Through this Privacy Policy, THINKWARE CORPORATION (the “Company”, “we”, “our”, “us”) intends to inform the users of the purpose and method of collecting, using and disclosing the Personal Data provided by the users to use the Thinkware Connected Service of the Company (the “Service”), including the measures taken for the protection of such Personal Data .
This Privacy Policy is incorporated as part of the Thinkware Connected Service Terms and Conditions of Use (“T&C”). Unless otherwise defined in the Privacy Policy, terms used in this Privacy Policy have the same meanings as in our T&Cs and in the Singapore Personal Data Protection Act (2012). This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of Personal Data by us.
1. Definitions
2. Your consent for the Company to collect and use Information
3. Purpose for Collection and Use of Personal Information
4. Retention of Personal Data
5. Transfer of Personal Data
6. Disclosure of Personal Data
7. Protection of Personal Data
8. Your Rights
9. Service Providers
10. Children's Privacy
11. Changes to this Privacy Policy
12. Contact Us
(a) ‘Data Subject’ is any individual who is the subject of Personal Data.
(b) ‘Personal Data’ as defined in the Singapore Personal Data Protection Act (2012) means data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which the Company has or is likely to have access.
(c) ‘User’ is the individual using our Service, and may be a Data Subject.
(d) ‘Usage Data’ is any usage pattern and details of using the Service and/or any product.
We collect several different types of Personal Data and information for various purposes to provide and improve our Service to you. By choosing to use our Service by purchasing our products and/or signing up as a Member, you are deemed to have agreed to the collection and use of Personal Data and information in accordance with this Privacy Policy.
The Company shall use the Personal Data collected for the following purposes:
(a) Providing the Service, including but not limited to obtaining payment of any fees, service charge, expenses, delivery of the products, issuing invoices, requests and demands to the billing address, verifying the identity of the user for security, regulatory obligations and financial transaction.
(b) Verifying the identity of the User using the membership service under the membership management system, identifying the User, preventing any abuse or variation of the Service including in an unjust manner or without authorization, attending to any feedback, queries or complaints, and conveying of notices to the User or Member.
(c) Researching and developing of new components of service, conducting surveys and/or marketing services, providing any personalized service, conveying of information, and managing the use of the membership service.
(d) Analyzing any road, pedestrian, parking or traffic conditions, location and sharing the same to any regulatory authorities or other interested parties.
(e) Sending it on whether as raw footage, blackbox contents or edited, defined or extracted versions of the original footage via any distribution channel whether via real time or delayed mobile app service to the Member.
(a) We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, disclosure to any regulatory authority or third parties), resolve disputes, and perform obligations under our legal agreements and policies.
(b) We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
(c) The Personal Data may be used by us directly, our parent company, any of our group companies, our agents, service providers, intermediaries and/or sub-contractors for the purpose of communicating with you on any matter relating to your use of our Service, our products and/or managing your membership.
(a) We may transfer your Personal Data, and maintain any Personal Data on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
(b) If you are located outside of the Republic of Korea and provide information to us, please note that we may transfer the data, including Personal Data, to the Republic of Korea and process it there.
(c) Your submission of such information represents your consent to that transfer.
(d) We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Data.
(a) Disclosure for Law Enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to by law or in response to valid requests by public authorities (e.g., a court or a government agency).
(b) Legal Requirements
We may disclose your Personal Data in good faith belief that such action is necessary:
(a) We shall use our best endeavors to protect Personal Data in our possession or under our control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risk. However, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security or lapses by third party service providers.
(b) We strongly advise that you do not share or publicize any footage which contains any Personal Data which we send to you, on any social media or public platform which may cause, directly or indirectly, any parties to lodge any claims for unauthorized recording of the Personal Data.
(c) You agree to hold us harmless from, and indemnify us for, any costs, expenses, losses, responsibility, claims, proceedings we may incur or face should there be any claims by any third parties arising from or related to your release or publication of any footage or information which we originally make available to you.
(a) We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us by writing to our Data Protection Officer at Email address: general@zmc.com.sg
(b) You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
(c) In certain circumstances as provided under Singapore law, you have the right and upon your payment of our reasonable costs:
(a) Third Parties
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
(b) Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
(c) Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
(d) Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g., payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your Personal Data and information is governed by their privacy policies or terms and conditions. As more information becomes available, it will be updated.
Our Service does not address anyone under the age of 18 ("Children" or “Child”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with their Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers. ).
We may revise this Privacy Policy from time to time including when any relevant legislation, guidelines, or regulation or the internal policy of the Company is amended. Upon the amendment of this Privacy Policy, the Company shall make a public announcement through the App. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, please contact our Data Protection Officer at Email address: general@zmc.com.sg