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PRIVACY AND DATA PROTECTION NOTICE

 

This Data Protection Notice (“Notice”) sets out the basis upon which Taproot LLP (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of Content Creators in accordance with the Personal Data Protection Act (“PDPA”). This 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.

 

APPLICATION OF THIS NOTICE

1.  This Notice applies to all who:

 

1.1    Sign Up their interests to be our Content Creators through the Influencer Sign Up Form (“Sign Up”);

1.2    Content Creators engaged in a contract of service (whether paid and not paid) with us (“Campaign Agreement”) through the Media Invitation Registration Form(s);

1.3    Subscribe to our newsletter;

1.4    Enter contests, promotions or surveys that we conduct from time to time;

1.5    Give us feedback or make enquiries;

1.6    Use mobile, social media pages, or web applications developed and/or managed by us, our partners, and/or clients;

1.7    Register for our events and/or when you visit our website;

1.8    Personal data is provide to us through third-party sources, including business partners, advertising and social media companies, and vendors; and through other data collection points;

1.9    Participate in any activities organised by us, in your feedback or participation in surveys, market research and/or analysis for statistical, profiling, trend analysis or other purposes to enable us to customise, review, improvise and develop our and/or our clients’ products and services, to understand market trends and any other purpose that we may notify you of at the time of obtaining your consent; and

1.10   Are photographed or filmed through the use of cameras, mobile devices, closed-circuit television systems or other surveillance devices and systems at our client(s)’ premises.

PERSONAL DATA

2.  As used in this Notice, “personal data” means data, whether true or not, about a Content Creator who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

 

3.  Depending on the nature of your interaction with us, personal data which we may collect in the context of your engagement with us includes, without limitation, your:

 

3.1    Name or alias, gender, date of birth, nationality, and country of residence;

3.2    Your preference information such as activities, food and beverage preferences, dietary information, and special requests;

3.3    Instagram Handler and social media account(s)’ name;

3.4    Photos in your Instagram and/or social media post for the Campaign and for purpose of re-sharing in Taproot and/or our clients’ social media and websites;

3.5    Mailing address, telephone numbers, email address and other contact details; and

3.6    Bank account details.

4.  Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

5.  We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your Sign Up and/or Campaign Agreement with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

 

6.  We may collect and use your personal data for any or all of the following purposes:

 

6.1    Performing obligations under or in connection with your Sign Up and/or Campaign Agreement with us, including processing payment of remuneration or credit transactions;

6.2    Performing obligations in the course of or in connection with our provision of the Sponsored Products and/or services requested by you;

6.3    Performing obligations under or in connection with the provision of our goods or services to our clients;

6.4    Verifying your identity and assessing and evaluating your suitability for taking part in our Campaign (Campaign means assignment(s) that Taproot offers to Content Creator to create Post or Sponsored Post for Client through Sponsored Products or Payment) or continued as our Content Creator;

6.5    Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

6.6    Managing your relationship with us;

6.7    Ensuring business continuity for our organisation in the event that your Sign Up and/or Campaign Agreement with us is or will be terminated;

6.8    To conduct sales and marketing to our potential clients and/or clients including to present or send our clients your Instagram and social media profile and engagement statistics, Instagram and social media posts’ content and photos; and

6.9     Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and

6.10   Any other purposes for which you have provided the information;

 

7.    In addition to the personal information you provide to us directly, we may obtain from other sources additional personal information about you, including:

7.1    Friends and family-provided information such as information that your friends or family provide to us about you in connection with your participation in our Campaign and/or events;

7.2    Publicly available information such as name, contact information, Instagram handler and social media profile, Instagram Post and engagement statistics, social media profile(s)’ engagement statistics, content and online activity that we obtain from publicly available sources (such as public databases), and social media platforms you interact with;

7.3    Device information such as geolocation data and other location information derived from your IP address, country, and zip code;

7.4    Data collected by cookies and similar technologies such as information about your online activities, devices, browsing actions, and usage patterns across our website, social media, and third-party websites that we obtain through the use of cookies, web beacons, and similar technologies;

7.5    Video, audio and other sensory information such as images, video, audio, thermal, and olfactory data that may be collected or processed through ours and/or our clients’ security cameras, closed-circuit television, recorded phone lines, voice recorders, and other technologies, where permitted by law; and

7.6    Data from third-party sources such as personal information we obtain from our third-party service providers, partners, and marketing partners;

8.    We may disclose your personal data:

 

8.1    Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;

8.2    Where such disclosure to our clients is required for performing obligations under or in connection with the provision of our goods or services to our clients;

8.3    For data analytics purposes including to maintain and improve our products and services, and to analyse your Instagram and social media post’s engagement;

8.4    To third party service providers, agents and other organisations we and/or our clients have engaged to perform any of the functions in the Campaign Agreement, Sign Up, and with reference to the above mentioned purposes;

8.5   To our client for the purpose of re-sharing photos and content in your Instagram and/or social media post for the Campaign in Taproot and/or our clients’ social media and websites;

8.6    To conduct sales and marketing to our potential clients and/or clients including to present or send our clients your Instagram and social media profile and engagement statistics, Instagram and social media posts’ content and photos; and

8.7    To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

9.    The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to the Sign Up and/or Campaign Agreement) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under the Sign Up and/or Campaign Agreement with you).

 

10.   The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

11.   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.

 

ACCESS TO AND CORRECTION OF PERSONAL DATA

12.   If you wish to make (a) an access request for access to 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) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

13.   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.

14.   We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your access 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).

15.   Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

 

PROTECTION OF PERSONAL DATA

16.   To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, and authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.).

17.   You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

ACCURACY OF PERSONAL DATA

18.   We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

 

RETENTION OF PERSONAL DATA

19.   We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

 

20.   We 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.

 

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

21.   We may transfer the personal information we collect about you to countries where our service providers are located eg: the U.S, and Singapore, and other countries outside of the country in which the information originally was collected, including the jurisdictions in which our service providers operate. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Privacy and Data Protection Notice and in accordance with applicable law.

 

DATA PROTECTION OFFICER

22.   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, in the following manner:

 

Attention to: Data Protection Officer

Email Address: contact@taproot.page

Address: 1 Irving Place, The Commerze @ Irving #08-01, Singapore 369546

 

EFFECT OF NOTICE AND CHANGES TO NOTICE

23.   This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

24.   We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services, and/or engagement in our Campaign, constitutes your acknowledgement and acceptance of such changes.

 

 

Effective date    :             21/06/2021

Last updated     :             21/06/2021

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