Last modified on 4 June 2020<\/em><\/p>\n\n\n\n Our Commitment to You<\/strong> At ViSenze, we are 100% committed to protecting the privacy and security of the businesses we work with to provide our services to. We respect the privacy and confidentiality of any personal data that we process when we provide our services.<\/p>\n\n\n\n We have two types of Privacy Policies:<\/p>\n\n\n\n Our home is Singapore and we have implemented policies and practices about the way we process personal data in compliance with the Personal Data Protection Act (PDPA) of Singapore. Being a global business, we have also implemented policies and practices required by the General Data Protection Regulation (GDPR).<\/p>\n\n\n\n As there may be changes to privacy laws and regulations, we reserve the right to update this Privacy Policy at any time. <\/p>\n\n\n\n We are transparent about the changes we make to our Privacy Policy. For past Privacy Policy updates:<\/p>\n\n\n\n \u2018Personal Data\u2019 means any data (in Singapore, whether true or not), about or relating to an individual who can be identified from that data (including when it is put together with other information to which we have or are likely to have access) or is otherwise an identified or identifiable individual.<\/p>\n Your name, plus information such as your phone number, physical or email address, your employer\u2019s name and your job title, is personal data. Your image in a photo or video may be personal data. Your IP address may also be personal data.<\/p>\n An individual who can be identified from personal data is called a \u2018data subject\u2019.<\/p>\n <\/div>\r\n <\/div>\r\n We will ask you for it (including contact information and relationship information) when you interact with us and\/or when you have been referred to us as an individual who may be interested in knowing more about the services we provide, including:<\/p>\n We use a variety of third-party service providers to help us provide our services to our customers.\u00a0 They may be located inside or outside of the European Economic Area (EEA).\u00a0 In particular, they may be located in Europe, India, Asia Pacific, and North America.\u00a0 We use them to help us:<\/p>\n These service providers have limited access to your personal data to perform these tasks on our behalf and they are contractually bound to protect the personal data and only use it in accordance with our instructions.\u00a0 We share your personal data with them only so that we are able to ensure the adequate performance of our obligations to you.<\/p>\n To enable us to provide our services, we may share your personal data with companies that are in our corporate group (because they are related by common ownership or control).<\/p>\n If we undertake or are involved in any fundraising through investment in us or in any merger, acquisition, reorganisation, sale of assets, bankruptcy or insolvency event, we may sell, transfer or share some or all of our assets, including your personal data in connection with such a transaction or in contemplation of such a transaction (for example, in due diligence).<\/p>\n If this happens, we will if it is reasonably commercially possible notify you before your personal data is transferred and becomes subject to the privacy policy of the transferee.<\/p>\n <\/div>\r\n <\/div>\r\n We have five data centres globally at present.\u00a0 They are in Ireland, Singapore, Japan, China and the US.\u00a0 We may add more data centres in the future.<\/p>\n If you complete an online form on our website (such as \u2018Request for Free Trial\u2019 and \u2018Contact Us\u2019 or other such marketing reasons that would require your voluntary sharing or contact information) or if we otherwise process personal data about you because we think you and\/or your company may be interested in using our services we store the personal data we receive from you or otherwise collect about you on our server in Singapore and as we use the services of HubSpot, Inc., on their server in the US.<\/p>\n If you choose to use a dashboard that we make available to our customers and\/or business partners (such as our Enterprise Dashboard and our Sales Performance Dashboard), we store the personal data we receive from you or otherwise collect about you from such customer and\/or business partner:<\/p>\n If you and\/or your company have a contract with us (for example, a contract under which we provide services to you\/your company) we generally retain your personal data for as long as is necessary for the performance of that contract and to comply with our legal obligations.<\/p>\n If you have been nominated by your company to have access to a dashboard maintained by us that is relevant to the business relationship we have with your company, we retain your personal data only until the earlier of:<\/p>\n If we have been in active contact with you but you \/ your company have not entered into a contract with us we generally retain your personal data for no longer than two years after such contact ceases (for your and our convenience if you contact us again during that two year period).<\/p>\n If we have not been in active contact with you (for example, where you have completed the \u2018Request for Free Trial\u2019 or \u2018Contact Us\u2019 form on our website, we have responded to your request and we have not heard back from you) we generally retain your personal data for no longer than six months after you submit it to us.<\/p>\n <\/div>\r\n <\/div>\r\n You can request us to erase your personal data at any time. However, in any such case we may retain some of your personal data as necessary for our legitimate business interests, including our corporate record-keeping.\u00a0 We may also retain and use your personal data to the extent necessary or desirable to enable us to comply with our legal obligations.\u00a0 For example, we may retain some of your personal data for tax, legal and auditing purposes.<\/p>\n You have the right to obtain confirmation from us as to whether or not we are processing personal data concerning you.\u00a0 Where we are doing so, you have the right to obtain a copy of the personal data undergoing processing from us and:<\/p>\n You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you.<\/p>\n You have the right to obtain from us the erasure of personal data concerning you without undue delay if:<\/p>\n You have the right to obtain from us restriction of processing of personal data concerning you where one of the following applies:<\/p>\n You are entitled to request us not to process your personal data for certain specific purposes (including profiling) where such processing is based on our legitimate interest in processing it.\u00a0 If you object to such processing we will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required in order for us to establish, exercise or defence legal claims.<\/p>\n Where we process your personal data for direct marketing purposes, you may at any time ask us to cease processing your personal data for such purposes.\u00a0 You can do this by choosing \u2018unsubscribe\u2019 in an email we have sent to you or by\u00a0contacting us<\/span>.<\/p>\n You are entitled to request copies of personal data that you have provided to us in a structured, commonly-used and machine-readable format and\/or to request us to transmit such personal data to another service provider if it is technically feasible for us to do so.<\/p>\n If you have any complaints about the way or ways in which we have or have not processed your personal data or you believe that we have not complied with your rights as a data subject, please do\u00a0contact us<\/a>.<\/p>\n However, if you believe that we have not complied with your rights as a data subject, you can lodge a complaint to the supervisory authority in the country in which you live.<\/p>\n We do not use any personal data about you for automated decision-making, including profiling.\u00a0 Where we return visual matches to\u00a0query images<\/a>, to the extent that our visual search and recognition service includes automated decision-making it concerns the item in the query image and not any personal data about you.<\/p>\n <\/div>\r\n <\/div>\r\n We are ViSenze Pte. Ltd (\u2018ViSenze\u2019, \u2018we\u2019, \u2018us\u2019, \u2018our\u2019, etc.<\/strong>), a company incorporated in Singapore with registration number 201221002E.\u00a0 Our registered office and place of business is at 67 Ayer Rajah Crescent #07-11 Singapore 139950.<\/p>\n We are always happy to provide additional information about how we process personal data and to answer any questions about our processing activities. You can contact us by writing to us at our address above or by emailing\u00a0dataprotection@dgbrew.com<\/a>.<\/p>\n General Data Protection Regulation (GDPR) \u2013 European Representative<\/strong><\/p>\n Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Visenze has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:<\/p>\n If you are our employee or a job applicant, please contact our Human Resources Department or email\u00a0careers@dgbrew.com<\/a>\u00a0and we will be happy to provide you with information about how we process personal data in that context.<\/p>\n UK\u00a0General Data Protection Regulation (GDPR) \u2013\u00a0UK\u00a0Representative<\/b><\/p>\n Pursuant to the UK GDPR, Visenze has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:<\/p>\n When you visit our website and when you and\/or your company use our services, we collect certain transaction information by automated means.\u00a0 We do this by using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.\u00a0 We may also collect information about the website you were visiting before you came to our website and the website you visit after you leave our site.<\/p>\n Cookies are small text files that websites send to your computer or device to uniquely identify your browser or to store information or settings in your browser.\u00a0 We place cookies on your computer or other device when you use it to visit our website.<\/p>\n Technically-required cookies<\/strong><\/p>\n These are cookies that are mandatorily required for the technical functions of our website e.g. session cookies.<\/p>\n For these, consent is not required and we will delete technically-required cookies when you leave the website.<\/p>\n Cookies that are not technically-required<\/strong><\/p>\n We only use cookies and\/or other tracking mechanisms that are not technically-required if you have given us your prior consent the first time you visit our website.<\/p>\n We use such cookies for marketing purposes so that we are able to communicate better with you based on your interests.<\/p>\n We collect many different types of information from cookies and other tracking mechanisms.\u00a0 For example, we may collect information about your device type, your operating system type, browser type, domain and other system settings, language and IP address.<\/p>\n In many cases, we only use this information statistically in a non-identifiable way, without any reference to personal data \u2013 in other words, in these cases we are not able to uniquely identify you from the information collected.\u00a0 For example, we use information we collect about all website users to understand website traffic patterns.<\/p>\n Where you have contacted us through a contact form on our website and provided your name and contact details to us, we do associate the information we collect using cookies and other tools with your personal data \u2013 in other words, in these cases we do identify you.\u00a0 This Privacy Policy applies to information we collect using cookies and other tools only when we associate it with personal data about or referring to you.<\/p>\n In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. Please go to the \u2018help\u2019 section of your browser to find out about cookie preferences and other privacy settings that may be available in your browser and how to set them.<\/p>\n <\/div>\r\n <\/div>\r\n <\/section>\r\n<\/div>\r\n\n\n \u2018Personal Data\u2019 means any data (in Singapore, whether true or not), about or relating to an individual who can be identified from that data (including when it is put together with other information to which we have or are likely to have access) or is otherwise an identified or identifiable individual.<\/p>\n Your name, plus information such as your phone number, physical or email address, your employer\u2019s name and your job title, is personal data. Your image in a photo or video may be personal data. Your IP address may also be personal data.<\/p>\n An individual who can be identified from personal data is called a \u2018data subject\u2019.<\/p>\n We build up a \u2018reference database\u2019 of images of products from various sources \u2013 we call images in the reference database \u2018reference images\u2019.<\/p>\n The sources include businesses that provide images to us to add to our reference database to use in providing our visual search and recognition services. The sources also include business that provide us with images so that we can provide annotation and tagging services.<\/p>\n Some reference images may include an individual, such as a model in a clothing catalogue or an actor in a video. If so, that individual is a \u2018reference image data subject\u2019.<\/p>\n Any individual, as an\u00a0external end user<\/a>, can upload an image and send it to us to request a visual match to an item in it that the individual wishes to find available for purchase if the individual has an app, website or a mobile device that is integrated with our visual search and recognition service. The apps \/ websites send the image to us either directly or via our business partner that provided the app\/website used by the end user. In addition, an\u00a0internal end user<\/a>\u00a0can upload an image and send it to us for testing our visual search and recognition services. We call any such image a \u2018query image\u2019.<\/p>\n Some query images may include the image of an individual. If so, that individual is a \u2018query image data subject\u2019.<\/p>\n As an individual you can upload a\u00a0query image<\/a>\u00a0and send it to us to request a visual match to an item in it and\/or select a category of products that you want to search. You can do this if you have an app or if you use a website or mobile device that a business integrates with our visual search and recognition services. If so, we refer to you as an \u2018external end user\u2019.<\/p>\n If you represent a business that is our customer, you can upload a query image and send it to us to test our visual search and recognition services and\/or send us images for annotation or tagging. If so, we refer to you as an \u2018internal end user\u2019 \u2013 please refer to our Privacy Policy \u2013 General for information about personal data about or relating to you that we may process.<\/p>\n Where both external end users and internal end users are treated in the same way, in this Privacy Policy we simply use the term \u2018end user\u2019 of our services.<\/p>\n <\/div>\r\n <\/div>\r\n We build up a \u2018reference database\u2019 of images of products from various sources \u2013 we call images in the reference database \u2018reference images\u2019.<\/p>\n The sources include businesses that provide images to us to add to our reference database to use in providing our visual search and recognition services.\u00a0 The sources also include business that provide us with images so that we can provide annotation and tagging services.<\/p>\n Some reference images may include an individual, such as a model in a clothing catalogue or an actor in a video.\u00a0 If so, that individual is a \u2018reference image data subject\u2019.<\/p>\n If you are a reference image data subject we process your personal data incidentally:<\/p>\n We say \u2018incidentally\u2019 here because our services concentrate on the item in the image.\u00a0 But we cannot avoid processing your personal data too \u2013 for example, for product matching we need to know where your face is in the image and we need to detect your gender so that we can return relevant visual matches to the end user.<\/p>\n We process personal data for these purposes on the basis that it is necessary for the purposes of our legitimate interests and that, by doing so, we do not override the interests or fundamental rights and freedoms of the reference image data subject that requires protection of personal data.<\/p>\n If you are a reference image data subject your personal data:<\/p>\n If the reference image is related to product retailing we seek to keep visual matches that we return to\u00a0end users<\/a>\u00a0relevant to their likely current purchasing preferences.\u00a0By default we keep reference images for 12\u00a0months after the relevant business closes its account with us, but businesses generally update their reference images regularly so they are up\u2011to-date and may ask us to delete them immediately after, or a specified time (such as three months after) they close their account with us.<\/p>\n If the reference image is not related to product retailing, the relevant business generally requires us to delete the images after they close their account with us, but it may require us to delete reference images during the course of an ongoing relationship with them.<\/p>\n When we process reference images in our prediction models for the essential task of developing, supporting, continuously improving and optimising the ViSenze Service for the benefit of the businesses that use them, the reference images may become unidentifiable during such use and, in any event, we delete them when we cease using the prediction model.<\/p>\n We store a copy of all reference images in Singapore for the essential task of developing, supporting, continuously improving and optimising the ViSenze Service for the benefit of the businesses that use them.<\/p>\n <\/div>\r\n <\/div>\r\n Any individual, as an\u00a0external end user<\/a>, can upload an image and send it to us to request a visual match to an item in it that the individual wishes to find available for purchase if the individual has an app, website or a mobile device that is integrated with our visual search and recognition service.\u00a0 The apps \/ websites send the image to us either directly or via our business partner that provided the app\/website used by the end user.\u00a0 In addition, an\u00a0internal end user<\/a>\u00a0can upload an image and send it to us for testing our visual search and recognition services.\u00a0 We call any such image a \u2018query image\u2019.<\/p>\n Some query images may include the image of an individual.\u00a0 If so, that individual is a \u2018query image data subject\u2019.<\/p>\n If you are a query image data subject we process your personal data incidentally:<\/p>\n We say \u2018incidentally\u2019 here because our services concentrate on the item in the image.\u00a0 But we cannot avoid processing your personal data too \u2013 for example, for product matching we need to know where your face is in the image and we need to detect your gender so that we can return relevant visual matches to the end user.<\/p>\n We process personal data for these purposes on the basis that it is necessary for the purposes of our legitimate interests and that, by doing so, we do not override the interests or fundamental rights and freedoms of the query image data subject that requires protection of personal data.<\/p>\n If you are a query image data subject your personal data may be disclosed to personnel of our annotation service providers \u2013 we have entered into strict confidentiality arrangements with them.<\/p>\n Some businesses require us to delete query images immediately after we return visual search matches for them and others specify a period of time \u2013 such as a few weeks or months \u2013 for which we may keep them.\u00a0 Otherwise, we may decide to retain query images for up to one year:<\/p>\n If you are an\u00a0external end user<\/a>\u00a0and you are located in the European Economic Area we store the query images you send us in a data centre in a Member State of the European Union. \u00a0We keep your location information attached to such query images in the European Economic Area too.\u00a0 Otherwise, we store query images in a data centre agreed with the business through which we provide our services to you.<\/p>\n However, we also keep a copy of your IP address (which provides location information) in our system logs.<\/p>\n <\/div>\r\n <\/div>\r\n As an individual you can upload a\u00a0query image<\/a>\u00a0and send it to us to request a visual match to an item in it and\/or select a category of products that you want to search.\u00a0 You can do this if you have an app or if you use a website or mobile device that a business integrates with our visual search and recognition services.\u00a0 If so, we refer to you as an \u2018external end user\u2019.<\/p>\n If you represent a business that is our customer, you can upload a query image and send it to us to test our visual search and recognition services and\/or send us images for annotation or tagging.\u00a0 If so, we refer to you as an \u2018internal end user\u2019.<\/p>\n Where both external end users and internal end users are treated in the same way, in this Privacy Policy we simply use the term \u2018end user\u2019 of our services.<\/p>\n It is possible for you, as an external end user, to choose to send us a\u00a0query image<\/a>\u00a0that is a selfie.\u00a0 If you do so, the query image contains your personal data and you are both the\u00a0query image data subject<\/a>\u00a0and the external end user.<\/p>\nPurpose of this Privacy Policy<\/strong><\/h4>\n\n\n\n
<\/li>
We respect the privacy and confidentiality of any personal data that we process when we provide our services. With one exception, the way we do so is set out in this Privacy Policy. The exception occurs when our services are provided through an app on a mobile phone that was loaded onto it by the mobile phone manufacturer. In that case, please refer to the Privacy Policy in the app on your mobile phone.<\/li><\/ul>\n\n\n\nPersonal Data Compliance<\/strong><\/h4>\n\n\n\n
Updates to this Privacy Policy<\/strong><\/h4>\n\n\n\n
Past Policy Updates<\/h2>\n\n\n\n
GENERAL Privacy Policy<\/h2>\n <\/header>\r\n
<\/a>1. SOME TECHNICAL TERMS FOR YOUR UNDERSTANDING<\/i><\/h3>\r\n
What is \u2018Personal Data\u2019?<\/h4>\n
Examples of Personal Data<\/h4>\n
Who or what is a \u2018data subject\u2019?<\/h4>\n
<\/a>2. WHAT KIND OF DATA DO WE COLLECT?<\/i><\/h3>\r\n
We may collect the following types of personal data about or relating to you:<\/strong><\/h4>\n
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<\/a>3. HOW WE COLLECT PERSONAL DATA<\/i><\/h3>\r\n
We generally collect personal data directly from you.\u00a0<\/strong><\/h4>\n
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<\/a>4. HOW DO WE USE THIS INFORMATION?<\/i><\/h3>\r\n
We use personal data about or relating to you:<\/strong><\/h4>\n
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<\/a>5. HOW IS THIS INFORMATION SHARED?<\/i><\/h3>\r\n
Service providers<\/h4>\n
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Our related companies<\/h4>\n
Business transfers and other related transactions<\/h4>\n
<\/a>6. WHERE WE STORE PERSONAL DATA<\/i><\/h3>\r\n
Website forms; other marketing uses of personal data<\/strong><\/h4>\n
Use of a dashboard and\/or our annotation system<\/strong><\/h4>\n
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<\/a>7. HOW LONG DO WE STORE DATA FOR?<\/i><\/h3>\r\n
If there is a contract between us and you \/ your company:<\/strong><\/h4>\n
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If we have been in contact with you and we do not enter into a contract with you \/ your company:<\/strong><\/h4>\n
<\/a>8. YOUR RIGHTS<\/i><\/h3>\r\n
Your right to access personal data about or relating to you<\/strong><\/h4>\n
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Your right to rectification of personal data concerning you<\/strong><\/h4>\n
Your right to erasure \u2013 the \u2018right to be forgotten\u2019<\/strong><\/h4>\n
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Your right to restriction of processing<\/strong><\/h4>\n
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Your right to object to processing<\/strong><\/h4>\n
Your right to data portability<\/strong><\/h4>\n
Your right to raise issues<\/strong><\/h4>\n
Your right to know about any automated decision-making<\/strong><\/h4>\n
<\/a>9. CONTACT US<\/i><\/h3>\r\n
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<\/a>10 . COOKIES POLICY<\/i><\/h3>\r\n
Types of cookies<\/strong><\/h4>\n
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Cookies and your Personal Data<\/strong><\/h4>\n
Managing your cookie preferences<\/strong><\/h4>\n
SERVICES Privacy Policy<\/h2>\n <\/header>\r\n
<\/a>1. SOME TECHNICAL TERMS FOR YOUR UNDERSTANDING<\/i><\/h3>\r\n
What is \u2018Personal Data\u2019?<\/h4>\n
Examples of Personal Data<\/h4>\n
Who or what is a \u2018data subject\u2019?<\/h4>\n
Reference Image Data Subject<\/h4>\n
Query Image Data Subject<\/h4>\n
End User<\/h4>\n
<\/a>2. INFORMATION REGARDING REFERENCE IMAGE DATA SUBJECTS<\/i><\/h3>\r\n
What is a reference image and reference image data subject?<\/strong><\/h4>\n
Why we process the personal data of reference image data subjects<\/h4>\n
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Who receives the personal data of reference image data subjects?<\/strong><\/h4>\n
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How long we keep a reference image<\/strong><\/h4>\n
Where we store reference images<\/strong><\/h4>\n
<\/a>3. INFORMATION REGARDING QUERY IMAGE DATA SUBJECTS<\/i><\/h3>\r\n
What is a query image and a query image data subject?<\/strong><\/h4>\n
Why we process the personal data of query image data subjects<\/strong><\/h4>\n
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Who receives the personal data of query image data subjects<\/strong><\/h4>\n
How long we keep a query image<\/strong><\/h4>\n
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Where we store query images and IP addresses of external end users<\/strong><\/h4>\n
<\/a>4. INFORMATION REGARDING END USERS<\/i><\/h3>\r\n
What is an \u2018End User\u2019 ?<\/strong><\/h4>\n
Being an external end user and also a query image data subject<\/strong><\/h4>\n
What personal data we collect, why and how long we keep it<\/strong><\/h4>\n