Last Updated Date: [May 24, 2018]
AbeApps Pte Ltd., the provider of this website (referred to as “us”, “we”, and “our”), is committed to protecting user privacy (referred to as “you” and “your”). This policy applies to information we obtain from individuals interacting with AbeApps Pte Ltd., its websites, products, services, and applications, including without limitation online activities, phone contacts, offline contacts, and software reporting links (together referred to as “product”). This policy does not apply to information we obtain in our capacity as an employer. This policy is available for your review through links on our websites, references in our end user license agreements and website terms and conditions, and incorporating it into other legal documents as necessary.
BY YOUR ACCESS AND/OR USE OF THIS PRODUCT YOU ACKNOWLEDGE AND AGREE TO BE BOUND BY ALL OF THE TERMS AND CONDITIONS OUTLINED IN THIS POLICY AND THAT AbeApps Pte Ltd. MAY COLLECT, TRANSMIT, STORE, DISCLOSE, AND ANALYZE INFORMATION AS DESCRIBED BELOW FOR THE PURPOSES DESCRIBED IN THIS POLICY.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS OF THIS POLICY DO NOT ACCESS OR USE ANY ASPECT OF THIS PRODUCT AND/OR CLOSE AND DELETE ANY PORTIONS OF THIS PRODUCT DOWNLOADED OR INSTALLED BY YOU.
Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
means this website,abeapps.com;
“USA and EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and 2018]
means AbeApps Pte Ltd.( Formerly 383 Media Inc.)
Scope – What Does This Policy Cover?
1. The types of information we collect from you
There are two types of information that we collect about our users: personally Identifiable Information (“PII”) and Non-Personally Identifiable Information (“NPII”). Where the information is linked to your PII, that combined information is treated as PII.
A. PII – refers to information that lets us know the specifics of who you are such as your name, address, email address, telephone, and other personal information.
B. NPII – refers to information that does not in and of itself allow us to identify a specific individual such as your “log files” which tell us your IP address, which website your came from before ours or go to after, which browser you use, your browser language, the date and time of your requests, and the other similar activities. NPII may be analyzed and/or compiled on an aggregate or personal basis.
2. When and what information we collect from you
We may collect information from you when you: visit our websites; download or use our products; request service or support; and pay for products and services.
Cookies– When you use our websites we may store cookies on your computer in order to facilitate and customize your use of our websites. A cookie is a small data text file, which a website stores on your computer’s hard drive (if your web browser permits) that can be later retrieved to identify you to us. Our cookies consist of identification numbers only. We are able to look up information about your preferences, origin, and other information about you and your devices in order to save you time by eliminating the need to enter the same information repeatedly. You are always free to decline our cookies if your browser permits. However, some parts of our websites may not work properly and some services may not be available if you decline to accept our cookies. If a third party ad serving company is used to display advertisements on our websites they may, as a part of their service, place a separate cookie on your computer. However, these companies will not be given any of your PII without your consent.
Log Files – AbeApps Pte Ltd. maintains log files of the traffic that visits our websites. For example, our servers may automatically record the information you or your browser send when you visit a website. Those log files may include information such as your requests, IP address, browser type, browser language, the date and time of your requests, and one or more cookies that may uniquely identify your system.
Web Analytics Tools – AbeApps Pte Ltd. or third parties we have contracted or sub-contracted may employ the use of website analytic tools. These tools help us understand and measure the effectiveness of our website and our advertising in various ways. For example, these tools may count the number of individuals who visit our website from a particular advertisement or who make a purchase from our website after viewing a particular advertisement or they may tell us when a web page is viewed and provide a description of the page where the tool is placed. To do so these tools may use a cookie or other tracking mechanism, or collect your IP address or user agent information (further defined below). You may be able to block this collection of information by denying cookies.
Subscriptions– Our websites may make available news, offers, and information by subscription including emails, newsletters, and blogs. You may be asked for PII in relation to these subscriptions. The information you provide will be used to deliver the information you have requested through these subscriptions. We will not use this information for direct marketing purposes unless you agree also known as “opting in”. You are free to cancel your subscriptions at any time by clicking unsubscribe on the subscription or contacting us via the information provided herein.
Contact Us Forms & Communications– There are many opportunities to contact us via our websites. There may be links that allow you to reach us by email, by clicking a report button, by requesting online support services, live chat and other similar activities. We may collect information according to the nature of the reason you have contacted us. For example, your email address and name if you ask for support via email in order to reply, your telephone number if you request a call back, or we may ask you to allow remote access to the software and your computer files to assess a solution to a technical support request.
Other – AbeApps Pte Ltd. may also collect PII when you input such information on other parts of our website. For example, if you begin to register and/or download a product on our website but do not complete the action, you may be sent reminder communications that your action was not complete. By your initiation of such actions and use of our website, you consent to receive such communications.
B. Download or Use our Products – Dependent on whether the product is a trial, or purchased version, AbeApps Pte Ltd. may collect different types of information from you. The products may access such information through submission or processes initiated in the products by you or through internal automatic scanning and assessment functions and may submit collected data to AbeApps Pte Ltd. or its affiliates via internal automatic submission functions.
Limited Functionality and/or Duration Products – Typically, we do not require you to register PII in order to download and use trial versions of our products for the applicable trial period. However, in some cases, particularly with full functionality trials, we may ask you to register PII before you can download and use the product. Later, when you download and run such products we may collect information such as your IP address and/or Media Access Control address, the Machine/Install ID of the computer on which the product is installed, preferred language, your user agent (information such as browser information, your operating system, plug-ins you have installed such as Flash, and computer type), devices you have attached to your computer, your hardware and software and have access to your entire system registry (which may include programs you have on your computer, user files, recent websites you have visited, browsing history, etc.) and other general statistical information.
Purchased Products – Upon purchase of the product you will be asked to provide information such as your first and last name, email address, postal code, phone numbers, other contact information and your payment information to complete purchase of the product. Additionally, when you download and run such product we may collect information such as your IP address and/or Media Access Control address, the Machine/Install ID of the computer on which the product is installed, preferred languages, your user agent (information such as browser information, your operating system, plug-ins you have installed such as Flash, and computer type), devices you have attached to your computer, your hardware and software, status information about the installation or operation of the product, and have access to your entire registry (which may include programs you have on your computer, user files, recent websites you have visited, browsing history, etc.) and general statistical information.
C. Request Service or Support – We may collect PII and NPII from you in the course of providing our services or support. We may ask you to provide information about your computer, your internet access or service provider, IP address, information about your hardware and software, URLs of sites you have visited, files stored on your computer, and information about senders and receivers of email messages, and other similar NPII. We may request PII such as names, home or work address, email address, telephone number, or other information by which we may identify you. This information may be collected from you verbally, from your computer, or by way of electronic communication (including communication between your computer and ours, automated communications, and email). In your quest for support, we may also offer you the option of allowing one of our agents to take remote control of your computer wherein that agent will have access to your entire system.
3. How we use your information
Our primary goals in collecting information from End-Users are to provide and improve the Service and the Site, and to administer the Service and the Site.
- All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see the section “How Do We Store Your Data”, below.
- We use your Personal Information to provide the Service and administer your inquiries, including in the following ways:
- To process, validate and verify payments for purchases made through the Service.
- To make payments to Vendors.
- To verify the accuracy of your information.
- To contact you about the Service.
- To enable you to receive personalized content, advertising and promotions based on your preferences.
- Providing and managing your Account;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying Our [products and] services to you;
- Personalising and tailoring Our [products and] services for you;
- Responding to communications from you;
- Supplying you with email newsletters (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method;
- [Market research;]
- Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;
- We may also use your Personal Information to contact you with our newsletters, marketing or promotional materials and other information that may be of interest. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Deleting Information” below)
- We may also collect Personal Information from Vendors, including business contact details and any information that Vendors decide to provide to use, whether through the Site or otherwise. We use such information only in connection with our relationship with the applicable Vendor.
- In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.
- With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Com
- [Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.]
- Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- processing is necessary for compliance with a legal obligation to which we are subject;
- processing is necessary to protect the vital interests of you or of another natural person;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. [List specific legitimate interests if available]
4. How and Where Do We Store Your Data?
We only keep your data for as long as We need to in order to use it as described above in “How we use your information”, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:
[Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).]
[Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. [If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand.
Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.
Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
A. How our systems combine information and how we store, transfer, retain, and protect your information?
Our Systems – All PII is recorded in our ecommerce system and all NPII is stored in a separate tracking system. A user’s PII and NPII are linked by way of the fact that their information in both
systems is categorized under the same unique identification number (UID). Due to the shared UID number in these systems, all information collected and stored in both systems is treated by AbeApps Pte Ltd. as PII. However, neither system is able to use nor automatically access the information stored in the other. Where the NPII collected is disassociated from the UID, the information collected is treated as
NPII. Where such Mix Panel is a third party application utilized by AbeApps Pte Ltd. for the purpose of securely hosting Customer Relations Management (CRM). AbeApps Pte Ltd. analyzes data collected on an aggregate basis to optimize ecommerce flow and marketing campaigns.
Storage of Your Information – Information that we collect may be stored and processed in the United States or any other country in which we, our subsidiaries, affiliates, contractors, representatives, agents, or resellers maintain such information. PII on our servers is only accessible from our physical premises, premises of our subsidiaries, affiliates, contractors, representatives, agents and authenticated networks and personnel. Access is limited to authorized personnel only, and company networks are password protected and subject to additional policies and procedures for security. By your use of our product you consent to any such transfer of information outside of your country.
Data Transfer –Information may be transferred to the AbeApps Pte Ltd. group in the United States or other countries that may have less protective data protection laws than the region in which you are situated and be accessible by AbeApps Pte Ltd. employees or contractors exclusively to be used in accordance with the purposes outlined in this policy. For the same purposes the information may be shared with partners and vendors that process information on behalf of AbeApps Pte Ltd., including, for instance, banking and credit card partners to process payments made by you on our site. AbeApps Pte Ltd. has taken steps so that the collected information, if transferred, receives an adequate level of protection.
Data Retention – In general, AbeApps Pte Ltd. will retain your PII for as long as you are a user of our products and thereafter for internal reporting and reconciliation purposes as necessitated by legal requirements and to provide you with any feedback or information you might request or require. After this time period we may delete orde-identify the information from our systems. Please note that if we remove your PII from our systems as described above, because we keep track of past transactions, we cannot delete information associated with those transactions. Additionally, it may be impossible to completely delete your information because of our data backup processes.
Security –We use administrative, technical, and physical safeguards to protect the information we maintain and ensure it is used in accordance to the terms of this policy. Our security controls are designed to restrict access to the information to authorized personnel only. We test our website for security vulnerabilities. When you make payment on our websites using your credit card, we use SSL encryption in the transmission to AbeApps Pte Ltd. of the credit card number.
5. Do We Share Your Data?
[We may share your data with other companies in Our group. This includes [Our subsidiaries] AND/OR [Our holding company and its subsidiaries].]
We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with Google, Bing, Facebook,
We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
6. What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.
7. How Can You Control Your Data?
When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.
You may email Us at any time at email@example.com for further information on your data.
8. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
You may withdraw your consent for Us to use your personal data as set out above at any time by contacting Us using the details set out in section “What Cookies Do We Use and What For?”, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.
9. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at firstname.lastname@example.org, or using the contact details below under “Contact Us”.
10. What Cookies Do We Use and What For?
By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section on “Cookies” below. These Cookies are not integral to the functioning of Our Site.
All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.
Before [any] Cookies are placed on your computer or device, you will be shown a [Insert description of prompt e.g. pop-up, message bar etc.] requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. [You will be given the opportunity to allow only first party Cookies and block third party Cookies.]
[Certain features of Our Site depend on Cookies to function. [Your Country] and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in Table 1.1 Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.]
The following first party Cookies may be placed on your computer or device (Table 1.1):
|Name of Cookie||Purpose||Strictly Necessary|
|8812c36aa5ae336c2a77bf63211d899a||Maintains user country, currency and cart identified data. It also includes key marked for A/B||yes|
|PHPSESSID||Maintaining User’s session||Yes|
|SERVERID||Identifies which server is serving user’s request. This is used for load balancing||Yes|
|affiliateCode||From which affiliate user lands on website||No|
|clickid||Clickid of of landing page.||No|
|subSource||From which sub source user lands on website||No|
|ckIds||list of all Clickids of user||No|
and the following third party Cookies may be placed on your computer or device(Table 1.2):
|Name of Cookie||Provider||Purpose|
Our Site uses analytics services provided by [Google Analytics, Leads 383media. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the [products and] services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. [Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.]
The analytics service(s) used by Our Site use(s) the following Cookies:
|Name of Cookie||First / Third Party||Provider||Purpose|
|Third Party||Google analytic||Names of cookies that start with __utm and _ga originate from Google Analytics and are used to collect information about usage statistics.|
|JSESSIONID||Third Party||Leads 383media||User session identifier|
|LDSERVERID||Third Party||Leads 383media||Identifies which server is serving user’s request. This is used for load balancing|
|ckIds||Third Party||Leads 383media||List of all Clickids of user|
|clkid||Third Party||Leads 383media||Clickid of of landing page|
|clickid||Third Party||Leads 383media||Clickid of of landing page.|
|Name of Cookie||Provider||Purpose|
|APISID, NID, SID, 1P_JAR||Google API||Google uses these cookies, based on recent searches and interactions, to customise ads on Google websites|
You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]
11. Summary of Your Rights under GDPR
Under the GDPR, you have:
- the right to request access to, deletion of or correction of, your personal data held by Us;
- the right to complain to a supervisory authority;
- be informed of what data processing is taking place;
- the right to restrict processing;
- the right to data portability;
- object to processing of your personal data;
- rights with respect to automated decision-making and profiling (see section 14 below).
12. Automated Decision-Making and Profiling
In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.
Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
13.Third-Party Websites and Services
Except as otherwise discussed in this policy, this document addresses only the use and disclosure of information we collect about and from you. We do not endorse, approve, or guarantee any third party sites or products. Third party sites or products accessible through our products have their own privacy policies, data collection, and use and disclosure practices. Please also be aware that, in providing services on AbeApps Pte Ltd.’s behalf, our business partners may collect personal information about you. Please contact these third parties if you have any questions as to their privacy practices. AbeApps Pte Ltd. shall not be held liable for any damage or loss arising out of your interactions with any third party.
14. How you can update or make changes to your personal information
We believe that you should have the ability to edit the PII that you have provided us. You may access and edit your account information by contacting us through the contact information provided herein.
We encourage you to promptly update your PII if it changes. At this time AbeApps Pte Ltd. does not delete information collected from users.
15. How you can update your communication preferences
You may choose not to receive marketing communications from us by clicking on the unsubscribe link or following the instructions provided within those emails or contacting us using the contactinformation provided herein. If you choose to no longer receive marketing communications, AbeApps Pte Ltd. may still communicate with you regarding such things as product updates and functionality, responses to service requests or other transaction related communications. Any marketing by AbeApps Pte Ltd., or any third parties on behalf of AbeApps Pte Ltd., will be conducted in accordance with applicable laws. Please allow at least 10 business days for your email preferences to take effect. Because some promotions, such as direct mail catalogs, are developed in advance, you may sometimes receive solicitations after we receive your communication preference request.
16. Collection and Use of Children’s Information
AbeApps takes children’s privacy seriously. We do not knowingly collect, use or disclose personal information from children under the age of 13 through our websites. If you are under 18 years of age.
the age of majority in your jurisdiction, please do not submit any personal information through our websites without the express consent and participation of a parent or guardian.
17. Updating the Privacy Notice
18. Contact Us
The preferred method for you to contact us is via our Contact Us form on our Site. In the alternative, you may reach us at:
AbeApps Pte. Ltd.
Street: 17 PHILLIP STREET
#05-01 GRAND BUILDING
SINGAPORE (SG) 048695