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Privacy Policy

Effective date: January 29, 2019

Miiror Pte. Ltd. (“Miiror”, “us“, “we“, or “our“) operates the https://www.miiror.com website and the Miiror mobile application (the “Service“).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We will comply with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (the “PDPA”) and other applicable data protection and privacy laws, such as the European Union General Data Protection Regulation (the “GDPR”).

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

We value our User’s privacy and inform in accordance with the Articles 12, 13 and 21 of the European General Data Protection Regulation (GDPR):

Controller

Company Name: Miiror Pte Ltd.

Address Treasure Place, 61 Lorong Sarhad, #01-01, Singapore 119174

Email: [email protected]

Date Protection Officer

Contact details of our data protection officer:

Address: Treasure Place, 61 Lorong Sarhad, #01-01, Singapore 119174

Email: [email protected]

 

Information Collection And Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Full name
  • Gender
  • Current occupation and employment history
  • Academic and professional qualifications
  • Email address
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

In addition, the definition of personal data under the GDPR may be wider than that under the PDPA or other privacy laws, and includes sensitive personal information, such as your race, ethnicity, religion and any medical condition you may have. We do not require you to specify sensitive personal information (such as your race, ethnicity or religion) in your profile or resume and make this sensitive personal information publicly available.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Miiror uses the collected data for various purposes:

  • To provide and maintain the Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer care and support
  • To provide analysis or valuable information so that we can improve the Service
  • To monitor the usage of the Service
  • To detect, prevent and address technical issues
  • To personalise the content you see on our Services
  • To keep the Services safe and secure
  • To aggregate your and other customer’s User Information into anonymised statistical data, which we will use for statistical analysis so that we can better understand Users’ profile and improve service offering
  • To customise our marketing. You may choose to notify us to stop sending you targeted or customized marketing materials

If you are an EU resident, we are required to disclose the legal basis for processing your Personal Data under the GDPR. We process your Personal Data for these purposes on the following legal basis:

  • the processing is necessary for the performance of the contract of providing the Services to you or in order to take steps at your request prior to entering into a contract pursuant to Art 6 para 1 lit. b GDPR;
  • to protect our legitimate interests pursuant to Art. 6 para. 1 lit. f GDPR in order to make our services available to you. Our legitimate interest is to offer you an appealing, technically functioning and user-friendly app and to answer your inquiries appropriately.

We also process your Personal Data in individual cases for direct marketing purposes. If you do not wish to receive advertising, you have the right to object to it at any time; this also applies to profiling, insofar as it is associated with such direct advertising. We will take this contradiction into account in the future.

We will no longer process your data for direct marketing purposes if you object to the processing for these purposes. If you do not want to receive direct marketing messages from us, you can send an email request to be removed or unsubscribed at any time by emailing to: [email protected].

Transfer Of Data

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside Singapore and choose to provide information to us, please note that we transfer the data, including Personal Data, to Singapore and process it there.

If you are an EU resident, and if we do store any of your data in the European Economic Area (“EEA”), when we transfer the data outside the EEA, this is done either on the basis that it is necessary for the performance of the services provided to you by the Company, or that the transfer is subject to the European Commission’s model contracts for the transfer of personal data to third countries, pursuant to Art.44-46 GDPR.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Miiror will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Please note that if Miiror is acquired or merged with another company, your Personal Data may be transferred to the new owners so that we may continue to provide you with the Services.

Disclosure Of Data

Legal Requirements

In general, Miiror will not disclose your Personal Data, except when you consented to such disclosure or if the disclosure is required so by law and such action is necessary to:

  • To comply with a legal obligation or assist government enforcement agencies
  • To protect and defend the rights or property of Miiror or our Users.
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security Of Data

The security of your data is important to us, and we will be making reasonable and practical security arrangements to protect the User’s Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar. Unfortunately, however no method of transmission over the Internet, or method of electronic storage can be guaranteed to be absolutely secure.

The User agrees and acknowledges that the above-mentioned measures do not guarantee absolute protection and by accessing the Website, the User agrees to assume all risks associated with disclosure of Personal Data arising due to breach of firewalls and secure server software

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Where your consent has been provided, the Personal Data you provide us may be transferred to third parties as may be advised to you, either within or outside Singapore, as may be necessary for any of the purposes stated above. We will comply with our obligations under the PDPA in relation to such transfer, or processing for as long as the data remains within our possession or control.

If you are an EU resident, and if we do store any of your data in the European Economic Area (“EEA”), when we transfer the data outside the EEA, this is done either on the basis that it is necessary for the performance of the Services provided to you by Miiror, or that the transfer is subject to the applicable laws in the EU or under the GDPR.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service, including but not limited to the described below.

  • Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Firebase

Firebase is an analytics service provided by Google Inc.

You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en

We also encourage you to review the Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Do Not Track

Please note that we do not alter our Website’s data collection and use practices when we see a Do Not Track signal from your browser.

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. These third party sites have separate and independent privacy policies. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Period Of Storage Of The Personal Data

We maintain your Personal Data for the period necessary to carry out the purposes outlined in this policy, unless a longer retention period is required or permitted by law.

For EU residents, we will endeavour to delete data within 30 days of a request for deletion or contact you if it will take longer.

Rights In Relation To Your Personal Data

Under the PDPA, you may, by a written request to us, ascertain whether the information we hold about you is accurate and current, and you may also access and correct your Personal Data. Details of such rights are set out as follows.

The right to access: You have the right to know whether we process your Personal Data, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.

When handling a data access or correction request, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. We may charge you a reasonable fee for our administrative costs incurred for complying with your request.

We may not provide you with certain data if another law that prevails over the PDPA or the data privacy laws allows us not to provide you with such data, or if providing the data would reveal information about another person, or otherwise infringe on his or her right to privacy.

There are certain circumstances in which we will decline to comply with your request under to access your Personal Data. These include (to the extent allowable under applicable law) situations where:

(a)   a government agency in Singapore or regulator with jurisdiction over us direct us not to comply with a customer’s request;

(b)   the information may, in our discretion, affect the safety of any person or persons; and

(c)   the data may be relevant to a regulator or official investigators as part of an investigation into criminal conduct or breach of applicable laws.

The right to correction or rectification: You may request us to correct any data held about you that is inaccurate.

Withdrawal of Consent to Use Your Personal Data: You may withdraw your consent for us to use your Personal Data at any time by contacting us as directed below. We shall stop using your Personal Data and ensure that the parties to whom we transferred your Personal Data in accordance with this Privacy Policy, will comply with your request. If you only wish to stop receiving marketing or promotional materials and information from us, please contact us as indicated below.

Additional Rights for the EU residents

If you are a resident in the EU, you may have certain rights in relation to the Personal Data we hold about you, which we detail below. Some of these rights apply only in certain circumstances as set out below.

Right to information: You are entitled to request confirmation from us at any time within the scope of Art. 15 GDPR as to whether we are processing Personal Data relating to you.; If this is the case, you are also entitled under Art. 15 GDPR to receive information about such Personal Data as well as other specific information (inter alia, processing purposes, categories of Personal Data, categories of recipients, planned storage period, the origin of the data, the use of automated decision-making and, in the case of transfers to third countries, the appropriate guarantees) and a copy of the Personal Data.

Right to correction: According to Art. 16 GDPR, you are entitled to demand correction of the Personal Data stored about you if it is inaccurate or incorrect.

Right to deletion: You are entitled, under the conditions of Art. 17 GDPR, to request from us the deletion of Personal Data relating to you without delay. Among other things, there is no right of deletion if the processing of personal data is necessary for (i) the exercise of the right to freedom of expression and information, (ii) the fulfilment of a legal obligation to which we are subject (e.g. statutory retention obligations) or (iii) the assertion, exercise or defence of legal claims.

Right to limitation of processing: Under the conditions of Art. 18 GDPR you are entitled to request from us the limitation of the processing of your Personal Data.

Right to data transferability: You are entitled, under the conditions of Art. 20 GDPR, to request from us the provision to you of the Personal Data relating to you that you have submitted to us in a structured, current and machine-readable format.

Right of revocation: You have the right to revoke your consent to the processing of Personal Data at any time with effect for the future without incurring any costs other than the transmission costs according to the basic rates.

Right to objection: You are entitled to object to the processing of your personal data under the conditions of Art. 21 GDPR, meaning that we have to terminate the processing of your Personal Data. The right of objection exists only within the limits provided for in Art. 21 GDPR. In addition, our interests may prevent the processing from being terminated, so that we are entitled to process your Personal Data despite your objection.

Right related to the automated individual decision-making, including profiling: Under Art.22 GDPR, You have the right not to be subject to a decision by us based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you unless you have given your explicit consent or unless otherwise permitted under the GDPR.

Right of appeal to a supervisory authority: You are entitled to file a complaint with a supervisory authority, in particular, in the Member State of your place of residence, work or suspected infringement, under the conditions laid down in Art. 77 GDPR, if you believe that the processing of Personal Data concerning you infringes the GDPR. The right of appeal is not prejudicial to any other administrative or judicial remedy.

However, we recommend that you always address a complaint to our Data Protection Officer first. If possible, your applications for the execution of your rights should be addressed in writing to the above address or directly to our Data Protection Officer.

Scope of obligations to provide the Personal Data

Generally, you are not obliged to provide us with your Personal Data. However, if you do not provide this information, we will not be able to make our Services available to you, answer your questions and enter into a contract with you. Personal Data which we do not necessarily require for the above-mentioned processing purposes are marked as mandatory information by a “*” or another symbol.

Automated decision making / profiling

We use automated decision making or profiling of Users for the job-screening purposes. We do this on the legal basis stated in this Policy.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us: