The following expressions shall, unless the otherwise expressly stated, bear the following meaning:
Data means any data you may provide to us via the Graas Platform or as part of the Solv Services and includes any data we may access from you such as ad campaign data, device data and location data (which is set out in further detail below).
Graas Platform means a platform known as Graas.ai which, among other things, (i) gives customers recommendations on content, product pricing, inventory, advertising, and supply chain optimization; (ii) allows customers to manage eCommerce orders; and (iii) allows customers to execute and manage marketing campaigns.
Non-PII means any information that cannot be used to identify a particular individual and, for the avoidance of doubt, includes Data which is not Personal Data.
Personal Data means any data or information which either jointly with other data or on its own can be relating directly or indirectly about you (or any person) from which you (or such person) can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access including any sensitive personal data and expression of opinion about you. For the avoidance of doubt Data may also be Personal Data.
Process, Processing shall mean any dealings by Us with the Data, Personal Data and Non-PII including but without limitation to the collection, recording, holding, storing, use and disclosure of the Data, Personal Data and non-PII and shall further include, but not be limited to, the organisation, adaptation, alteration of the Data, Personal Data and Non-PII, the access to, retrieval, consultation or use of the Data, Personal Data and Non-PII, the disclosure of the Data, Personal Data and Non-PII by transmission, transfer, dissemination or otherwise making available or the alignment, combination, correction, erasure or the destruction of the Data, Personal Data and Non-PII.
Solv, Our, Us, We refers to Solv Pte Ltd and its Related Corporation(s).
Solv Systems means all online and/or mobile platform(s) and any other platforms maintained and operated by Solv where Solv provides services which shall include the Graas Platform.
A reference to “person(s)” shall include any company, partnership, individual person, firm, joint venture, association, corporation, statutory body, unincorporated body of persons, trust, bureau, minister, agency, instrument, court, regulatory body, government or state, any authority or other body corporate and vice versa.
A reference to you or the user is a reference to a user of any of the Graas Platform and/or the Solv Services.
3. HOW MAY WE COLLECT YOUR INFORMATION?
We may collect your information in various ways including but not limited to those described below. If you wish to stop and/or prohibit us from collecting your Data, Personal Data or Non-PII, we may no longer be able to provide the relevant Solv Services to you.
a. During any signing-up/registration process - any personal information provided by you if you sign up or register for anything on the Graas Platform and/or the Solv Services.
b. From your use of the Graas Platform and/or the Solv Services – when using the Graas Platform and/or the Solv Services we will ask you, among other things, to provide Data, Non-PII and your Personal Data such as your preferred language, your email address, your mobile number or other unique device identifiers assigned to your device and ad campaign data. In addition to this Data, Personal Data and Non-PII and in accordance with applicable law, we and/or our third-party service providers may use a variety of technologies that automatically (or passively) collect certain Data, Personal Data and Non-PII whenever you visit or interact with the Graas Platform and/or the Solv Services. Such information may include, among others, the browser that you are using, the IP address of your device, areas of the Graas Platform that you visit and time of the day of your visit. In addition, tracking information may be collected as you navigate or use the Graas Platform and/or the Solv Services. For users who are using the Graas Platform and/or the Solv Services and switch on the location services, the location of your mobile device/other apparatus and movement thereof may be captured. We may collect this information for various purposes including to provide you with support, recommendations and insights in respect of the Data, visualisation of the Data, reporting in connection with the Data, execute your requests in relation to the Data and to send you promotions and offers. We will also use the Data, the Personal Data and the Non-PII to enhance the Graas Platform and/or the Solv Services and for our internal business purposes. In respect of Data, you are consenting to us accessing your Data with “read” and “write” rights.
d. Use of Web Beacons and other Technologies - small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) or other similar technologies may be included in our website and mobile pages and messages. The web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored in a user’s computer hard drive, web beacons are embedded invisibly on Web pages. Web beacons or similar technologies help us to better manage content on the Graas Platform and/or the Solv Services by informing us what content is effective, count users of the Graas Platform and/or the Solv Services, monitor how users navigate the Graas Platform and/or the Solv Services or to count how many particular articles or links were actually viewed.
e. Embedded Scripts - an embedded script is programming code that is designed to collect information about your interactions with the Graas Platform and/or the Solv Services, such as the links you click on. The code is temporarily downloaded onto your device from our web server or a third-party service provide and is active only while you are connected to the Graas Platform and/or Solv Services and is deactivated or deleted thereafter.
g. Marketing Communications & Postings – We may collect your Data, Personal Data or Non-PII through direct communications with you (including by way of SMS, MMS, any form of text, e-mails, telephone conversations and any other mode of telecommunications) and when you respond to requests from us. The Data, Personal Data or Non-PII will be collected with your knowledge and consent and is provided by you voluntarily. If you do not agree to this information being collected and used by us then you should not provide or post it, which in turn means that you may not be able to participate in or receive the full benefit of such communications, polls, questionnaires or surveys.
h. Non-PII –Specific or aggregate information may be collected to help maintain accurate accounts, assist in marketing of our products and services and to help make the Graas Platform more useful to you. Solv may provide aggregated statistical information about user behaviour to reputable third parties. For avoidance of doubt, such information collected or collated as part of a statistic, is not Personal Data.
4. HOW WE MAY PROCESS DATA, PERSONAL DATA AND NON-PII
Your Data, Personal Data and non-PII may be processed for various purposes, including but not limited to the following purposes:
a. to provide the Graas Platform and Solv Services to you;
b. to provide you with recommendations and insights in respect of the Data, visualisation of the Data and reports in connection with the Data and to execute your requests in relation to the Data;
c. to contact you, manage any account you may have with us and to promote and market to you (including but not limited to by way of direct mail, SMS, MMS, any form of text, e-mail and/or any other mode of telecommunications) other services or products provided by us or our Related Corporation(s) and/or strategic partners, products, services, promotion, special offers of third parties whose products and services we think may be of interest to you;
d. to help us to monitor and improve the performance of our services;
e. to maintain and develop our services, business systems and infrastructure, including testing and upgrading of the system;
f. to gain an understanding of you in order for us to enhance our services or to improve your overall experience in using the Graas Platform and/or the Solv Services;
g. to conduct research and development and statistical analysis in connection with the Graas Platform and/or the Solv Services and to identify your needs, preferences and market trends;
h. to investigate and resolve any service issues, complaints or other enquiries regarding the Graas Platform and/or the Solv Services;
i. to detect and prevent fraudulent or criminal activity;
j. to comply with any law, rule or regulation to which we are subject;
k. to verify your identity and to conduct background checks and/or creditworthiness checks on you (if required);
l. any other uses to which you have explicitly consented; and
m. such other uses as we may deem reasonably necessary to provide the Graas Platform and/or the Solv Services.
We may also use certain de-identified and aggregated data about our clients for our internal data analytics purposes. Solv has a legitimate business interest to use the Data, Non-PII and Personal Data we collect from you to provide such requested services and in order to be able to service our clients better. With your consent, we may send you information or services or a promotional nature that we consider may be relevant to you.
5. TRANSFER AND STORAGE OF DATA, NON-PII AND PERSONAL DATA OVERSEAS
Our application is hosted within our domain only. However, please note that all of your information may be transferred to and maintained on computer networks which may be located outside of the state, province, country or other governmental jurisdiction in which you reside, and the countries in which these computer networks are located may not have privacy laws as protective as the laws in your country. When you provide us
with your Data, Personal Data and Non-PII, you also consent to such Data, Personal Data and Non-PII being transferred overseas.
We may also share your Data, Personal Data and non-PII with our service providers and other third parties as set out herein and they may be located outside of the country in which you reside. As these entities are located outside of the country in which you reside, the legal framework in relation to personal data protection or privacy protection may vary in degree in different countries/jurisdictions.
6. DISCLOSURE TO THIRD PARTIES
Your Data, Personal Data or non-PII may be disclosed to third parties, including but without limitation to the following persons:
a. any of our Related Corporation(s);
b. any person engaged/contracted/appointed by us (including, but not limited to, our employees, workers, staff, shareholders, directors, agents, contractors, business or strategic partners or associates) to facilitate the performance and provision of the Solv Services and/or any other purpose which is necessary or related to the provision of the Solv Services to you which may include but not be limited to:
i. any analytics partners to provide analytics on usage of the Graas Platform;
ii. any service providers which may include hosting, technology and communication providers, support and customer service vendors;
c. payment channels including but not limited to financial institutions;
d. any person for the performance of a contract to which you are a party;
e. any person as required by law, rule or regulation to which we are subject;
f. any person for the assessment or collection of any tax or duty or any other imposition of a similar nature;
g. any person for the purpose of responding to services or technical issues;
h. our professional advisors on a need to know basis for the purpose of those advisors providing advice to us;
i. any person which acquires all or part of the assets or business of Solv or its Related Corporations;
j. any person when there is a complaint, dispute or conflict, including an accident;
l. any person if it is necessary, in our sole discretion, to protect the safety, rights, property or security of Solv or its Related Corporations, the Graas Platform and/or the Solv Services or any third party;
m. any person in order to detect, prevent or otherwise address fraud, security or technical issues and/or to prevent or stop any activity which in our sole discretion is deemed to be illegal, unethical, unlawful, or poses a serious risk to the society in general; and
n. otherwise as permitted under the applicable law.
7. YOUR OBLIGATIONS
You are responsible for updating your Personal Data with us and you hereby confirm that all Personal Data furnished to us is true, accurate, complete, not misleading and kept up-to-date at all times. You shall immediately report and notify us in the event of any error or necessary update in the Personal Data which you have submitted and/or provided to us and/or otherwise collected by us whether through your usage of the Graas Platform and/or the Solv Services or otherwise.
If you do not wish to receive certain information from us whether via SMS, MMS, or any form of text, e-mail or otherwise you shall notify us and request to be excluded from such services, failing which you shall deemed to have accepted the services voluntarily.
We shall not be responsible for any Data, Personal Data or Non-PII made available by you on any third-party sites which may have a link on the Graas Platform and or the Solv Services.
We take reasonable precautionary measures to safeguard your Data, Personal Data and non-PII against loss, theft, unauthorised access, or use. However, please note that we cannot guarantee the security of your Data, Personal Data or non-PII and we do not assume or accept any liability for any improper access or use of it or any theft or loss of it.
9. YOUR DECLARATION
PLEASE TAKE NOTE THAT YOU MAY REFUSE TO PROVIDE US WITH ANY DATA, PERSONAL DATA AND/OR NON-PII AND TO TERMINATE THIS RELATIONSHIP WITH SOLV AT ANY TIME HOWEVER.
10. YOUR RIGHTS
• Right to be informed & right to access: You are entitled to make a written request to us for information of the Personal Data that is being processed by or on behalf of Solv upon payment of a prescribed fee. You may also request for a copy of the Personal Data upon payment of a prescribed fee.
• Right to correct your Personal Data: You may also request for correction and/or modification in relation to any of your Personal Data. If you are concerned with the confidentiality of any information given or you wish to correct any Personal Data provided by you to us, kindly contact us at firstname.lastname@example.org.
• Right to prevent processing for direct marketing purpose: If you do not wish to receive certain information from us whether via SMS, MMS, or any form of text, e-mail or otherwise you shall notify us at email@example.com. and request to be excluded from such services or click the “unsubscribe” link at the bottom of any marketing email, failing which you shall deemed to have accepted the services.
• Right to prevent processing of data likely to cause distress & right to withdraw consent: You are entitled to inform us in writing should you wish us to stop processing your data but we may not be able to provide the Solv Services to you.
13. LAW AND JURISDICTION