Welcome to The Prop Game! Data protection and data security when using our Platform are very important to us. We would therefore like to inform you which of your personal data we collect when you visit our Platform and for what purposes it is used.
BACKGROUND
This Privacy Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to make sure you understand the information provided. However, to achieve this objective we would like to explain to you the following concepts.
- What is Personal Data?
Personal Data is any includes information relating to an individual who can be identified or who is identifiable, directly from the information in question; or who can be indirectly identified from that information in combination with other information.
- What is Special Category Data?
Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing
- What is Processing?
“Processing” means and covers virtually any handling of data.
WHAT LAW APPLIES
We will only use your Personal Data in accordance with the applicable data protection laws, in particular Singapore’s Personal Data Protection Act 2012 (“PDPA”), the UK’s Data Protection Act (“DPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.
WHO IS RESPONSIBLE
The Data Controller is Garuda Education and Training Pte Ltd., UEN: 202342938C, of 60 Paya Lebar Road, #07-54, Paya Lebar Square, Singapore 409051 (“The Prop Game”, “we”, “us”, or “our”). Please direct any questions you may have to support@thepropgame.com.
DATA COLLECTION
All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:
- you have given your consent;
- the data is necessary for the fulfilment of a contract / pre-contractual measures;
- the data is necessary for the fulfilment of a legal obligation; or
- the data is necessary to protect the legitimate interests of our company and business.
DATA RETENTION
We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with Singapore’s Commercial Law and Fiscal Code and others for up to 8 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.
DATA WE COLLECT
- Provision and use of the Platform
When you visit our Platform, we collect the Personal Data that your browser automatically transmits to our server. This is technically necessary for us to display our Platform and to ensure its stability and security. In this sense, we collect the following data: i) IP address of the requesting computer, ii) Date and time of access, iii) name and URL of the file accessed, iv) website from which the access was made (referrer URL), v) browser used and, if applicable, the operating system of your device as well as the name of your access provider. The legal basis is our legitimate interest.
- Hosting
The hosting services used by us for the purpose of operating our website is Google LLC Google Cloud (UK London location), and in relation to our client area and portal 1&1 IONOS SE (US location), which is supported using the services of Monitor Line Ltd. In doing so the foregoing processes inventory data, contact data, content data, usage data, meta data and communication data of customers, interested parties and visitors of our Platform, on the basis of our legitimate interests.
- Content Management and eCommerce System
We use the Content Management System of WordPress by Automattic Inc and eCommerce System of WooCommerce by Automattic Inc to publish and maintain the created and edited content and texts on our Platform. This means that all content and texts submitted to our Platform are transferred to Automattic. The legal basis for this processing is our legitimate interest.
- Fonts
We integrate Google Fonts by Google LLC, and Font Awesome of Fonticons Inc. To enable the display of fonts, a connection to Google’s and Font Awesome’s server is established when our website is accessed. This enables Google, and Fonticons to determine which website sent the request and to which IP address the display of the font is to be transmitted. The integration is based on our legitimate interest.
- reCAPTCHA
We also use Google`s reCAPTCHA from Google LLC to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyses the behaviour of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.
- Cookies
We use so-called cookies on our Platform. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the PDPA, the UK`s Privacy and Electronic Communications Regulations (“PECR”) and the EU`s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of Non-essential Cookies. For further information on the cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.
- Cookie consent
Our Platform uses a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our Platform, the following Personal Data is transferred to us: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our Platform. The basis for processing is our legitimate interest and your consent.
- Economic analyses and market research
For business reasons, we analyse the data we have on web and server traffic patterns, website interactions, browsing behaviour etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarised and or anonymized values. For this purpose we use Google Analytics, SourceBuster JS and MonsterInsights. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.
- Contacting Us
We offer you the opportunity to contact us using various methods. We collect the data you submit such as your name, email address, telephone number and your message in order to process your enquiry and respond to you. The legal basis is both your consent and contract.
For the Chat, we use the Brevo Conversations Live Chat of the company Brevo (Formerly Sendinblue) tawk.to, Inc, on our website. Brevo Live Chat uses cookies to enable you to personalise your online experience. We have no knowledge of the storage period at tawk.to and no possibility to influence it.
We also offer to contact us via the messaging services of WhatsApp. If you contact us via WhatsApp we store and use the mobile phone number, you use and – if provided – your first and last name in accordance with the provision of a contractual or pre-contractual measure to process and respond to your request. The legal basis is both your consent and contract.
- Providing our services
The protection of your data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfil our contractual obligations to you or to carry out pre-contractual measures.
- Registration
If you register, we will request mandatory and, where applicable, non-mandatory data in accordance with our registration form including your name and email address. The entry of your data is encrypted so that third parties cannot read your data when it is entered. Your data will remain stored for as long as the registration lasts, in particular if the storage is necessary for the fulfilment/execution of the contract, to enforce our rights or for our other legitimate interests or we are required by law to retain your data (e.g., within the framework of tax retention periods).
- Profile
As a registered user, you have the opportunity to create a user profile with just a few clicks and details and the relevant profile data you provide will be posted on your profile. Of course, you can change the information at any time via the settings in your profile. You have choices about the information on your profile. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add Personal Data to your profile that you would not want to be available. The legal basis for the processing of your Personal Data is the establishment and implementation of the user contract for the use of our Platform.
- Using our Platform
If you wish to use our Platform and its features, we process the Personal Data you voluntarily provide for the purpose of providing our Platform. Depending on how you use our services, we need certain data to allow you to participate in our Services. In turn we may process:
- User Data: full name, address, country of residence, email address, password, telephone number, government identity, country of residence, location in connection with identity verification.
- Transaction Data; which includes details about payments earnings, pay-out requests, payments made; details about payments to and from you and us and other details of products and services you have purchased.
- Financial information; such as billing address, bank account information, pay-out country, corporate or business entity if any for tax purposes. (Please Note: we have no access to any Payment Data you may submit)
- Anti Money laundering and risk management. We also process customer and prospect data for risk evaluation, AML and risk management purposes. This processing is carried out on the legal basis of our legitimate interest, and our legal obligations and serves our interest in further developing our services, to carry out our services lawfully and informing you specifically about our services. Further data processing may take place if you have consented or if this serves the fulfilment of a legal obligation such as adherence to AML Obligations. Data process may include:
- Identity verification information, such as an image of your government issued ID, passport, national ID card or driving licence, and under special conditions also a social security number.
- Residence verification information, such as utility bill details, phone bill or similar document.
Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your racial or ethnic origins, sexual orientation, sexual preferences and gender. By choosing to provide this data, you consent to our processing of that data. You have choices about the data you provide and how you share it. You don’t have to provide Personal Data or Special Category Data. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available. The legal basis for the processing of your Personal Data and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent.
Finally and if you are providing us with Personal Data relating to a third party, you agree a) that you have in place all necessary appropriate consents and b) that such third party has read this Privacy Policy. You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising from your non-compliance with these requirements.
- Affiliate Registration
Affiliate Registration requires some Personal Data and the acceptance of our Affiliate Program Terms. The following information is collected and stored by us : User Name, First Name, Last Name, Email, Password. Full registration is necessary to use our Affiliate services. The processing of your Personal Data is based on your consent.
- Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose including improving our Platform and Services. 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. 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.
- Administration, financial accounting, office organisation, contact management
We process data in the context of administrative tasks as well as organisation of our business, and compliance with legal obligations, such as archiving, internal data management using Microsoft Office and Google Docs and Cloud Services or AML verification using the service of Veriff. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.
- Payment Data
Payment Data will be processed via the payment service providers Stripe for Card Payments and Triple A Technologies Inc, Forum Pay for crypto payments, and Credit Card payment will solely be processed through the payment system of Stripe and Crypto through Forum Pay. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.
- Service Reviews
We use the rating functions of Trustpilot to constantly improve our service, we offer our customers the opportunity to rate us via an independent portal, without us being able to influence this in any way. For this purpose, some data is transmitted to Trustpilot. The integration is based on our legitimate interest, and we have no influence or control over the data collected and processed by Trustpilot.
- Forms
To provide our forms we are using Google Forms by Google LLC. All entries made by you will be processed on Google’s servers. Google Forms stores a cookie in your browser that contains a unique ID. Google Forms is used on the basis of our legitimate interest and your consent. The data you enter in the form will remain with us until you request us to delete it or revoke your consent to store it or the purpose for storing the data no longer applies.
- Customer Communications and Mailings
For customer communications and mailings, we use the communication services of Brevo, (formerly Sendinblue). Brevo provides cloud-based communication service for marketing and Brevo may collect and process information such as your email address. This data processing is based on our legitimate interest.
- Promotional use of your data
We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.
- Our Community
We process the Personal Data that arises when you use our community services. In particular, this requires you to join our server and community on Discord. If you contact or connect with us via Discord, we and Discord are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a membership, if any.
ADVERTISING
We would like to show you interesting advertising outside of our Platform and use various third-party tools and cookies for this purpose. These collect and process information about your activities on our Platform – for example, which products you are interested in or which pages you visit. By knowing what you are looking for and how you use our Platform, we can adapt our advertising to your needs. And thus increase the likelihood that you will also be shown suitable and interesting advertising outside our Platform.
We also analyse this data to evaluate the relevance of the advertisements and to optimise the advertisements for you. Through the tools, your browser regularly establishes a connection to the server of the tool provider when you visit our Platform. For some tools, we have no direct influence on what data is processed by the providers. The following personal data may be processed by third-party providers i) HTTP header information (e.g., IP address, web browser, website URL, date and time); ii) measuring pixel-specific data (e.g., pixel ID and cookie ID); and iii) additional information about visits to our Platform (e.g., orders placed, products clicked on). The legal bases for processing are our legitimate interest and your consent in case of cookies.
MARKETING
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.
You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.
Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.
SOCIAL MEDIA
- a) General
We are present on social media on the basis of our legitimate interest (currently Facebook and Instagram, YouTube (Google LLC), TikTok, X (formerly Twitter), and Telegram).. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Information collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.
- b) Market research and advertising
In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behaviour and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.
- c) When you visit our profiles and interact with us and others
When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Information from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.
DATA SHARING
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.
- Internal
If necessary, we transfer your Personal Data within The Prop Game. Of course, we ensure that your data is processed properly. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.
- External bodies
Personal Data is transferred to our service providers in the following instances:
- in the context of fulfilling our contract with you,
- to use marketing services and to advertise our services online,
- to communicate with you,
- to provide our Platform, and
- to state authorities and institutions as far as this is required or necessary.
- International transfers
We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.
DATA SECURITY
Our Platform uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our Platform.
Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.
YOUR RIGHTS AND PRIVILEGES
- Privacy rights
You can exercise the following rights under the PDPA:
- Right to access
- Right to correction
- Right to erasure
- Right to opt-out
- Right to data portability
You can exercise the following rights under the GDPR and the UK’s DPA:
- Right to information
- Right to rectification
- Right to object to processing
- Right to deletion
- Right to data portability
- Right to withdraw consent
- Right to complain to a supervisory authority
- Right not to be subject to a decision based solely on automated processing.
If you wish to exercise any of your rights, please contact us.
- Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.
- Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when 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 will tell you why.
- Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority. The supervisory authority in Singapore is the Personal Data Protection Commission (www.pdpc.gov.sg).
- What we do not do
- We do not request Personal Data from minors and children;
- We do not process special category data without obtaining prior specific consent;
- We do not use Automated decision-making including profiling; and
- We do not sell your Personal Data.
- Singapore Spam Control Act 2007(SCA)
The SCA is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with SCA, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.
- 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. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalised. As such, our Platform does 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 policy.
VALIDITY AND QUESTIONS
This Privacy Policy was last updated on Friday, 24th of May 2024, and is the current and valid version. However, from time to time changes or a revision to this policy may be necessary. If you feel that the above is not sufficient or if you have any queries as regards the collection, processing or use of your information we are looking forward to hearing from you. We will make every effort to reply as soon as possible and take into consideration any suggestions from your end.
