Privacy Policy

Last Updated 1 June 2022


PLEASE READ THIS PRIVACY POLICY (this "POLICY") CAREFULLY.

1. Introduction

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 (defined below), visit and use the Quilt Software (defined below) and/or use our services.

This privacy policy describes how Quilt will use your data in relation to the actions described above as they relate to the license of the SPHERE dashboard, as may be updated or replaced by feature enhancements, software updates or system restore software (the "Quilt Software") provided by Quilt. 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 “Your rights in relation to your Personal Data” section.

By visiting the Website, using the Quilt Software and/or our services, you signify that you have read and understood this Policy, and that you agree to the terms of this Policy (which reference herein shall include any incorporated terms). Where this is required under applicable law, you provide your consent to us collecting, using and disclosing your personal data in accordance with this Policy.

We comply with the Personal Data Protection Act 2012 (the "Act") and the General Data Protection Regulation (the "GDPR") when dealing with Personal Data (as defined below).

2. Definitions

"Personal Data" means information about an identifiable individual (a natural person) that can be used on its own or with other information to identify, contact, or locate a single person, or to identify that individual in context.

"Terms of Service" means our terms of service or terms of use applicable to the Quilt Software, as may be updated from time to time.

"Website" means https://www.quilt.ai/, https://www.quilt.ai/sphere/, https://www.sphere.quilt.ai/ and/or https://www.quiltsphere.com/ (as the context requires).

3. Updates to the Policy

This Policy does not limit or exclude any of your rights under the Act and other applicable laws. If you wish to seek further information on the Act, please head to the following link.

We may change this Policy by uploading a revised policy onto the dashboard. The change will apply from the date that we upload the revised policy.

4. What information do we collect?

We collect, hold and process two (2) categories of Personal Data in relation to the Quilt Software.

a. Accounting and Marketing Data

This relates to Personal Data that we collect about you:

  1. (i) in connection with the creation or administration of a customer account;
  2. (ii) if you ask to receive information about us or our services or sign up to our newsletter;
  3. (iii) when you sign up to or access or use the Quilt Software;
  4. (iv) when you contact us directly (e.g. website enquiry form, email, live chat features or through your user dashboard) or visit our Website; and/or
  5. (v) if you participate in customer feedback surveys.

The Accounting and Marketing Data we collect may include, inter alia:

  1. (i) your name, username and password;
  2. (ii) your address, email address and phone number;
  3. (iii) your payment details, including billing addresses and credit card details, when you transact with us or subscribe to our services;
  4. (iv) your survey responses, marketing preferences, including any consents you have given us; and
  5. (v) your location or information related to the browser or device you use to access our Website.

b. Personal Data that forms part of the Data (as defined in our Terms of Service) (the “Client Data”)

This may include any Personal Data collected by our clients, including our client's end user's names, addresses, contact details or other details to help you with your experience.

We will not collect or process Client Data except as provided in our Terms of Service and/or other agreements with our clients that govern the processing of Client Data (as applicable) and we require our clients to comply with applicable privacy and data protection laws.

5. Who do we collect your data from?

‍We collect Personal Data about you from:

(a) you, when you provide that Personal Data to us, including via our Website and services through any registration, subscription or purchase process on our website, through any contact with us (including Live Chat or email), by entering information on Website or the Quilt Software in any other way, when you interact with us on social media platforms such as Facebook, LinkedIn and Twitter, or by providing us with feedback on our products or services; and/or

(b) third parties where you have authorized this or the information is publicly available. Where possible, we will collect Personal Data from you directly.

When you visit or use our Website or services, we may collect information about you:

(c) by recording clickstream data, which is non-personal information that is recorded when you click anywhere on a webpage and is used for the purposes of collecting, analyzing and reporting data about how you use our Website and related services; and

(d) through the use of cookies, web beacons and similar storage technologies (see more detail about our use of cookies below).

6. How do we use your data?

‍We process Personal Data for the following purposes:

(a) To fulfil a contract, or take steps linked to a contract: this is relevant where you transact with us or subscribe to the Quilt Software or any of our services. This includes:

  1. (i) to verify your identity;
  2. (ii) to take payments that are outstanding from you to us, including authorizing and processing credit card transactions;
  3. (iii) to respond to communications from you, including enquiries and complaints; and/or
  4. (iv) to provide customer service and make arrangements for the provision of our services, access to the Website or the Quilt Software; and

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

  1. (i) to provide the Website and services to you;
  2. (ii) to personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
  3. (iii) to improve our Website in order to better serve you;
  4. (iv) to allow us to better service you in responding to your customer service requests;
  5. (v) to send periodic emails regarding your subscription or other products and services, (you can choose to stop receiving our marketing emails by following the unsubscribe instructions included in those emails);
  6. (vi) to conduct research and statistical analysis (on an anonymized basis);
  7. (vii) to protect and/or enforce our legal rights and interests, including defending any claim;
  8. (viii) 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);
  9. (ix) to monitor customer accounts to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law;
  10. (x) to use information you provide to investigate any complaints received from you or from others, about our Website or our services;
  11. (xi) for any other purpose authorized by you, the Act or other applicable law; and/or
  12. (xii) to respond to lawful requests by public authorities, including to meet law enforcement requirements.

We may transfer your information in the case of sale, merger, consolidation, liquidation, reorganization or acquisition.

7. 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 Policy.

8. 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.

9. 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):

(a) 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;

(b) our external consultants (including technology and engineering teams), professional advisors (including lawyers and auditors) and agents; and/or

(c) 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, India, the United Kingdom and the United States. 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, India, the United Kingdom and/or the United States.

10. How do we protect your data?

Our Website and the Quilt Software are scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, any sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your Personal Data. Any transactions are processed through a gateway provider and are not stored or processed on our servers.

You can play an important role in keeping your Personal Data secure by maintaining the confidentiality of any password and accounts used in relation to our services. Please do not disclose your password to third parties. Please notify us immediately if there is any unauthorized use of your account or any other breach of security.

11. Do we use 'cookies'?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

(a) understand and save user's preferences for future visits; and

(b) compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies. If you turn cookies off, it won't affect your experience on our Website.

For more information, please head to the following link for our cookie notice which is hereby incorporated by reference.

12. Third-party disclosure

We do not sell, trade, or otherwise transfer to outside parties your Personal Data unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses for anonymized statistical information.

13. Your rights in relation to your Personal Data

(a) Subject to applicable laws, you may have rights in relation to your Personal Data.

(b) 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.

(c) 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).

(d) 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 Act and the GDPR. 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.

If you want to exercise either of the above rights, email us at [email protected].

Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Data, or the correction, that you are requesting).

14. 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 six (6) years after this. Where we process Personal Data in connection with performing a contract, we keep the data for six (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.

15. Third-party links

We do not include or offer third-party products or services on our Website or any third-party behavioral tracking.

16. Advertising

Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. We have not enabled Google AdSense on our Website but we may do so in the future.

17. Contact Information

If there are any questions regarding this Policy, you may contact us at: [email protected].