Privacy Notice

Last Updated: 7 July 2022

Summary of how we use your data
‍

• Quilt AI Pte. Ltd. as well as its affiliates, subsidiaries and related entities (also referred to as "Quilt", "we" or "us") use your personal data when you visit our website(s) and/or use our services.  
• Data is shared with companies in the Quilt group, third party providers and professional advisers. 
• If you email or contact us via our enquiries email, our “Contact Us” button or otherwise, we will respond and store your email address associated with your request whether it be for a career opportunity or a business relationship.
• If you add your email address to our subscription list, we will send you our newsletters and/or content emails at periodic intervals.
• Where we rely on your consent, such as for marketing our services to you, you may withdraw this consent at any time.
• Our privacy notice sets out more details of this processing, in particular the details of your data protection rights, including your right to object to certain processing. 
• This privacy notice does not cover personal data that we process in the course of carrying out social listening services on behalf of our clients. In this case, the client is the data controller of the information and such processing is subject to the client's privacy policies. 

What does this notice cover?

This notice describes how Quilt will make use of your data when you visit our website(s) and/or use our services. It also describes your data protection rights, including a right to object to some of the processing that we carry out. More information about your rights, and how to exercise them, is set out in the "What rights do you have in relation to your personal data?" section.

Quilt carries out social listening services on behalf of our clients, where we may process personal data that you publish on publicly available social media and web platforms. In this case, the client instructing us will be the data controller of the information. As a result, such processing will be covered by the privacy policies of our clients and not this privacy notice. You can obtain more information on the clients that we work with by contacting us using the details set out later in this notice.

By visiting our website(s) and/or using our services, you signify that you have read and understood this notice. Where this is required under applicable law, you provide your consent to us collecting, using and disclosing your personal data in accordance with this notice.

We may change this notice at any time by uploading a revised notice onto our website(s). Unless otherwise stated, the change will apply from the date set out in the revised notice. You are responsible for ensuring you are familiar with the latest notice, and we encourage you to review this notice regularly to stay informed. By continuing to access our website(s) and/or use our services from the date of the revised notice, you agree to be bound by the revised notice. This notice was last updated on the date shown at the top of this web page.

What information do we collect? 

We collect and process personal data about you when you visit our website(s) and/or use our services. This includes:

• Your name, username and password;
• Your address, email address and phone number;
• Your payment details, including billing addresses and credit card details, when you transact with us or subscribe to our services;
• Your marketing preferences, including any consents you have given us; and
• Information related to the browser or device you use to access our website(s). 

What information do we receive from third parties?

Sometimes, we receive information about you from third parties. In particular:

• Your contact information and information related to your profile, when you interact with us on social media platforms such as Facebook, LinkedIn and Twitter; and
• Usage and technical information through cookies and related tracking technologies, such as Google Analytics (please see our Cookie Notice for more details).

How do we use this information, and what is the legal basis for this use? 

If you are in the European Economic Area or the United Kingdom, we are required to disclose the purpose(s) for which we process your personal data and the legal basis for processing your personal data. We are also required to disclose the purposes for processing your data under certain applicable laws, including the Singapore Personal Data Protection Act. 

We process personal data for the following purposes:

• To fulfil a contract, or take steps linked to a contract: this is relevant where you transact with us or subscribe to our services. This includes:

1. Verifying your identity;
2. Taking payments; 
3. Communicating with you; and
4. Providing customer services and making arrangements for the provision of our services;

• As required by us to conduct our business and pursue our legitimate interests, in particular:

1. We will use your information to respond to any comments or complaints you may send us;
2. We monitor use of our websites and online services, and use your information to help us monitor, improve and protect our products, content, services and websites, both online and offline;
3. We use information you provide to personalize our website(s) or services for you;
4. If you provide a credit or debit card as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see data sharing below);
5. We monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
6. We use information you provide to investigate any complaints received from you or from others, about our website(s) or our services;
7. We will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and
8. We use data of some individuals to invite them to take part in market research;

• With your consent where required by applicable laws:

1. We will send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners; 
2. We place cookies and use similar technologies in accordance with our Cookie Notice and the information provided to you when those technologies are used; and
3. On other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time; and

• For purposes which are required by law, including responding to requests by government or law enforcement authorities conducting an investigation.

Relying on our legitimate interests

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.

Withdrawing consent or otherwise objecting to direct marketing

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds (where recognized under applicable law) for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

Who will we share this data with, where and when?

Quilt may disclose your personal data to the following categories of recipients (in all cases, only when necessary to fulfil their functions):  

• Third party service providers who process your personal data on our behalf for the purposes identified above. In particular, we use third party providers of website hosting, maintenance, call center operation and email marketing services. 
• Our external consultants (including technology and engineering teams), professional advisors (including lawyers and auditors) and agents.
• Government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business. 

We have offices in Singapore, the UK and the US. Therefore, where required to perform our contract with you or for our wider business purposes, the information that we hold about you will be transferred to, and stored at, a destination in Singapore, the UK and the US.

Transfers of data from within the EEA or the United Kingdom to outside the EEA

Where information is transferred from within the EEA, or the United Kingdom, to a country outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request by contacting us at using the details set out below.  

Transfers of data from a country not within the EEA or the United Kingdom to outside of that country 

When information is transferred from a country (not within the EEA or the United Kingdom) to outside of that country, we will ensure that your information is protected to at least the same standard as that which is required in the originating country. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.

What rights do you have in relation to your personal data?‍

Subject to applicable laws, you may have rights in relation to your personal data. 

Such rights include the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). 

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are set out under applicable law, including the Singapore Personal Data Protection Act and the EU General Data Protection Regulations. We will inform you of relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to the data protection authority where you live, work or where you believe a breach may have occurred. 

We will indicate to you at the point of collection whether the provision of information is mandatory: if relevant data is not provided, then we will not be able to provide our website(s) or services to you. All other provision of your information is optional – in this case, there will be no impact on the provision of our website(s) or services if you do not provide us with the requested information. 

How long will we retain your data?

Where we process user registration data, we do this for as long as you are an active user of our services and for 6 years after this. Where we process personal data in connection with performing a contract, we keep the data for 6 years from your last interaction with us.

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing indefinitely so that we can respect your request in future.

Which Quilt entity is my data controller, and which affiliates might my data be shared with?

The data controller for your information is Quilt AI Pte. Ltd. We may share your personal data with our affiliates where required to perform our contract with you or for our wider business purposes. You can obtain the identity and contact details of the affiliates with whom we share your personal data by contacting us using the details set out below. 

How can you get in touch with us?

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch with us at [email protected] or by writing to 3 Coleman Street, #03-24 Peninsula Shopping Complex, Singapore 179804.

‍