Privacy Policy

This Privacy Policy sets out the basis on which KOL Radar and related companies may collect, use, disclose or otherwise process your personal data when you use our website at https://www.kolradar.com/, our mobile applications, or otherwise use any of our Services in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”). This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes. 

This Privacy Policy is read in conjunction with and is deemed incorporated by reference into the Terms of Service. Except as otherwise provided herein, all capitalized terms shall have the same meaning as defined in the Terms of Service. Our affiliates that are involved in providing the Services are each referred to as an “Affiliate”. KOL Radar and Affiliates are collectively referred to as the “KOL Radar Group”.

If you do not agree to this Privacy Policy and our Terms of Service, please do not use any of the Platforms. Your continued use of our website, mobile applications and Services constitutes your acknowledgement and acceptance of this Privacy Policy.

1. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

We collect and use personal information about you when you use the Service, interact with us, request products or services directly from us, contact us directly with respect to any queries, participate in or opt out of any of our marketing promotions, or otherwise communicate with us.

The personal information we collect include:

1. your basic personal details, including your name, age, date of birth, registration ID (which is your email address) and gender;
2. further personal details, including your identity card/document, occupation, preferences, interests, information about your firm/employers), education and training details (including qualification, attendance at educational establishments and training received), professional and employment details, background check and public records information, job preference information,  personal data which is of sensitive in nature such as physical or mental health or medical condition, religious beliefs or other beliefs of a similar nature, the commission or alleged commission of any offence as well as any other information you provide in connection with your submission or application
3. contact information, including your address, phone number, email, or other information that permits us to contact you; and
4. technical information, including:
   1. information about the device you use to interact with us and our services (including IP address, geographical location, device type and model, screen resolution, app version, device language, device identification codes and other features/data that can be used to identify a device); and
   2. information from your visits to our websites or mobile applications (including browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term you use, device logs in the event of a crash or error report, unique identifiers saved in cookies and information associated with a cookie which is necessary to provide the services you have requested or which helps us measure and improve our sites).

2. HOW WE OBTAIN YOUR PERSONAL INFORMATION

We collect personal information about you in connection with the Services. For example, we collect your personal information when you browse our website, use our mobile applications, enquire about or register to use any of the Services, sign a contract with us, sign up to receive messages from us, or when you communicate with us via e-mail, phone, SMS, or any other electronic means. 

We also receive personal information about you from other sources, including:

1. the Services;
2. Affiliates;
3. suppliers providing services on our behalf;
4. third parties for purposes required by law; and
5. publicly available sources. 

We may combine information that we have about you from various sources, including the information you have provided to us. 

As you use our Services, website or mobile applications, certain information may also be passively collected:

1. Site Activity Information: We may keep track of some of the actions you take on our website or mobile applications, such as the content of searches you perform;
2. Access Device and Browser Information: When you access our website from a computer or other device, we may collect anonymous information from that device, such as your Internet protocol address, browser type, connection speed and access times;
3. Cookies (i.e. small pieces of information that a site sends to your browser while you are viewing a website): We may use both session cookies (which expire once you close your web browser) and persistent cookies to make our website and Services easier to use, to make our advertising better, and to protect both you and KOL Radar. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to stay logged in to our website; 
4. Device information: We may also collect non-personal information from your mobile device or computer. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the application(s) and information about the type of device or computer you use. In addition, in the event our application(s) crashes on your mobile device we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our application(s); 
5. Web Analytics: We may use third-party web analytics tools to help analyse how users use our website. Such tools may use cookies to collect information such as how often users visit our website, what pages they visit, and what other sites they used prior to coming to our website. We use the information we get from the web analytics tools to improve our website and Services. 

3. HOW WE USE YOUR PERSONAL INFORMATION

We use the information we collect to operate our business, including the Services. For example, we use your personal information for the following purposes:

1. for the exercise of rights and performance of obligations under, and managing compliance with, our KOL Radar rules and related documentation; 
2. to respond to your queries, feedback, claims or disputes (including resolving payment disputes) or otherwise provide customer support and services;
3. for research, statistical analysis, analytics, business planning and business intelligence purposes in order to understand how users like you perceive our products and services, industry trends, usage patterns and other factors that may affect our business;
4. to contact you in relation to our provision of Services, contact you in connection with any communication preferences or requests you have expressed, ask you for feedback about Services or other related products and services, collect feedback from you and your staff about our products and services and use such feedback to improve our business and/or customize products and services; send you information about products and services, including for promotional purposes, present you with offers or promotions; and contact you for legal purposes;
5. to operate marketing and advertising activities, including promotional events;
6. to manage our business, including billing, invoicing, account management, reconciliation, collection, audit purposes and internal reporting;
7. for the establishment, exercise or defense of legal claims, for the purposes of legal proceedings, for compliance, regulatory and investigative purposes;
8. for security, authentication and risk control purposes, including to manage anti-money laundering and fraud risk, to perform creditworthiness and solvency checks, to assess, detect, investigate, prevent, remediate or report data breaches, fraud, other potentially prohibited or illegal activities and violations of our agreements and policies, industry standards, guidelines, laws and regulations, to protect the integrity and maintain the security of our services, products and platforms, to protect our rights or property and those of others and to prevent any harm or financial loss to us or others;
9. to make disclosures as may be required by any rules, law, regulation, subpoena, court order, other legal process or contractual or commercial requirements, including to regulatory authorities, government officials, courts, card associations or other payment schemes. Such requirements may relate to “know your customer” checks, anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes;
10. for any proposed or actual merger, acquisition, corporate reorganization, financing, sale joint venture, assignment, transfer, disposition or similar transaction, including the sale of business, assets or stock;
11. to transmit to the KOL Radar Group or any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; 
12. otherwise for everyday business purposes, to comply with law, or in other ways for which we provide specific notice at the time of collection.

4. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We share your personal information to operate and manage our business, including for the purposes indicated under How We Use Your Personal Information. Thus, for example, we may share your information with:

1. third party service providers elected by you;
2. third parties where you have instructed us to share information with them;
3. Affiliates;
4. any agent, contractor or third party service provider that we work with in providing Services. For example, we may work with third parties to help us with fraud prevention, anti-money laundering checks, data entry, database management, promotions, marketing, customer service, technology services, products and services alerts;
5. law enforcement agencies, insurers, government and regulatory or supervisory authorities and any other organizations to which KOL Radar, or any Affiliate or third party service provider, is under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement;
6. parties relevant to litigation proceedings and the assessment of claims or disputes, including courts;
7. individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and
8. our own and others’ professional advisors (e.g., lawyers, accountants, auditors, and trustees).

5. HOW DO WE STORE AND PROTECT YOUR PERSONAL INFORMATION?

We will only retain your information for as long as is necessary for providing Services to you and will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes. 

We use a variety of security measures and technologies designed to help protect your personal information from loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction. In some cases, we use the widely accepted 256-bit SSL encryption mechanism to ensure the secure transmission of your Personal Data. Personal Data /information collected through KOL Radar will be stored on servers located in Republic of China (Taiwan). 

6. HOW DO WE PROCESS PERSONAL INFORMATION ABOUT CHILDREN?

Our service is not directed towards children under 18 years old, nor does KOL Radar knowingly collect information from children under 18. If you are under 18, please do not use Services or submit any personal information to us.

If you, acting as a guardian of a child, have relevant questions in respect of a child’s personal information, please contact us using the details set out in the Contact Us section below.

7. THIRD PARTY SERVICES AND SITES

We may provide links to third party websites and services for your convenience and information. These services and websites may operate independently from us. Linked services and websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked services and websites. To the extent any linked websites and services you visit are not owned or controlled by us, we are not responsible for (i) these websites’ or services content, (ii) any use of these services or websites by you, or (iii) the privacy practices of these services or websites.

8. WHAT IS OUR LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION?

In accordance with applicable data protection and privacy laws and regulations, we may use your personal information on bases set out below.

1. For the performance of any contracts to which you are a party;
2. To comply with legal and regulatory obligations;
3. With your consent – for example when you give consent to our using cookies in order to measure and improve our sites;
4. For legitimate interests:

1. 1. to operate and improve our business and minimise any disruption to the Services that we offer to you;
   2. to send you service-related communications and marketing/promotional communications and make these communications with you more relevant and personalised to you;
   3. to make your experience of our products and services efficient and effective;
   4. to transfer your personal information internationally in order to accommodate our technical infrastructure and as part of our business structure, including as a result of laws and regulations applicable to us and other Affiliates and legal claims or proceedings that involve us or other Affiliates; and
   5. for other purposes including those set out in How We Use Your Personal Information.

However, in cases in which we wish to use your data for our legitimate business purposes, we carefully consider the position and do not proceed if we think your interests or fundamental rights and freedoms relating to your personal information would be prejudiced. Examples of matters we consider include how we use your data responsibly (for instance, security measures we put in place to protect it, such as access controls).

9. DATA TRANSFERS

We are a global business and your information may be processed outside of the country where you live. Regardless of where your information is processed, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection and privacy laws and regulations, or a standard of protection that is at least comparable to that provided under the PDPA.

10. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:

1. ask us about the processing of your personal information, including to request a copy of your personal information;
2. request the correction and/or (in some cases) deletion of your personal information;
3. in some cases, request the restriction of the processing of your personal information, or object to that processing;
4. withdraw your consent to the processing of your personal information (where KOL Radar is processing your personal information based on your consent);
5. request receipt or transmission to another organization, in a machine-readable form, of the personal information that you have provided to KOL Radar where we are using your personal information based on consent or performance of a contract; and
6. complain to the relevant supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information.  Where you are given the option to share your personal information with us, you can always choose not to do so. If we have requested your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.

However, choosing not to share your personal information with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described (See How We Use Your Personal Information) or that you are unable to make use of the services and products offered by us. Please note that withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

If you would like to (b) access a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. Such request shall include the details of the requestor, description of the personal data being requested and the date and time range the personal data was believed to be collected. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

If you would like to withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

If you would like to exercise any other right, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below . 

11. CONTACT US

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, by email via kolradar@ikala.ai.

As required under applicable law, please note that we may take steps to ask you to provide further information to verify your identity before granting you access to information or acting on your request to exercise your rights.

12. CHANGES TO THIS PRIVACY POLICY

We may change, amend or revise this Privacy Policy from time to time. We will notify you of any substantive or material change in this Privacy Policy by updating this web page, sending push notifications, e-mails or letters, by phone or by publishing announcements on our website. You can also review this Privacy Policy at the home page of our website.

13. MISCELLANEOUS 

Neither the KOL Radar Group nor any providers of Services under this Privacy Policy shall be liable for delay in performing obligations or for failure to perform obligations under this Privacy Policy if the delay or failure resulted from events, causes and circumstances beyond its reasonable control, including but not limited to, acts of God, governmental acts (including directives issued by regulators and amendments to legislation), shut down or failure of telecommunications facilities or networks, failures or acts of application distributors, failure of information technology or telecommunications equipment or facilities, hacker attacks, denial of service attacks, virus or other malicious software attacks or infections, power failures, epidemics, flood, fire, explosion, accident, civil commotion, industrial dispute, or impossibility of obtaining materials.

The illegality, invalidity or unenforceability of any provision of this Privacy Policy under the law of any jurisdiction shall not affect its legality, validity or enforceability under the law of any other jurisdiction nor the legality, validity or enforceability of any other provision.

Save for the related companies of the KOL Radar Group, partners of the KOL Radar Group and as expressly provided in this Privacy Policy, a person who is not a party to this this Privacy Policy shall have no right to enforce or enjoy the benefit of any term of this this Privacy Policy under the Contracts (Rights of Third Parties) Act 2001 of Singapore. Notwithstanding any term of this this Privacy Policy, the consent of any person who is not a party to this this Privacy Policy is not required to rescind or vary this this Privacy Policy at any time.

This Privacy Policy shall be governed by, and construed in accordance with, the laws of Singapore. The Parties shall attempt in good faith to resolve promptly any dispute arising out of or in connection with this Privacy Policy through amicable negotiations (which shall be commenced by either party giving written notice to the other).  In the event that such dispute cannot be resolved by amicable negotiations within thirty (30) days of either party giving written notice to the other party that a dispute has arisen, the dispute shall be submitted by either party for resolution by the courts of Singapore which courts shall have exclusive jurisdiction.

Last updated on July 30, 2024.