1. Collecting your personal data. We collect personal data that is relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, such as when:

  • You authorise us to obtain your personal data from a third party;
  • You use our services, e.g. our Sentinel Protocol Platform;
  • You visit our websites, download or use our applications, e.g. our UPPward Extension,
  • You register an account with us through our websites or applications;
  • You contact us or request that we contact you e.g. through social media platforms, you transact with us, contact us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;
  • Your images are captured via photographs or videos taken by us or our representatives when you are within our premises or attend events organised by us;
  • You participate in events and programs, competitions, contests or games organised by us;
  • Ye seek information about you and receive your personal data in connection with your relationship with us, for example, if you are an investor or shareholder;
  • You submit your personal data to us for any other reason.

Depending on your relationship with us, we may also collect your personal data from third party sources, for example:

  • Our business partners such as third parties providing advertising, marketing and promotional services to us;
  • Your referees, educational institutions or previous employers (if you have applied to us for a job);
  • Your family members or friends who provide your personal data to us on your behalf; and/or
  • Public agencies or other public sources.

2. Automated Data Collection Technologies. Our websites, applications and services may contain or involve certain technologies (including those described below) that collect data from you, such as your Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our websites that you visit, the time and date of your visit, your time spent on our websites, applications and services, unique device identifiers and other diagnostic data.

  • Cookies. Cookies allow your browser or device to be recognised. We may make use of cookies to store and track information such as the number of users, frequency of use, profiles of users and online preferences. Cookies do not capture information that personally identify you, but we may use information collected to analyse the usage of our websites and applications and to improve your user experience. You may disable cookies through your device or plug-in settings. However, this may affect your use of our websites and applications.
  • Website Log Files. We collect data in the form of server log files that tell us generally about the activity of users on our websites and applications, including length of visits, the webpages requested, IP address, cookies, the type of web browser and operating system you are using, click-stream data and so forth. We use this data to analyse overall trends, administer our websites, applications and services, track usage, optimize and improve your user experience, as well as evaluate and improve our websites, applications and services.
  • Analytical Tools. We use analytical tools, which allow us to, among other things, identify potential performance or security issues with our websites, applications and services, improve their stability and function, understand how you use them, so that we can optimize and improve your user experience, as well as evaluate and improve our websites, applications and services.
  • Third Party Analytical Tools. Our analytical tools include third party tools. We do not control these third parties, their technologies or how they may collect and use information through their tools. The tools that are currently in use include: Google Analytics (https://marketingplatform.google.com/about/), Logentries (https://www.rapid7.com/), and Sentry (https://sentry.io/). More details about these tools, including the privacy policies of their provider can be found on their respective websites. If you have any queries about these technologies and how they collect and use information, please contact the responsible provider directly.

Please do not use our websites, applications and services if you do not wish to have your data collected through such means. Alternatively, you may also disable the operation of these technologies on your devices where it is possible to do so. Our websites, applications and services do not support Do Not Track ("DNT"). However, you may enable or disable DNT, if supported by your web browser, by enabling or disabling this feature in the preferences or settings page of your web browser.


3. What personal data we collect from you. The personal data we may collect from you depends on the purposes for which we will be using the personal data and what you have chosen to provide, and may include your name, contact information (such as email address); IP addresses; and other information that may identify you.

4. Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself (such as your family members). If you do so, you are responsible for informing him/her of the specific purposes for which we are collecting his/her personal data and to ensure that he/she has provided valid consent for your provision of his/her personal data to us.

5. Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide is true, accurate and complete, and to inform us of any changes to your personal data.

6. Voluntary provision of personal data. Your provision of personal data to us is voluntary and you have the right to withdraw your consent for us to use your personal data at any time by contacting us. However, if you do so, it may not be possible for us to fulfil the purposes for which we require the personal data, including providing services which you require from us.

7. Minors. Our websites, applications and services are not intended for children, minors or persons who are not of legal age. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us to request for erasure of their personal data.