Privacy Policy

1. Overview

1.1 Playfix Pte. Ltd. and its related companies and affiliates (collectively, “Playfix”) own and operate the website https://www.playfix.io/ and all its subdomains (“Site”), and provide related platforms, tools, applications, documentation, software and other services (“Services”).

1.2 Application.

1.2.1 This Privacy Policy applies to all Personal Data processed by Playfix in its provision of the Site and Services. For the purposes of this Privacy Policy, “Personal Data” shall have the meaning defined in the Singapore Personal Data Protection Act 2012 (“PDPA”).

1.2.2 If you have not used our Site or Services and your Personal Data was provided to us by your service provider who utilises our Site or Services, only Clause 4 of this Privacy Policy applies to your Personal Data. Your service provider bears primary responsibility for your Personal Data and Clause 4 of this Privacy Policy sets out our agreement with your service provider in respect of your Personal Data.

1.3 Playfix is committed to protecting your privacy and the security of your Personal Data. This Privacy Policy sets out the ways in which Playfix collects, uses, discloses, processes, and protects your Personal Data.

1.4 Access to and use of the Site and Services is conditional upon acceptance of Playfix’s Terms of Service accessible at https://playfix.io/terms (“Terms of Service”), into which this Privacy Policy is incorporated by reference and which this Privacy Policy is an integral part of. By accessing and/or using the Site or Services, you acknowledge you have read Playfix’s Terms of Service including this Privacy Policy, and that you expressly agree to the Terms of Service and expressly consent to Playfix’s collection, use, disclosure, and processing of your Personal Data in accordance with this Privacy Policy. If you do not agree to the Terms of Service and/or do not consent to such collection, use, disclosure and processing of your Personal Data, please do not access or use the Site and/or Services.

1.5 Playfix may collect Personal Data about you online through the Site and Services, or through other means of communication such as text messages and phone calls. By providing Personal Data to Playfix, you consent (or if you are providing Personal Data of another person, you represent that you have the requisite authorisation and consent on that person’s behalf) to Playfix collecting that Personal Data and using, disclosing and processing it in accordance with this Privacy Policy or as permitted or required by law. If you do not consent to such collection, use, disclosure or processing, please do not provide the Personal Data.

1.6 We reserve the right to amend this Privacy Policy at any time in accordance with the relevant laws and regulations.

2. Data Collection and Use

2.1 Playfix collects and uses your Personal Data to provide you with the Site and Services, and to
customise and improve the Services to make your experience more secure and convenient.

2.2 The types of Personal Data that Playfix may collect from you in the course of using the Site and Services include, but are not limited to:

2.2.1 where you register to use our Services, your name, age, date of birth, gender, email address, contact number and physical address;

2.2.2 information about your browsing session and usage of our Services that is automatically collected when you browse the Site or use the Services, such as your IP address and IP domain, location, clicked links and viewed content (“Browsing Information”); and

2.2.3 any Personal Data as Playfix may deem essential or appropriate from time to time to fulfil your commercial relationship with Playfix or to provide the Site or Services to you.

2.3 The purposes for which Playfix may use or process your Personal Data include, but are not limited to, the following:

2.3.1 to provide the Services requested by you;

2.3.2 for customer service, communication and administrative purposes;

2.3.3 to fulfil any legal requirements and relevant regulatory guidelines;

2.3.4 to customise your online experience;

2.3.5 to analyse and understand our customers’ behaviour and preferences;

2.3.6 if you consent and sign up to do so, for marketing purposes, and to inform you of certain promotions which may be of interest to you. You may modify or revoke this consent via the settings page on the Site;

2.3.7 conducting due diligence and investigations, such as user authentication and checking for fraud.

2.4 Playfix only collects and uses Personal Data about you that Playfix considers reasonably necessary for achieving the purposes for which such Personal Data was collected.

2.5 If you have requested for any services which can only be fulfilled upon the collection, use, disclosure or processing of your Personal Data, you will be deemed to have consented to such collection, use, disclosure or processing.

2.6 We may collect, use, disclose or process your Personal Data without your consent under circumstances which are permitted by the PDPA.

2.7 We do not knowingly collect or use Personal Data from children under 16 years of age. If we learn that we have collected Personal Data from a child under 16 years of age, the Personal Data will be deleted as soon as possible. If a child under 16 years of age has provided us with Personal Data, their parent or guardian may contact our Data Protection Officer using the contact details set out at the end of this Privacy Policy.

3. Sharing with and Disclosure to Third Parties

3.1 Certain Services require your Personal Data to be disclosed to third parties. Playfix will only disclose your Personal Data to third parties to the extent that it is necessary to enable Playfix to provide Services to you, or for purposes to which you have consented.

3.2 The purposes for which Playfix may disclose your Personal Data to third parties include, but are not limited to:

3.2.1 fulfilling your requests for Services to be provided to you;

3.2.2 customer service, communication and administrative purposes;

3.2.3 making insurance claims;

3.2.4 protecting, proving or enforcing our legal rights;

3.2.5 where required for any legal proceedings; and

3.2.6 conducting due diligence and investigations, such as user authentication and checking for fraud.

3.3 Third parties to whom Playfix may disclose your Personal Data include, but are not limited to:

3.3.1 our related entities, for the purposes stated above;

3.3.2 our third party service providers (including data centre and cloud service providers, service providers which host, maintain, or manage the Site or our software and/or data from the Site or the Services, and other technology service providers) to enable us to provide Services to you;

3.3.3 marketing agencies where you have consented to receive marketing materials from us;

3.3.4 legal advisors, consultants, auditors, and any other agents or subcontractors acting onPlayfix’s behalf; and/or

3.3.5 government or regulatory authorities, whether within or outside of Singapore, to the extent required in the normal course and scope of Playfix’s business in the provision of the Site and Services, the courts where required in the course of legal proceedings, or otherwise where required by applicable law, statute, regulation or by-law, regulatory or governmental order or court order.

3.4 We will take all reasonable efforts to ensure that no unnecessary disclosure of Personal Data to third parties takes place.

3.5 Though Playfix strongly encourages all third parties Playfix works with to comply with the Personal Data protection requirements under the PDPA and/or other relevant laws, Playfix cannot be responsible for and hereby excludes all liability for any third party’s non-compliance with the PDPA and other relevant laws.

3.6 Our Site and Services may, from time to time, contain links to and from the websites of third parties, or enable you to view, manage, connect to, and/or integrate your software with third-party websites, software, services and/or materials (“Third Party Content”). If you access or use such Third Party Content, please note that these third parties have their own privacy policies and that Playfix does not accept any responsibility or liability for these policies, or any acts or omissions of such third parties. Please check these policies before you submit any information to these third parties.

4. Playfix as Data Intermediary

4.1 The Site and Services can generally be used without the submission of individuals’ Personal Data. Unless Personal Data is specifically requested from you by Playfix in writing or is Browsing Information automatically collected by Playfix, the Terms of Service require that you do not provide any Personal Data of any individuals to Playfix. This includes Personal Data of your customers, which should be anonymised before being stored with Playfix such that it no longer qualifies as Personal Data.

4.2 Where you utilise Playfix’s Site and/or Services to process Personal Data for your own or any third party’s purposes (including to record transactions on Playfix’s console), you are using Playfix as a data intermediary as defined in the PDPA. Accordingly, in respect of such Personal Data:

4.2.1 Playfix may decline to process such Personal Data and may require you to remove such Personal Data from Playfix’s Services or anonymise it and if you do not do so within a reasonable time, we may ourselves delete such Personal Data;

4.2.2 if Playfix agrees to process such Personal Data, we will do so only upon your express written instructions and will not use the Personal Data for our own purposes;

4.2.3 Playfix will provide reasonable security arrangements for such Personal Data while it is within our possession or control, in accordance with Clause 5 of this Privacy Policy;

4.2.4 we will notify you if we have reason to believe that a data breach has occurred in relation to such Personal Data;

4.2.5 you must be fully responsible for processing such Personal Data in accordance with the PDPA and all other applicable legislation, including obtaining the necessary consents from the relevant individuals and processing their requests for withdrawal of consent and corrections to their Personal Data;

4.2.6 you agree that Playfix will not be liable for any loss, damage, liability, claims, demands, fees, costs and expenses (including legal and professional costs and expenses) suffered by you or any third party (collectively “Loss”) arising as a result of or in connection with the processing of Personal Data for your own or any third party’s purposes;

4.2.7 you agree to indemnify, hold harmless, and defend Playfix, its affiliates, officers, directors, employees and agents, to the fullest extent permitted by applicable law, from and against any and all Loss incurred, arising out of or relating to the processing of Personal Data for your own or any third party’s purposes.

5. Security

5.1 Playfix puts in place reasonable security arrangements to protect your privacy and Personal Data, in such manner and to such extent as Playfix deems reasonably appropriate to prevent unauthorised access, collection, use, disclosure, processing, copying, modification, disposal or similar risks. However, there is no such thing as "perfect security" and Playfix does not guarantee in any way, and you should not expect, that your Personal Data or private communications will always remain private and/or safe from any unauthorised access or misuse by third parties.

5.2 Your Personal Data to be used by Playfix is stored on Playfix's and/or its data centre providers’ and cloud service providers’ and other service providers’ servers located in Singapore. Playfix uses such procedural and technical safeguards as Playfix deems reasonably necessary to protect your privacy and to protect your Personal Data against loss, theft and unauthorised access, collection, use, disclosure, processing, copying, modification, disposal, or similar risks. Such safeguards include but are not limited to the use of encryption and firewalls.

5.3 Playfix’s employees are bound by strict confidentiality obligations, and are required, as a condition of their employment, to treat Personal Data held by Playfix as confidential, and to maintain the confidentiality of that Personal Data.

5.4 Playfix does not represent or warrant that there will not be, and hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, processing, copying, modification, disposal or similar actions with regard to any data held or maintained by Playfix.

6. Cookies

6.1 Playfix may use data collection devices such as "cookies" on certain pages of the Site to improve your experience using the Site, promote trust and security, help analyse the web page flow and measure promotional effectiveness. The following cookies may be used:

6.1.1 Functional cookies. These are used to remember the selections you make on our Site so that your selections are saved for your next visits;

6.1.2 Analytical cookies. These allow us to improve the design and functionality of our Site by collecting data on how you access our Site, for example data on the content you access, how long you stay on our Site, etc;

6.1.3 Targeting cookies. These collect data on how you use the Site and your preferences. This allows us to personalise the information you see on our Site for you; and

6.1.4 Third-Party cookies. These are created by a website other than ours. We may use third-party cookies to ascertain your preferences and tailor advertisements around your interests.

6.2 If you engage in activities or transactions on the Site which cannot take place without cookies that collect, use, disclose or process Personal Data, you are deemed to have consented to such collection, use, disclosure or processing if you had voluntarily provided the Personal Data for that activity or transaction, and it is reasonable that you would do so.

6.3 When you first access the Site, you will be provided with options to indicate your consent to our use of cookies. Your choices will be remembered and thereafter, if you do not wish to consent to any use of cookies, please adjust your browser settings accordingly. Most Internet browsers provide you with the option of adjusting your browser security settings to disallow the use of cookies. However, please note that disabling cookies entirely may decrease the quality of your user experience.

7. Transfer of Personal Data Overseas

7.1 If there is a need to transfer your Personal Data out of Singapore, Playfix will ensure that the overseas recipient is legally bound to provide a standard of protection to your Personal Data at least comparable to that under the PDPA, and to comply with the requirements of the PDPA in relation to such transfer.

8. Accessing and Updating your Data

8.1 If you wish to access, update or otherwise change or remove any Personal Data that you provide for Playfix’s use, or you would like to understand how Playfix has used or disclosed your Personal Data, please contact our Data Protection Officer using the contact details set out at the end of this Privacy Policy. However, if you remove any Personal Data which is necessary for Playfix to provide you with the Site or Services, Playfix’s provision of the Site or Services to you may become impossible, impeded or deficient.

8.2 Please note that the above right to access, update, change or remove does not apply to any data which is not Personal Data.

9. Changes to the Privacy Policy

9.1 Playfix reserves the right to amend its prevailing Privacy Policy at any time and will post any such amendments on the Site and/or notify you of such amendments by email. Any amendments will apply and take effect seven (7) days after the date they are published on the Site.

9.2 Please ensure that you read and accept all such amendments, and do not access or use the Site or Services if you do not agree to any amendment.

10. Governing Law

10.1 This Privacy Policy is governed by and shall be construed in accordance with Singapore law.

10.2 By accessing this Site or using the Services, and providing Personal Data or information requested, you agree that any dispute, controversy or claim arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity, breach or termination, shall be referred to and finally resolved by arbitration in Singapore at the Singapore International Arbitration Centre ("SIAC") or at such other venue in Singapore as the Parties may agree in writing in accordance with the Arbitration Rules of the SIAC (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of arbitration shall be Singapore, and the law of the arbitration shall be the Singapore International Arbitration Act 1994. The arbitral tribunal shall consist of a single arbitrator to be appointed by the President of the Court of Arbitration of SIAC in accordance with the SIAC Rules. The decision of the tribunal shall be final and binding on you and us. The language of the arbitration shall be English. Both you and we undertake to keep the arbitration proceedings and all information, pleadings, documents, evidence and all matters relating thereto confidential.

11. Contact Playfix

11.1 If you have further questions about this Privacy Policy or wish to contact Playfix regarding Playfix’s privacy practices and policies, please contact Playfix’s Data Protection Officer at: trust@playfix.io. You can also write to Playfix at 3 Shenton Way #11-10 Shenton House Singapore (068805).