Last updated: May 24, 2018
This Policy aims to help you understand how we collect, use, share and protect your personal information to support products, features and services offered by Viola.
In this policy, “Viola”, “we”, “our, “us” mean, collectively, Viola Tech Pte Ltd. “You”, “your”, “yours” means the persons to whom this policy applies.
1. What Personal Data or Information We Collect?
“Personal data” is data that can be used to identify a natural person. Some examples of personal data that we may collect are:
• Your identity
• Your personal details
• Your photos and images
• Your account details
• Your preferences
• Your payment information
• Your device information
• Your employment details and any information submitted for verification purposes
• Your personal opinions made known to us
• Your information on your use of our service
• Texting and any type of communication data from you to Viola, us or any party or groups
• Information from other organisation - These organisations can include business partners with whom we are working with on promotions, fraud-prevention agencies, business directories, credit reference agencies or individuals we believe you have authorised to provide your personal details on your behalf.
2. Usage of Your Information
We may use your information for:
a) Provisioning & Personalisation of Services
We use the information we have to deliver our Products, including to personalize features and content (including suggestions make by Viola in the chat) and make suggestions for you (such as gifts you may be interested in or topics you may want to read more) on and off our Products. To create personalized Products that are unique and relevant to you, we use your connections, preferences, interests and activities based on the data we collect and learn from you and others; how you use and interact with our Products; and the people, places, or things you're connected to and interested in on and off our Products.
• Processing your orders and activate or deactivate services
• Processing bills and payments
• Communicating with you, including providing you with updates on changes to products, services, advice and/or recommendations
• Responding to queries or feedback
• Addressing or investigating any complaints, claims or disputes
• Verifying your identity
• Responding to enquiries and requests from you or people you have authorized
• Monitoring products and services provided by or made available through us
• Providing services or content
b) Market Research, Network & Service Enhancement
• Performing market analysis
• Analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies, as well as personalise the services we offer you
c) Sharing of Rewards and Benefits
• Offering rewards and promotions, and share promotional benefits and loyalty programs which you may qualify for
• Determining your eligibility for rewards and promotions
• Providing updates, offers, invitations to events and deliver relevant advertising, including through voice and SMS with your prior consent or if otherwise permitted under local laws and regulations
d) Communicating with You
We use the information we have to send you marketing communications, communicate with you about our Products, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
e) Security and Risk Management
• Informing you of service and security issues
• Conducting internal audits
• Ensuring the safety and security of our properties and systems
• Conducting checks against money laundering, terrorism financing and related risks
• Promoting safety and security. We may use your information, including date of birth, to verify identity and to determine eligibility to use the Services
• Loss prevention, anti-fraud and/or unauthorized activity and to enforce our Terms of Service
f) Legal & Regulatory Requirements
• Meeting legal, regulatory and other requirements including providing assistance to law enforcement, judicial and other government agencies
• Conducting anti-money laundering, suppression of terrorism financing and related checks
• As part of legal matter or investigation, including an investigation related to a suspected breach of our Terms of Service
• Seeking professional advice, including legal advice
g) Research and Innovation
We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics of general social welfare, technological advancement, public interest, health and well-being. For example, we may use the information on the transition from couples to married couples to help in public policy study.
We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customer.
3. Use of Personal Data for Marketing Purposes
We may use your personal data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with the Personal Data Protection Act of Singapore (PDPA) and any other relevant privacy laws.
In respect of sending telemarketing messages to your telephone number via short message service, telephone calls, facsimile and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry.
If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
4. Sharing of Your Information
We work with third-party partners who help us provide and improve our Products which makes it possible to operate our companies and provide free services to people around the world. We do not sell any of your information to anyone. We also impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties we share information with:
a) Partners offering goods and services in our Products
When you subscribe to receive premium content, or buy something from a Partner in our Products, the content creator or partner can receive your public information and other information you share with them, as well as the information needed to complete the transaction, including shipping and contact details.
b) Merchants and service providers
We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Products are used, providing customer service, facilitating payments or conducting surveys.
c) Researchers and academics
We also provide information and content to research partners and academics to conduct research that advances innovation that support our business or mission, and enhances discovery and innovation on topics of general social welfare, technological advancement, public interest, health and well-being.
d) Law enforcement or legal requests
We share information with law enforcement or in response to legal requests in the circumstances outline below.
5. How do Viola and Lunch Actually Companies work together?
Viola will share resources with Lunch Actually Products to provide an innovative, relevant, consistent and safe experience across all Lunch Actually Products you use. We also process information about you across the Lunch Actually Companies for these purposes, as permitted by applicable law and in accordance with their terms and policies. We also work to understand how people use and interact with Lunch Actually Products, such as understanding the number of unique users on different Lunch Actually Products.
6. How can I manage or delete information about me?
We provide you with the ability to access, rectify, port and erase your data.
We store data until it is no longer necessary to provide our services and Viola Products, or until your account is deleted - whichever comes first. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things you have posted, such as your photos and status updates, and you will not be able to recover that information later. Information that others have shared about you is not part of your account and will not be deleted. To delete your account at any time, please contact us at [email protected].
7. Compliance and Cooperation with Regulatory Authorities
We access, preserve and share your information with regulators, law enforcement or others:
• In response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of Singapore when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
• When we have a good-faith belief it is necessary to: detect, prevent and address fraud, unauthorized use of the Products, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.
Information we receive about you (including financial transaction data related to purchases made with Viola) can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.
9. How to Contact Us?
To contact us on any aspect of this policy or to provide any feedback that you may have, please visit any of our offices or [email protected].
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To learn more about Viola.AI
and our ICO, join our
communities or email us directly.
Email: [email protected]
Viola Tech Pte. Ltd.
51 Cuppage Road #10-07 Singapore 229469