Analyze our data, sometimes combined with data from other sources, to send you communications.

Conduct research and analyze data to improve our products, services and sites.

Where permitted by law, combine personal information about you that S11 has collected with personal information about you that a business partner has collected so we can jointly send tailored promotional communications to you. In such instances, our business partner will not be permitted to use S11 data or the combined data for its own, independent marketing purposes. Our service provider will only be allowed to use the combined set of information to send you joint communications that we hope will be of interest to you. If you prefer not to receive these joint communications, you can always opt out by following the instructions provided in any such communication or through this Privacy Policy as indicated above.

Perform other services that we request.

Other situations.

We may disclose your personal information:

As part of the sale of a S11 brand to another company.

To protect and defend the rights and property of S11(including enforcing our Terms and Conditions).

When required by law and/or government authorities.

Personal Information Retention Period

We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Aggregated and non-personal information.

We share aggregated and/or anonymous information that does not identify you for S11 business purposes. For example, we may disclose the number of visitors to S11 sites or services. We may also share aggregated and/or anonymous information with our business partners for their own business purposes.

Your Choices & Access to Your Information

We give you choices about how we communicate with you.

Email Communications

You can stop receiving promotional email messages from S11 by following the opt-out instructions provided in any such message you receive.

Postal Mail

You can stop receiving promotional postal mail from S11 by following the opt-out instructions that may be included within those communications.

Mobile Text Messages

We only send you promotional mobile text messages if you explicitly ask to receive these (you opt in). You can stop receiving promotional text messages by following the instructions to opt out provided within that text messaging program.

PLEASE NOTE: We will honour your request to stop receiving promotional email, text and postal messages from S11. However, we may continue to send you service-related communications such as emails confirming purchases through our websites. And we may keep information for record keeping, such as to ensure we fulfil consumer requests not to send particular types of messages.

Access

We take steps to keep your personal information accurate. Many S11 programs provide access to view or update personal information you provided when you registered online. Check where you registered to learn if you can view or update your information there.

Cookies and Other Technologies

S11 and our third-party service providers use a variety of technologies to assess how our sites or mobile applications are used, to personalize your experience and to deliver you advertising, including online content, tailored to your interests. Some technologies we may use include the following:

Cookies

A cookie is a small file placed on your device when you visit a site that can be understood by the site that issued the cookie. We use the information collected by cookies to remember who you are to log you in and your preferences, to provide to you advertisements, offers or other content tailored to your interests and to assess how our sites are used. You can accept or decline cookies through your browser settings. To learn more, please look at the cookie settings available in your specific web browser(s).

Other Technologies

We use other technologies including web beacons and JavaScript that sometimes work together with cookies and other means within our mobile applications to uniquely identify your device. These other technologies help enable features on our websites and within our mobile applications.

Links to Third Party Sites and Social Media

S11 sites may include links to third-party sites. S11 does not control these third-party sites, and we encourage you to read the privacy policy of every site you visit.

Social Networks and Third-Party Plug-ins

Our websites may include plugins from social networks or other third parties. An example of a plugin is the Facebook "Like" button. Where legally permitted, these plugins may communicate with and send information to the party that provided the plugin, even if you do not click on the plugin. This information may include your IP address, information about your browser and device, and the address of the web page you are visiting on our site. Loading, using or clicking the plugins may also place, read and transmit cookies. These cookies may contain a unique identifier the social network or third party assigns to you. The loading, functionality and your use of the plugins are governed by the privacy policy and terms of the party that provided the plugin.

Social Network and Third-Party Login

Our websites may allow you to log in using a social network or other third-party account. An example of a third-party login is "Log in with Facebook." Logging into one of our sites with your social network or other third-party account may allow us to gather information that you give us permission to access from that social network or third party. The login feature may also transfer information to the social network or third party, such as your username and password, to authenticate you. The social network or third party may also automatically collect information such as your IP address, information about your browser and device, and the address of the web page you are visiting on our site. The login feature may also place and read cookies from that third party that may contain a unique identifier the social network or other third party assigns to you. The functionality of and your use of the login is governed by the privacy policy and terms of the party that provided the login functionality.

User Generated Content

Information Security

S11 is committed to keeping personal information secure. We have implemented technical, administrative and physical procedures designed to protect personal information from loss, misuse or alteration.

We limit access to personal information to those who have a business need. We keep personal information only for so long as deemed reasonably necessary.

Information Transfer

S11 may transfer your personal information within S11 and/or to other third parties, such as our third-party service providers. Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected. This may include the United States. When we do so, we transfer the information in compliance with applicable data protection laws.

We have implemented procedures and controls to help ensure that personal information is protected no matter what country it is stored in or transferred to.

Children's Online Privacy

We do not intend to collect personal information online from children under 13 or as defined by local legal requirements, except on sites specifically directed to children. On those sites we follow applicable data protection laws.

Changes

We may occasionally update this Privacy Statement. If the changes we make are material, we also may post a notice regarding the changes on our websites or mobile applications and related licensing agreements. We encourage you to periodically review this Privacy Statement to stay informed about how we are helping to protect the PII we collect. Your continued use of our websites and mobile applications constitutes your agreement to the Privacy Statement and any updates. Subsequent changes in this Privacy Statement will not apply to data that were collected before the change is made.

This Privacy Statement was last updated on 11th April 2016.

Contact S11 Granuity Management Pte Ltd (S11)

If you have questions or concerns regarding your privacy, please contact S11 Granuity Management Pte Ltd (S11) directly.



You can also write to us at:

S11 Granuity Management Pte Ltd

PPT Lodge 1B

2 Seletar North Link #02-01

Singapore 797601



Singapore

S11 Granuity Management Pte Ltd complies with Singapore's Personal Data Protection Act 2012 (the "PDPA").

We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

The personal data which we collect from you may be collected, used, disclosed and/or processed for the purposes as stated in the Global Consumer Privacy Policy and any other purposes which we notify you of at the time of obtaining your consent (collectively, the "Purposes").

We may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes.

We will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations permissible under law. For more information on the exceptions, please refer to the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.

You may request to access, correct and/or withdraw consent relating to the personal data currently in our possession or control by submitting a written request to us. Note that the PDPA exempts certain types of personal data from being subject to your access request. We may also charge you a reasonable fee for the handling and processing of your requests to access your personal data and will provide you with a written estimate of such fees.

We will take reasonable efforts to ensure that your personal data is accurate and complete, and put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with. We also cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so.

If you need to contact S11 Granuity Management Pte Ltd in relation to your personal information, please contact us at 6587 6200 or write to our Data Privacy Officer via ppt1b@s11capital.com

Terms of use

General

This website is owned and operated by S11 Granuity Management Pte Ltd (S11).

By accessing and using any part of this website, you unconditionally agree and accept to be legally bound by these Terms and Conditions of Use. If you do not agree to these Terms and Conditions of Use, please do not use this website.

In case of any violation of these Terms and Conditions of Use, S11 reserves the right to seek all remedies available under the law and in equity for such violations. These Terms and Conditions of Use apply to all visits to this website, both now and in the future.

S11 reserves the right to change these Terms and Conditions of Use from time to time at its sole discretion. All changes will be posted on this page, and your use of this website after such changes have been posted will constitute your agreement to the modified Terms and Conditions of Use and all of the changes. You should therefore read this page carefully each time you visit this website.

Proprietary Rights

The materials located on this website, including the information as well as any software programs available on or through this website ("the Contents"), are protected by copyright, trademark and other forms of proprietary rights. All rights, title and interest in the Contents are owned by, licensed to or controlled by S11.

Content

Except as otherwise provided, the Contents of this website shall not be reproduced, republished, uploaded, posted, transmitted or otherwise distributed in any way, without the prior written permission of S11.

You may use, hyperlink, copy and distribute the Contents found on this website solely for personal, internal, non-commercial, informational purposes only. You may download one copy of any information provided in this website onto a single computer for your own personal non-commercial use provided that you keep intact all accompanying copyright and other proprietary notices. You may not display, distribute or otherwise use any of the Content found on this website for any commercial purpose unless you receive specific prior written consent from S11.

Modification of any of the Contents or use of the Contents for any other purpose will be a violation of S11's copyright and other intellectual property rights. Graphics and images on this website are protected by copyright and may not be reproduced or appropriated in any manner without the prior written permission of their respective copyright owners. The design and layout of this website is protected by intellectual property and other laws and may not be copied or imitated in whole or in part. No logo, graphic, sound, image or search engine from this website may be copied or transmitted unless with the prior express permission of S11.

Disclaimer of Warranties and Liability

The Contents of this website are provided on an "as is" basis without warranties of any kind. While S11 has made every reasonable effort to ensure that the Contents of this website have been obtained from reliable sources, S11 is not responsible for any errors or omissions, or for the results obtained or consequences arising from the use of any of the Contents.

To the fullest extent permitted by law, S11 does not make any representations or warranties of any kind whatsoever in relation to the Contents of this website and hereby disclaims all express, implied and/or statutory warranties of any kind to you or any third party, whether arising from usage or custom or trade or by operation of law or otherwise, including but not limited to any representations or warranties:

as to the accuracy, completeness, correctness, reliability, currency, timeliness, non-infringement, title, merchantability, quality or fitness for any particular purpose of the Contents of this website; and

that the Contents available through this website or any functions associated therewith will be uninterrupted or error-free, or that defects will be corrected or that this website and the server is and will be free of all viruses and/or other malicious, destructive or corrupting code, programme or macro.

S11 shall also not be liable to you or any third party for any damage or loss of any kind whatsoever and howsoever caused, including but not limited to any direct or indirect, special or consequential damages, loss of income, revenue or profits, lost or damaged data, or damage to your computer, software or any other property, whether arising directly or indirectly from -

S11 shall also not be liable to you or any third party for any damage or loss of any kind whatsoever and howsoever caused, including but not limited to any direct or indirect, special or consequential damages, loss of income, revenue or profits, lost or damaged data, or damage to your computer, software or any other property, whether arising directly or indirectly from - your access to or use of this website;

any loss of access to our use of this website, howsoever caused;

any inaccuracy or incompleteness in, or errors or omissions in the transmission of, the Contents;

any delay or interruption in the transmission of the Contents of this website, whether caused by delay or interruption in transmission over the internet or otherwise; or

any decision made or action taken by you or any third party in reliance upon the Contents, regardless of whether S11 has been advised of the possibility of such damage or loss.

Right of Access

S11 Granuity Management Pte Ltd (S11) reserves the right to update or modify this website from time to time. S11 further reserves all rights to deny or restrict access to this website to any particular person, or to block access from a particular Internet address to this website, at any time, without ascribing any reasons whatsoever. You agree that you will not:

use any robot, spider, other automatic device, or manual process to monitor or copy any pages within this website or the Contents without S11's prior written permission;

use any device, software or routine to interfere or attempt to interfere with the proper working of this website; and

take any action that imposes an unreasonable or disproportionately large load on S11 's servers

Hyperlinks to Third Party Sites

Third-Party Links.

In an attempt to provide increased value to our visitors, this Site may contain links to other sites on the Internet that are owned and operated by third party vendors and other third parties (the "External Sites"). However, even if the third party is affiliated with S11, S11 has no control over these linked sites, all of which have separate privacy and data collection practices, independent of S11. S11 has no responsibility or liability for these independent policies or actions and is not responsible for the privacy practices or the content of such web sites. These linked sites are only for your convenience and therefore you access them at your own risk. Links do not imply that S11 sponsors, endorses, is affiliated with or associated with, or has been legally authorized to use any trademark, trade name, service mark, design, logo, symbol or other copyrighted materials displayed on or accessible through such External Sites. Nonetheless, S11 seeks to protect the integrity of its Site and the links placed upon it and therefore requests any feedback on not only its own Site, but for sites it links to as well (including if a specific link does not work).You should contact the Site administrator or Webmaster for those External Sites if you have any concerns regarding such links or the content located on such External Sites.

Governing Law

These Terms and Conditions of Use shall be governed and construed in accordance with laws of Singapore.