Privacy Policy

Last updated: 3 September 2024

This privacy policy ("Privacy Policy") elucidates the procedures by which Aelf Pte Ltd("Aelf", "our", "Company", "we", or "us") gathers, employs, and divulges information about you.

We reserve the right to modify this Privacy Policy periodically. Should alterations occur, we will notify you by amending the date at the top of this policy. Additionally, in certain instances, we may provide further notification, such as appending a statement to our Website or dispatching a notification to you. We encourage you to regularly review this Privacy Policy to remain informed about our information procedures and the choices at your disposal.

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regard to your personal information, please contact us here.

1. Our Role In Your Privacy

This Privacy Policy is applicable to you if you:

- visit our website at https://www.aelf.com (the "Website"); or

- engage with us in other related ways ― including any sales, marketing, or events.

In this privacy policy, if we refer to:

- “Website,” we are referring to any website of ours that references or links to this privacy policy.

- “Services,” we are referring to our Website, and other related services, including any sales, marketing, or events.

The purpose of this Privacy Policy is to explain to you in the clearest way possible what information we collect, how we use it, how we share the information on a need-be basis and what rights you have in relation to it. If there are any terms in this Privacy Policy that you do not agree with, please discontinue use of our Services immediately.

Please read this Privacy Policy carefully, as it will help you understand what we do with the information that we collect.

2. Your Responsibilities

- Read this privacy policy

- If you provide us with personal information about other people, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. By submitting the information you confirm that you have the right to authorise us to process it on our behalf in accordance with this privacy policy.

3. Collection of Information

Information you provide to us: We gather information either directly or indirectly from you when you interact with us or other sources connected to us. This may include filling out forms, making purchases, communicating with us via third-party platforms, participating in contests or promotions, seeking customer support, or engaging in other forms of communication. The personal information we collect may encompass your name, email address, postal address, phone number, credit card details, and any additional information you choose to share.

General Information we collect from you:

- a. Personal information you disclose to us

- We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.

- The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products, Services, and features you use. The personal information we collect may include the following:

- Contact details – We may collect names; phone numbers; email addresses; mailing addresses; contact preferences; and other similar information.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

- b. Information we collect automatically when you interact with us:

Upon accessing our Website or engaging in transactions with us, certain information is automatically collected, including:

- Transactional Information: Details pertaining to purchases or returns, such as product specifications, purchase prices, and transaction dates and locations, are collected.

- Device and Usage Information: We gather data regarding how you access our Website, encompassing information about your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use) and device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).

- Location Information: Subject to your device permissions, we may collect precise location data such as, but not limited to the country, location, information about how and when you use our Website and other technical information such as device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your ‘location setting’ on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services. You have the option to cease the collection of precise location information at any time (refer to the "Your Rights and Choices" section below for further details).

- This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

- c. Information we collect from other sources: We may obtain information about you from third-party sources, such as identity verification services, data analytics providers, and mailing list providers (if applicable).

4. Use of Information

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We may use your information which we collect or receive for the purposes set out below:

- To send administrative information to you – to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

- To protect our Services – as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

- To enforce our terms, conditions and policies – for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

- To respond to legal requests and prevent harm – If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

- Fulfill and manage your orders – to fulfill and manage your orders, payments, returns, and exchanges made through the Website.

- Administer prize draws and competitions – to administer prize draws and competitions when you elect to participate in our competitions.

- To deliver and facilitate delivery of services to the user – to provide you with the requested service.

- To respond to user inquiries/offer support to users – to respond to your inquiries and solve any potential issues you might have with the use of our Services.

- To send you marketing and promotional communications – We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, provided this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time.

- Deliver targeted advertising to you – to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness

- Responding to Job Applications – to respond to an employment or independent contractor application you may have submitted with aelf.

5. Sharing of Information

We may process or share your information under the following circumstances or as otherwise outlined in this Privacy Policy:

- Consent – if you have given us specific consent to use your personal information for a specific purpose.

- Legitimate Interests – when it is reasonably necessary to achieve our legitimate business interests.

- Performance of a Contract – Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

- Legal Obligations – where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

- Vital Interests – where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your information or share your personal information in the following situations:

- Business Transfers – We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

- Vendors, Consultants, and Other Third-Party Service Providers – We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this privacy policy , we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

- Affiliates – We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

- Business Partners – We may share your information with our business partners to offer you certain products, services, or promotions.

6. Who Will Your Information Be Shared With?

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in section 14 below.

- Data Analytics Service Providers

- Data Storage Service Providers

- Cloud Computing Service Providers

- Communication & Collaboration Tools

- Performance Monitoring Tools

- Product Engineering & Design Tools

- Social Networks

- Sales & Marketing Tools

- Testing Tools

- Website Hosting Service Providers

7. Use of Cookies And Other Tracking Technologies

While we do not directly utilize cookies or other tracking technologies on our Website, we may engage with third-party service providers who deploy such technologies as part of their service offerings. For instance, we use Hotjar in order to better understand our users' needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users' experience (eg how much time they spend on which pages, which links they choose to click, what users do and don't like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users' behavior and their devices device's IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. By interacting with our Website, you may be subject to these third-party technologies, which are governed by the respective provider's privacy policies. We recommend reviewing these policies to understand how your information may be collected and used. For further details, please see the 'about Hotjar' section of Hotjar's support site.

8. Transfer of Information to Other Jurisdictions

Aelf operates and engages service providers in various jurisdictions. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. By using our Website, you acknowledge and agree to such transfers and processing, including to and in the United States. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable laws.

- European Commission’s Standard Contractual ClauseWe have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

9. Duration of Storage of Information

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this Privacy Policy will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. Maintaining security of the Information

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we collect and process.

However, please remember:

- Despite our safeguards and efforts to secure your information, unfortunately no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information.

- Transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

- You are responsible for your username and password and should keep them safe.

- If you believe your privacy has been breached, please contact us immediately here.

11. Your Rights and Choices

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right to :

- Request access and obtain a copy of your personal information.

- Request rectification or erasure.

- Restrict the processing of your personal information and, if applicable, to data portability.

- In certain circumstances, you may also have the right to object to the processing of your personal information.

- If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

12. Controls For Do-not-track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

13. Changes To This Privacy Policy

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

14. Contact Us

If you have questions or comments about this privacy policy, you may email us here.

15. How Can You Review, Update, Or Delete The Data We Collect From You?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, have any inaccurate information corrected or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us on the above provided details.