Last Updated: 7 July 2022
Summary of how we use your data
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:
What information do we receive from third parties?
Sometimes, we receive information about you from third parties. In particular:
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:
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):
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.