ERGO GLOBAL PRIVACY POLICY
INTRODUCTION
Welcome to Ergo Global’s Privacy Policy (“Privacy Policy”).
Ergo Global Pte. respects your privacy and is committed to protecting your personal data.
This Privacy Policy will inform you as to how we look after your personal data when you visit our website https://ergoglobal.com/, regardless of where you visit it from (“Website”) and tell you about your privacy rights and how the law protects you. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Policy.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. [COOKIES]
5. [HOW WE USE YOUR PERSONAL DATA]
6. [DISCLOSURES OF YOUR PERSONAL DATA]
10. [YOUR CHOICES AND LEGAL RIGHTS]
11. [GLOSSARY]
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY POLICY
This Privacy Policy aims to give you information on how Ergo Global collects and processes your personal data through your use of the Website, including any data you may provide through this Website when you sign up for our newsletter, purchase a product or service, or take part in a competition.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
WHO WE ARE:
Ergo Global is made up of different legal entities, details of which can be found here. This Privacy Policy is issued on behalf of the Ergo Global Group, so when we refer to “Ergo Global,” “Company,” “we,” “us,” or “our” in this Privacy Policy, we are addressing the relevant entity within the Ergo Global Group responsible for processing your data. Ergo Global acts as a data controller when collecting information from users through our Website. We will inform you which entity will serve as the data controller for your information when you purchase a product or service from us. This information may be provided before or at the time of processing your order, referenced in any invoice issued to you, or communicated to you at another appropriate time. You are always welcome to contact us to inquire about the specific entity currently responsible for controlling your data.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise the rights granted to you under this Privacy Policy, see the link, please contact us at the contact details below in the first instance. If you are not satisfied with resolving your request, please contact the DPO using the details set out below.
If you have any questions regarding this Privacy Policy, or if you wish to exercise any of the rights granted to you under this policy, please reach out to our Data Protection Officer (DPO) using the contact information listed below:
CONTACT DETAILS
For the attention of: DPO
Mailing address: 74, South Bridge Road
#02-01
Wong Shee Fun Building,
Singapore 058704
Email: [email protected]
If you are not satisfied with the resolution provided by DPO, you always have the right to make a complaint to your local data protection supervisory authority (“DPSA”). We would, however, appreciate the chance to deal with your concerns before you approach the DPSA, so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our Privacy Policy under regular review. Historic versions can be obtained by contacting us. We will notify you of any substantial changes in the management of personal information. Notification may be provided through various means, including the contact information you have supplied. The revised Privacy Policy will take immediate effect upon posting unless otherwise specified. Your continued use of the Website after the effective date of the updated Privacy Policy will signify your consent to these modifications. However, we will not use your personal data in a significantly different manner than disclosed at the time of collection without obtaining your consent. If you disagree with the changes, you shall stop using our Website.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
CHILDREN DATA
Our Website is designed for a general audience and is intended for adults 18 and older. We do not knowingly collect personal information from minors, anyone younger than age 18. If we become aware that a child younger than 18 has provided us with personal information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that we have collected personal information from your child, please contact us at: [email protected].
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, last name or similar identifier.
- Contact Data includes billing address, delivery address, email address, and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type, and version, time zone setting, and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses, including messages between you and our consultants and answers to questions of multiple choice or other free-form text inputs. This also includes information about your working patterns, movement behaviors, and sleep patterns.
- Usage Data includes information about how you use our Website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data includes information about your IP address, the country code/region/state/city associated with your device, and the time zone.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We refrain from intentionally gathering Sensitive Information from users and strongly advise against sharing any such data, encompassing health-related details, medical information, physical health diagnosis, or medical records, during the use of the Website. Disclosing sensitive data is not required to access the complete functionality of the Website. We do not collect any information about criminal convictions and offenses.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We will collect and process the following data about you:
- Information you give us. This is information (including Identity, Contact, Financial, Marketing, and Communications Data) you consent to giving us about you by filling in forms on the Website and any related services, sales, marketing, or events (collectively referred to as the “Services”), or by corresponding with us (for example, by post, email or chat). This includes personal data you provide when you:
- apply for our products or services;
- purchase our products or services;
- subscribe to our services or publications;
- request marketing to be sent to you;
- share data via our social media functions;
- enter in a competition, promotion, survey; or
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical and Usage Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar tracking technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our “Cookies” section below for further details.
- Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- analytics providers such as Google and Smartlook;
- public databases and joint marketing partners;
- advertising networks; and
- search information providers such as Google.
- Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services.
- Identity and Contact Data from data brokers or aggregators, social media profile information, marketing leads, and search results and links, including paid listings (such as sponsored links). We may collect limited data from publicly available databases, marketing partners, and other outside sources.
4. COOKIES
When you visit our Website, our servers automatically record data that is transmitted by your browser. The technology used to collect information automatically from users may include cookies and other tracking technologies. For detailed information about the tracking technologies employed on our Website, please refer to our Cookie Policy.
5. HOW DO WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal obligation.
- Where you provide your consent for the specific purposes of the processing of your personal data (e.g., before sending direct marketing communications to you via email). You have the right to withdraw consent to marketing at any time by contacting us at the details provided below.
Review the Lawful Basis section in the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
To register you as a new customer | Identity Data Contact Data |
Performance of a contract with you |
To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us |
Identity Contact Contact Data Financial Data Transaction Data |
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
To manage our relationship with you which will include: Notifying you about changes to our Terms and Conditions or this Privacy Policy Asking you to leave a review or take a survey |
Identity Data Contact Data Profile Data Marketing and Communications Data Location Data |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
To enable you to partake in a prize draw, competition or complete a survey | Identity Data Contact Data Profile Data Usage Data Marketing and Communications Data |
Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, fraud prevention, reporting and hosting of data) | Identity Data Contact Data Technical Data Usage Data Location Data |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Necessary to comply with a legal obligation |
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Data Contact Data Profile Data Usage Data Marketing and Communications Data Technical Data Location Data |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) With your consent |
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences | Technical Data Usage Data Location Data |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business operations) |
To manage our marketing email campaigns | Identity Data Contact Data Technical Data Usage Data Profile Data Marketing and Communications Data Location Data |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) With your consent |
To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity Data Contact Data Technical Data Usage Data Profile Data Marketing and Communications Data Location Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the “Internal Third Parties” section below within the Glossary.
- External Third Parties as set out in the “External Third Parties” section below within the Glossary.
- Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We may also disclose your personal information in other circumstances as required by law:
- Legal and Investigative purposes. We may also disclose your personal information as required by law for legal and investigative purposes. This includes sharing information with government agencies, law enforcement, or private parties to comply with legal obligations, conduct investigations, protect the rights and interests of Ergo Global or third parties, ensure public safety, or prevent unlawful, fraudulent, or unethical activities. Disclosure may occur when we deem it necessary or appropriate to:
- Respond to applicable laws, regulations, legal processes, or government requests.
- Detect, prevent, or address fraud, security, or technical issues.
- Protect the rights, property, or safety of Ergo Global, our users, or the public.
7. INTERNATIONAL TRANSFERS
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Singapore, United Kingdom and Ireland. If you are accessing our Sites from outside Singapore, United Kingdom or European Union, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in and other countries.
If you are a resident in the European Economic Area (“EEA”), please consider that we and many of our external third parties are based outside the EEA so our and their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the EEA which give personal data the same protection it has in the EEA.
- When using service providers from countries with inadequate data protection, we rely on the European Commission’s standard contractual clauses or other appropriate cross-border transfer mechanisms to ensure adequate protection in compliance with applicable laws.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We share your personal data within the Ergo Global Group. This will involve transferring your data outside the EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. DATA SECURITY
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Services within a secure environment.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We implement the following security technical measures:
- TLS Encryption Technology: Use of Transport Layer Security (TLS) technology for encryption during all-access to the Services.
- SSL Data Encryption: Implementation of Secure Socket Layer (SSL) technology for data encryption during information upload and transmission between our facilities.
- HTTP Strict Transport Security: Utilization of HTTP Strict Transport Security to provide an additional layer of protection for users.
- Regular Evaluation: Periodic evaluation of personal data collection, storage, and processing procedures, including physical security safeguards, to prevent unauthorized access to our systems.
We have further implemented the following organizational measures:
- Need-to-Know Access: Access to user personal data is granted to Ergo Global employees and contractors exclusively on a need-to-know basis.
- Confidentiality Commitments: Our personnel are obligated to confidentiality commitments through Non-Disclosure Agreements (NDAs) and employment contracts.
- Access Mechanism Security: Implementation of a secure mechanism for granting and revoking access to data hosting.
- Annual Data Security Training: All personnel undergo annual mandatory training on data security measures and knowledge of the data breach policy.
- Education on Data Protection Standards: Education of the personnel on personal data protection standards outlined in the Company’s internal policies on data protection.
- Certified Cloud Infrastructure Services: Deployment of certified cloud infrastructure services conforming to globally recognized security assurance frameworks and certifications, including ISO 27001, ISO 27017, ISO 27018, PCI DSS Level 1, and SOC 1, 2, and 3, validated by independent third-party assessors.
9. DATA RETENTION
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Most commonly we store personal data within one year of your giving a consent to process your personal data, for example by login or other use of our Website. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for three years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
10. YOUR CHOICES AND LEGAL RIGHTS
At Ergo Global, we ensure that all users have choices regarding their personal information. Regardless of location, we provide the following options for users to manage the privacy of their data:
- Managing Marketing Communications: You have the option to unsubscribe from our marketing newsletter by utilizing the “unsubscribe” link at the bottom of each newsletter and following the provided instructions. Alternatively, you can opt out of all communications by contacting us at [email protected]. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
- Correcting Your Personal Information: To request the correction or update of any personal information we hold about you, please contact us at [email protected].
- Accessing Your Personal Information: You may request a copy of the personal information we maintain about you by contacting us at [email protected].
- Deleting Your Personal Information: You may request the deletion of your personal information by contacting us at [email protected].
- Opting Out from Targeted Advertising. As mentioned earlier, we and our advertising partners may utilize your personal information to deliver targeted advertisements or marketing communications that may be of interest to you. For a comprehensive understanding of how targeted advertising functions, you can refer to the Network Advertising Initiative’s (“NAI”) educational page. You may be able to opt-out of interest based advertising by visiting the NAI Opt-Out Page or the Choices Opt-Out Page (or the Digital Advertising Alliance of Canada Opt-Out Page, if you are based in Canada).
To opt out of targeted advertising of some ad networks, you can use the following links:
- Facebook: https://www.facebook.com/settings/?tab=ads
- Google: https://www.google.com/settings/ads/anonymous
- LinkedIn:https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out
In certain circumstances, residents of specific countries are granted particular rights under applicable data protection laws concerning their personal data. Below is a list of these country-specific rights for the respective residents:
Residents of Europe, including those in the European Economic Area (“EEA”), the United Kingdom (“UK”) (including Gibraltar), and Switzerland
General Data Protection Regulation (Regulation (EU) 2016/679 (“GDPR”), UK Data Protection Act 2018 and Federal Act on Data Protection of 25 September 2020 (known as “FADP”), provide residents of the EEA, UK and Switzerland with the following rights:
- Request access to your personal data.
- Request correction (rectification) of your personal data.
- Request the erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent at any time.
- Right to human intervention and not to be subject to a decision based solely on automated means.
- Right to lodge a complaint with a supervisory authority. The EU residents may find the list of the competent DPSA by the link:
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en, the UK residents may contact the UK Supervisory Authority at
https://ico.org.uk/global/contact-us/, and Swiss residents may contact the Swiss Data Protection and Information Commissioner at
https://www.edoeb.admin.ch/edoeb/en/home/deredoeb/kontakt.html.
If you wish to exercise any of the rights set out above, please contact our Data Protection Officer at the following details:
Ergo Global Limited
Address: Geashill, Ballinlough, Dunshaughlin Co.
Meath, Ireland
Attention: Data Protection Officer
Email: [email protected]
Residents of Canada
Personal Information Protection and Electronic Documents Act, S.C. 2000, also known as “PIPEDA”, entitles residents of Canada with the following rights:
- Request access to your personal data.
- Request correction (rectification) of your personal data.
- Right to withdraw consent at any time.
- Right to lodge a complaint with a supervisory authority (namely, the Office of the Privacy Commissioner of Canada).
To exercise any of the rights set out above, please contact our Data Protection Officer at the following details:
Attention: DPO
Ergo Global Limited
Address: 74, South Bridge Road #02-01, Wong Shee Fun Building
Singapore 058704
Email: [email protected]
California Residents
California Business and Professions Code Section 22575, also known as the California Online Privacy Protection Act (“CalOPPA”), entitles our users who are residents of California to exercise the following rights:
- Request review of your personal data.
- Request changes to your personally identifiable information.
To exercise any of the rights set out above, please contact our Data Protection Officer at the following details:
Attention: DPO
Ergo Global Limited
Address: 74, South Bridge Road #02-01, Wong Shee Fun Building
Singapore 058704
Email: [email protected]
For additional details regarding these rights and their interpretation, please refer to the Glossary.
NO FEE USUALLY REQUIRED
We typically do not impose a fee for processing or responding to user requests unless exceptional circumstances warrant such charges. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. If we are unable to fulfill a request, an explanation for the refusal will be provided.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us verify your identity and ensure your right to access your personal data (or exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within 1 (one) month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. GLOSSARY
Non-Identifying Information means any information whose disclosure, alone or in combination with other information, does not reveal the identity of the user to whom it relates.
YOUR LEGAL RIGHTS
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction (rectification) of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data’s accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right to human intervention and not to be subject to a decision based solely on automated means, including profiling, if the decision produces legal effects concerning you or significantly affects you in a similar way.
Lodge a complaint with a supervisory authority in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the applicable law.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent means the processing of your personal data where you have explicitly agreed to such processing for one or more specific purposes outlined in this Privacy Policy. For example, this may include the processing of your personal information for our own or third parties’ marketing purposes.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Ergo Global Group and its affiliates.
EXTERNAL THIRD PARTIES
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
- Regulators and other authorities based in Singapore, EEA, UK, Switzerland or other countries who require reporting of processing activities in certain circumstances.
- Market researchers and web and mobile analytics who provide web, mobile and market analytics services such as Google Analytics and Smartlook.
- Price comparison sites that provide price comparison services.
- Virtual assistance and customer support service providers who provide customer support services such as HubSpot.
- Service providers that offer various services related to our Website and Services. For more details about the full list of the service providers we use, please refer to the table below.
- Ad servers and network advertisers that serve our advertisements on other websites, within mobile apps and elsewhere online and provide us with information regarding the use of the Services and the effectiveness of our advertisements, such as Google, LinkedIn, Facebook, and others. Such ad servers and network advertisers may collect certain information about your visits to and activity on the Website as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. We may also share certain Non-Identifying Information with these parties in connection with the services they provide to us.
Service Provider |
Processing Purpose |
Location |
Legal Basis of Data Transfer |
Link to Privacy Policy |
Amazon Web Services, Inc. Address: 2021 7TH Ave Seattle, Washington 98121-2601 Attn: Greg Luloff Associate General Counsel, Privacy Amazon.com, Inc. Phone: (206) 266-1000 |
To host users’ data securely within the cloud provider. To manage user registration and the account and to facilitate access to and use of the Website. To administer and protect our business, to resolve disputes or troubleshoot problems, and to prevent potentially prohibited or illegal activities. |
European Economic Area United States |
EU-U.S. Data Privacy Framework (“DPF”) Swiss-U.S. DPF UK Extension to the EU-U.S. DPF https://www.dataprivacyframework.gov/list
|
|
MongoDB, Inc. Attn: DPO [email protected] Phone: 1-866-692-1371 |
To host users’ data securely within the cloud provider. |
European Economic Area United States |
EU-U.S. Data Privacy Framework (“DPF”) Swiss-U.S. DPF UK Extension to the EU-U.S. DPF |
|
Cloudflare, Inc. Address: 101 Townsend St. San Francisco, CA 94107 Attention: Data Protection Officer
|
To increase the performance, security, and availability of our Website |
European Economic Area United States |
EU-U.S. Data Privacy Framework (“DPF”) Swiss-U.S. DPF UK Extension to the EU-U.S. DPF |
|
HubSpot, Inc. Address: 25 1ST St Ste 200 Cambridge, MA 02141 Attn: Nicholas Knoop Director, Senior Corporate Counsel Email: [email protected] |
To provide customer support services – communicate with users through the integrated Website chatbot functionality |
European Economic Area United States |
EU-U.S. Data Privacy Framework (“DPF”) Swiss-U.S. DPF UK Extension to the EU-U.S. DPF |
|
Google LLC Address: 1600 Amphitheatre Parkway Mountain View, California 94043 Attn: Chief Privacy Officer Google Data Protection Office |
To measure interest in and improve our products and Services and to customize user experiences through an analytics services provider used for behavioral analytics. To deliver personalized ads tailored to user preferences and interests |
United States |
EU-U.S. Data Privacy Framework (“DPF”) Swiss-U.S. DPF UK Extension to the EU-U.S. DPF |
|
The Rocket Science Group LLC d/b/a Mailchimp Address: 2700 Coast Avenue Mountain View, CA 94043 Attn: Liza Schmitt Sr. Program Manager – Global Privacy Program Email: [email protected] |
To manage your marketing email subscription deliver our marketing newsletter and promotional offers to you |
United States European Economic Area |
EU-U.S. Data Privacy Framework (“DPF”) Swiss-U.S. DPF UK Extension to the EU-U.S. DPF |
|
Smartlook, s.r.o.
Address: Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic, EU DPO: [email protected] |
To analyze user behavior and get insights into how users use navigate our website |
European Economic Area |
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
13. COMPANY GROUP STRUCTURE
No. | Entity | Registration Details |
1 | Ergo Global Pte. Ltd. | Registration number 201838625E and registered office address at 74, South Bridge Road #02-01 Wong Shee Fun Building, Singapore 058704, doing business as Ergo Global. |
2 | Ergo Global Limited | Registration number 671620 and registered office address at Geashill, Ballinlough, Dunshaughlin Co. Meath, Dunshaughlin, Meath. |