Privacy Policy

Thank you for using Proxima Beta’s services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to the website for Level Infinite (www.levelinfinite.com) and our press site (press.levelinfinite.com) (collectively referred to as “Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service. If you use the LEVEL INFINITE PASS website or account, please refer to the LEVEL INFINITE PASS privacy policy instead (https://account.levelinfinite.com/privacypolicy.html).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Service?	If you register for a LEVEL INFINITE PASS Account, this includes a username and email address. We will generate an Open ID, which is an internal ID for your account. Depending on your use of the account and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account.If you sign up for newsletters, we use your name and email address to send you newsletters. We use newsletter statistics to monitor the performance of our newsletters.We use cookies and other similar technologies to collect information about you when you use the Service, including your standard internet log information and details of visitor behaviour patterns.If you choose, you can provide other information to personalise your experience of the Service. This includes your language selection.If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.	More Information.
How will we use your information?	We use your information to provide you with the Service, to send you newsletters as per your subscription request, to maintain and monitor the performance of our services, to improve our services, to personalise your experience of the Service, to resolve user queries, and to comply with our legal obligations and enforce our legal rights.	More Information.
Who do we share your information with?	We use third parties and work with our affiliates to help us deliver the best possible experience (such as for website hosting, newsletter delivery, and performance analysis). All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above).In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
Where do we process your information?	Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.We have servers for the Service in Singapore. We also have support, engineering and other teams who may support the Service, including from Singapore.We use Mailchimp, a third-party email newsletter provider to email newsletters and to monitor the performance of our newsletters. Mailchimp is located in the United States. Mailchimp also engages third-party vendors who process personal information on its behalf in the United States and in other international locations.We use a third-party service, Google Analytics, to collect cookies information. Google maintains servers around the world and your information may be processed on servers located outside of the country where you live.For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.	More Information.
How long do we keep your information?	Unless otherwise required or permissible by applicable laws, we retain your information for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to the Level Infinite website!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the website (www.levelinfinite.com) and the press site (press.levelinfinite.com) for Level Infinite (collectively referred to as “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo@levelinfinite.com. We have representatives for data protection purposes listed here.

Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

Children

Children must not use the Service for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located	Minimum age of the user
Canada	13
European Economic Area	16
Hong Kong	18
India	18
Indonesia	21
Japan	18
Macau	18
Malaysia	18
Philippines	18
Qatar	18
Saudi Arabia	18
Singapore	13
Switzerland	14
Taiwan	20
Thailand	20
United Arab Emirates	21
United Kingdom	13
United States	13
Vietnam	16

How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

For users who live in Brazil, the European Economic Area, Indonesia, Switzerland, Thailand, Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
Newsletter information: name, email address	We use this information to send you newsletters as per your subscription request.	We use this information with your consent.
LEVEL INFINITE PASS Account registration information: email address, user ID, nickname, user token, Open ID, date of birth (only if you are in US, UK or Colombia), and country. https://account.levelinfinite.com/privacypolicy.html	We use this information to create your LEVEL INFINITE PASS Account in accordance with your request. Date of birth is only processed momentarily and not stored.	Necessary to perform our contract with you to set up your LEVEL INFINITE PASS Account.
Information collected to verify your identity: Open ID, status of verification (through third-party service provider) and adult / minor status This is applicable only if you are located in Korea	We use this information to verify your identity.	It is in our legitimate interest to verify your identity to ensure you are eligible to use the Service.
Cookies information (collected via Google Analytics) including the following: Your browsing behaviour while using the Service, including time on the site (the total time spent on the site, the time spent on each page and in what order the pages were visited), what internal links were clicked (based on the URL of the next pageview)User agent stringInitial page inspectionGeographic locationOperating system informationBrowser informationDevice information including screen sizeReferring siteWhether Java or Flash is installed	We use this information to maintain and monitor the performance of the Service and to improve the site and the services it offers to our visitors. Please refer to our Cookies Policy  here for more details.	It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services.
Cookies information (processed by other cookies set by us) including the following: Cookie preference Download informationLanguage setting	We use this information to personalise your experience of the Service. Please refer to our Cookies Policy  here for more details.	Necessary to perform our contract with you to support the Service.
Newsletter statistics (collected via Mailchimp) such as email opens, clicks, unsubscribes, IP address	We use this information to monitor the performance of our newsletters.	It is in our legitimate interest to use this information to monitor the performance of, and to improve, our services.
Customer support information:  email address (if you contact us via email), screenshots to illustrate problem (optional), any other information you provide to us, details of ticket, complaint and handling	We use this information to provide support and troubleshooting, such as addressing and remediating technical issues and bugs, and improve our services.	Necessary to perform our contract with you to support the Service.

How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Service in Singapore.We also have support, engineering and other teams who may support the Service, including from Singapore.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

• Third parties that provide services in support of the Service, including providers of services that process information identified in this policy for the purpose of providing the Service, Amazon Web Services, who hosts the website in Singapore, and Mailchimp, a email newsletter provider located in the United States. Mailchimp engages third-party vendors who process personal information on its behalf in the United States and in other international locations. We also use Google Analytics to collect cookies information. You may find more information on how Google Analytics processes and safeguards data here. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).
• Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you.  All such group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying  with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
• Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

Data Retention     

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law.If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Newsletter information	For as long as you subscribe to the newsletter. If you submit an un-subscription request, your data will be deleted within 30 days.
LEVEL INFINITE PASS Account registration information (except date of birth) Information collected to verify your identity (Korea only)	Stored for the lifetime of your use of the LEVEL INFINITE PASS Account (i.e. until account deletion in accordance with your request) and then deleted within 30 days. Date of birth is only processed momentarily to verify your eligibility to use LEVEL INFINITE PASS Account and not stored on our servers.
Cookies information (collected via Google Analytics)	Stored for up to 2 years by Google Analyics.
Cookies information (processed by other cookies set by us)	Download information is stored for 30 days. Other information is only processed and stored on your device browser, and is not retained on our servers.
Newsletter statistics	Stored by Mailchimp according to its retention policy.
Customer support information	Stored until resolution of customer support case.

Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). To exercise any of your rights, please contact us.

Access

You may access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account or you can contact us.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent or pursuant to our contract with you, as described above in Section 3 (How We Process Your Personal Information). We will provide further information to you about transferring this data if you make such a request.

Correction

You may correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account and correct the personal information by contacting us.

Erasure

You may delete certain personal information, by contacting us. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us.Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

Advertising

You may choose to stop receiving marketing promotions from us by following the opt-out instructions included in the promotions or by contacting us.

Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: dpo@levelinfinite.com

Mailing Address:

International Privacy & Data Protection Centre

30 Raffles Place #12-01

Singapore

048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 3-5 1082 VA Amsterdam	dpo@levelinfinite.com
UK	Image Frame Investment (UK) Limited	4th Floor 80 Strand London WC2R 0RL	dpo@levelinfinite.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo@levelinfinite.com

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:

• Identifiers, such as your name as your email address. This information is collected directly from you.
• Cookies information as described in the main Privacy Policy. This information is collected directly from you and your device.
• Newsletter statistics (collected via Mailchimp) as described in the main Privacy Policy. This information is collected directly from you or your device.
• Customer support information as described in the main Privacy Policy. This information is collected directly from you.
• Other information described in subdivision (e) of Section 1798.80. This information is collected directly from you in the context of being our consumer.

We collect and disclose your personal information for the following purposes:

• To provide you with the Service and customer service.
• To send you newsletters as per your subscription request.
• To maintain and monitor the performance of, and to improve, our services.
• To personalise your experience of the Service.

For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect to the following types of entities:

• Other companies within our corporate group who process your personal information in order to operate the Service.
• Other companies that provide services on our behalf in support of the Service and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
• Regulators,  judicial authorities and law enforcement agencies and other third parties where reasonably necessary to comply with a legal obligation; enforce our terms and conditions; detect and prevent fraud or security issues; and to protect ours and others’ rights, property or safety.
• Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold or shared Personal Information of California residents within the meaning of “sold” and “share” in the CCPA, and we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information about you.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see Section 6 (Data Retention).

Rights under the CCPA:

If you are a California resident and the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:

• Request we disclose to you free of charge the following information covering the 12 months preceding your request:
  • the categories of personal information about you that we collected;
  • the categories of sources from which the personal information was collected;
  • the purpose for collecting personal information about you;
  • the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
  • the specific pieces of personal information we collected about you;
• Request we delete personal information we collected from you, unless CCPA recognises an exception;
• Request we correct inaccurate personal information that we maintain about you; and
• Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.  

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need you to provide certain information such as your email address, or any other information necessary to verify your identity.  

Under the CCPA, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission.  We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as specified in Section 8 (Contact).

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

France

Instructions for the processing of your personal data after your death. You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation, your heirs, or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us as set out in Section 8 (Contact).

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

Where we permit any third parties to collect and use sensitive personal information, we shall use reasonable measures to ensure that the third parties do not further disclose such information to the extent required by applicable laws.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us as set out in Section 8 (Contact). Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to use the Service.

In the event we fail to maintain the confidentiality of your personal information, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information, in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to use the Service.

By accepting this Privacy Policy and using our services, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases, affiliates or service providers, and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information) may include “special care-required personal information” (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 8 (Contact).

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Service to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

• Our data protection officer, responsible for the management and safety of your personal information
  • Telephone: +603-22872388
  • Email: as set out in Section 8 (Contact)

Philippines

You are entitled to the following rights:

• Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
• Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
• Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
• Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
• Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy and using our services, you consent to us:

• collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);
• sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
• transferring or storing your personal information in destinations outside the Philippines as described in Section 4 (How We Store and Share Your Personal Information)

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Singapore

By accepting this Privacy Policy and using our services, you consent to the cross-border transfer of your information to any country where we have databases, affiliates or service providers, and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact).

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or knowingly allow such persons to use the Service platform. If you are under 7 years of age, please do not attempt to use our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Service. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Service.

Thailand

By accepting this Privacy Policy and using our services, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to use the Service.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

• withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;
• request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;
• request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or
• lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber-security threats in the UAE.

Vietnam

By accepting this Privacy Policy and using our services, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.

Virginia

This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.

If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:

• request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.
• request we delete personal data we collected from you, unless the law recognises an exception;
• request we correct inaccurate personal data that we maintain about you;
• be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the law.

We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

How to Exercise Your Rights

If you are a Virginia resident to whom the VCDPA applies, you may exercise your rights, if any, by contacting us as set out in Section 8 (Contact).

How to Appeal Decision on Your Request

If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us as set out in Section 8 (Contact).