We at the “Lyte Group”, consisting of Lyte Ventures and/or any company, directly or indirectly, controlled by, controlling or under common control of Lyte Ventures, take the protection of your Personal Data (defined below) seriously.
Scope of this Policy
This Policy applies to all Personal Data collected, whether or not processed online, through all of our forms, websites, applications, services, and domains, that references or links to this Policy, which include, but are not limited, to the following: –
- (together, the “Platforms”).
You will have the option to manage your privacy when using the Platforms.
Types of Personal Data We Collect
The types of Personal Data that we collect depend on the circumstances of collection and on the nature of the transaction undertaken with us.
The personal data that we may request for includes but is not limited to (individually and collectively referred to as “Personal Data”): –
- personal identification information, including name, gender, date of birth, images, photographs, videos, voice recordings;
- government-issued identification information or information relating to any professional certification or license;
- contact information, including postal address, email address, phone number and documentary proof of the same;
- payment information relevant for your usage of credit or debit card(s), or bank account(s) in furtherance of services we provide to you;
- demographic information such as academic qualifications, occupation, job details, preferences and interests;
- technical and statistical data, such as your IP address, browser type, domain names, access times, and referring website addresses, which will automatically be collected by us to maintain quality of the service and to compile general statistics regarding use of our websites.
Separately, we encourage you to review the privacy statements of websites that you may link to from time to time through our Platforms to understand how these websites collect, use and share your information. Your use of such third-party websites is subject to their privacy policies and is not covered by this Policy.
As we cannot control or be responsible for the policies of other sites we may link to, or the use of any data you may share with them, you access these third-party websites at your own risk.
How We Collect Personal Data
We use different methods to collect data about you, including the following: –
You may provide us with your Personal Data by filling in forms or by corresponding with us through our websites, by post, telephone, email, chatbots, or other means of communications we employ from time to time. Such interactions include, but are not limited, to the following scenarios: –
- When you apply for, and/or use, our product(s) or service(s);
- When you create an account on any of our Platforms;
- When you subscribe to our service(s) or publication(s);
- When you provide us information via email or over a telephone conversation;
- When you request for marketing to be sent to you;
- When you enter a promotion or contest, complete a survey, or give us feedback;
- When you use mobile or web applications developed by us; and/or
- When you submit your resume or an application for an internship, employment, or other contracting opportunities with us.
- Automated technologies or interactions
- As you use our Platforms, we may automatically collect technical data about your equipment, browsing actions, and patterns. We collect this data by using cookies, server logs, and other similar technologies. Please see our Cookies Policy for further details.
Third parties or publicly available sources
We may receive your Personal Data from various third parties and public sources, including financial and transaction data from providers of technical, identification, compliance, payment, and delivery services.
What We Do with your Personal Data
The Personal Data you provide helps us to understand your needs, maintain our relationship with you, process transactions, fulfil our delivery obligations for any goods, services or activities you undertake with us, and improve our service delivery. In particular, we collect your Personal Data for the following purposes, including without limitation: –
- to provide our services to you;
- to conduct client due diligence as necessitated by law or other regulation;
- to process relevant information including conducting analytics, for the provision of products, services or activities that best meet your preferences or needs;
- fulfilling instructions, sending postal mail, and e-mails, providing marketing assistance, processing payments, and providing customer service;
- to respond to feedback from you and to respond to your queries, requests, and complaints;
- to provide updates on promotions and events;
- to improve our products and services and to customise our websites according to your interests;
- to develop content of our websites and our related network of websites;
- for safety, security, and general legal compliance;
- for record keeping;
- to conduct marketing activities including market research, customer profiling, customer insights, and targeted marketing activities;
- to carry out profiling and statistical analysis to improve the services provided to you;
- to market products, services, and activities offered by us, our partners as well as our appointed agents, and to conduct product or customer satisfaction surveys and market research, which you
- will always have the option of opting out from receiving such information;
- to ourselves use or for the use of third parties, including Facebook, cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on
- the Internet and to use such information to provide measurement services and targeted advertising,
- to post testimonials, reviews, endorsements or statements on our Platforms or marketing materials, from time to time, that may contain your Personal Data, with your consent. We will seek your
- express consent to use your Personal Data and your content when you provide your testimonials, reviews, endorsements or statements.
(collectively referred to as “Purposes”).
- Where we process your Personal Data pursuant to any of the above Purposes, we do so on one or more of the following legal basis: –
it is necessary for the performance of our contractual relationship with you, which is regulated by the applicable terms and conditions governing the use of the Platforms and by the specific forms collecting your data;
- it is necessary for our legitimate interests;
- it is necessary to comply with our legal obligations;
- it is authorised under any applicable law or regulation; or
- you are deemed to have consented to such processing under any applicable law.
- Please note that we may process your Personal Data for more than one lawful ground depending on the specific purpose(s) for which we are using your data. Please contact us if you need details about the specific legal grounds) we are relying on to process your Personal Data.
Disclosure of Your Personal Data
We may also use and disclose your Personal Data within the Lyte Group, and with and to third parties. Such third parties include our agents, authorised service providers such as marketing partners and web analysis companies, and their business partner, our auditors and professional advisors, business partners, our underwriters and insurers, law enforcement agencies, and any person to whom disclosure is permitted or required by any applicable laws, enforceable governmental requests or court orders. We impose strict obligations on the third parties mentioned above with which we share your Personal Data to maintain the integrity and security of that data. We only allow third parties to use your Personal Data for specified purposes and in accordance with our instructions.
We disclose your Personal Data in order to fulfil the Purposes, in which case, we may: –
- disclose, transfer, and jointly use your Personal Data to and with such third parties in Singapore and overseas, and your Personal Data may also be transmitted to data storage facilities or our offices and appointed agents in Singapore or other countries in connection with our performance of the transaction with you;
- share your Personal Data with our trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your Personal Data except to provide these services to us, and they are required to maintain the confidentiality of your Personal Data;
We may also disclose your Personal Data if required or authorised to do so by law or pursuant to a court order, including but not limited to circumstances where use and/or disclosure is: –
- necessary for any investigation or legal proceedings, including but not limited to fraud, intellectual property infringement or privacy;
- necessary for establishing, exercising or defending our legal rights, or obtaining legal services;
- necessary for responding to an emergency that threatens the life, health or safety of an individual;
- in connection with or forms part of any purchase, sale, lease, merger or amalgamation of the Lyte Group, including business or assets, or any other acquisition, disposal or financing of the Lyte Group, but otherwise it is not in our usual course of business to sell, rent or lease your Personal Data to third parties.
How We Seek Your Consent
Your express consent will be sought when first collecting your Personal Data. There will be instances where your consent for the collection or use of your Personal Data will necessarily be implied from the circumstances by nature of the task or transaction, including your interaction with us or in the course of signing up for, or accepting, any of our products, services, or activities you have requested.
Access to Your Personal Data
We will, upon your written request to our Data Protection Officer (see contact details and requirements below), allow you to enquire about the ways in which your personal data has been or may have been used or disclosed within a year before the request. Where required or authorised to do so by law, we reserve the right to charge a reasonable administrative fee for this service and/or deny your request for access to your Personal Data.
Ensuring Accuracy In Your Personal Data
You should ensure that all Personal Data submitted to us is current, complete and accurate. Failure on your part to do so may result in our inability to provide you with the products, services and activities you have requested.
If you believe that any Personal Data we are holding on you is incorrect or incomplete, please write to or email our Data Protection Officer (see contact details and requirements below).
How Long is Your Personal Data Kept
We will retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, the legal or business purposes of the Lyte Group as set out above, or as required by relevant laws.
When destroying Personal Data, we will take commercially reasonable and technically possible measures to make the personal identifiable information irrecoverable or irreproducible.
Security of your Personal Data
We are committed to ensuring the security and protection of your Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying modification, disposal or similar risks. We maintain physical, electronic and procedural safeguards to protect your Personal Data.
For example: –
- We use industry-standard Secure Sockets Layer (“SSL“) authentication to ensure the confidentiality of online transactions made on our site. SSL authentication and encryption of the information that you send to us over the Internet help protect your online transaction information from third party interception.
- We restrict the access of personally identifiable data to only specific authorised internal staff of the Lyte Group with dedicated login access and passwords.
- We ensure that our appointed IT service provider has the necessary security protocols in place to host and protect our data.
- While we strive to protect your Personal Data, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter our websites or computer systems (for example viruses, bugs, trojan horses, spyware or adware). Despite all of our efforts, there is always a risk that third parties may unlawfully intercept transmissions.
This reality is true of all Internet use. Further, we are not responsible for the privacy statements or content on websites not controlled by us.
Protection of Your Personal Data
If you access our website from a shared computer or a computer in an internet cafe, a library, or any public facility, certain information about you, such as your user ID, activity or reminders from our website, may also be visible to other individuals who use the computer after you. To protect your Personal Data or communication from being disclosed to others, you should log out, clear browsing data and close the web browser after using our website.
You should be aware of the risks associated with disclosing any information or transacting over the Internet or when using online portals, and we urge you to take every precaution when using the Internet to disclose your Personal Data to us, including using strong passwords, changing your password regularly, using a secure browser and not to share your password with anyone or via an unsolicited phone call or e-mail.
We will never ask for your password by phone or e-mail, so if you receive such an enquiry, please report the incident to our Data Protection Officer at email@example.com.
If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any loss or damage resulting from your act or omission to safe-keep your username and password from unauthorised use, and also for any information you transmit over the Internet which you do so solely at your own risk.
Compliance with the GDPR
In the event that we have existing access and consent to your Personal Data, and you are a data subject in the EU, please contact us should you wish to exercise any of your following rights: –
- to request for the erasure of your Personal Data;
- to request for the restriction of processing of your Personal Data;
- to object to the processing of your Personal Data; and/or
- to request to transfer your personal Data to you or a third-party.
All requests made to us in exercising the rights above will be processed within a reasonable time except where we refuse such requests in accordance with any applicable laws or regulations.
To the extent the Personal Data contain personal data which we process are subject to the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), you acknowledge and agree that for purposes of providing matching, measurement, and analytics services described hereinabove, the Lyte Group is the data controller in respect of such personal data, and where applicable, we may, from time to time, instruct Facebook Ireland Limited to process such personal data on your behalf as your data processor pursuant to these terms and Facebook’s Data Processing Terms, which are incorporated herein by reference. “Personal data”, “data controller” and “data processor” in this paragraph have the meanings set out in the Data Processing Terms.
- would like to withdraw your consent to any use of your Personal Data;
- would like to obtain access and make corrections to your Personal Data; or
- report any security incident relating to your username, password or transaction with us that involves your Personal Data,
Data Protection Officer
Lyte Ventures Pte Ltd
Email address: firstname.lastname@example.org
To protect your privacy and security, we will also require you to verify your identity before we can respond substantially to your request.
Last updated on 22 December 2022