Fifty-Fifty is committed to the highest standards of privacy and data protection compliance. We are bound by the Personal Data Protection Act 2018 of Singapore (PDPA) and the regulations enacted under it (as may be amended from time to time.
2.Information provision and collection
You may refuse to provide us with personal information, and you may object to our collection of information, however, this may impact your ability to use or benefit from our site, platforms, apps, products, and/or services, and our ability to provide you with support or assistance.
Information you provide
We collect content that you create, upload, or receive from others when using our site and other platforms. This includes comments, listings, images and videos or sound files you generate.
Information we collect about your browser and devices
While you use our site and other platforms, we collect general information of the sort that web browsers, servers and network operators typically make available, such as unique identifiers (e.g. persistent cookies, MAC addresses, device IDs, IMEI numbers), browser type and settings, location data, device type and settings, operating system, IP address, mobile network information including operator name and phone number and application version number, language preferences, crash reports, system activity, and the date, time and referral URL of each visitor request. This information helps us troubleshoot problems, understand how visitors use our site, allocate and balance resources, and improve our products and services.
Information we collect about how you use our site and services
As you use our site and services, we collect information about how you interact with our platform and how you use our services (your activity), such as the links that you click, content that you view, terms, products, and services that you search for, products that you buy, people you communicate or share information with, and how you interact with advertisements.
We collect information about your activity to understand how you use and interact with our site and other platforms, and our products and services. This helps us to understand customer preferences, optimise our site and other platforms, allocate and balance resources, and improve our products and services.
3.Usage of collected information
- carry out our obligations and to provide you with agreed products and services;
- establish, maintain and administer your account;
- maintain, troubleshoot, and improve our site, platforms, apps, products, and services;
- develop new products and services;
- if your preferences permit, to provide you with recommendations and personalised products and services;
- measure the performance of our site, platforms, apps, products, and services;
- secure and protect you, us, our site, platforms, apps, products, and services, and the public;
- meeting our legal, regulatory, and tax reporting obligations;
- communicate with you about our site, platforms, apps, products, and services—such as to notify of changes and updates, alert you to data or security breaches, and to provide you with customer support;
- with your explicit consent, to create or distribute promotional and marketing material that is relevant to you;
- for quality assurance and training purposes;
- in the case of non-personally identifiable information only—or personal information only with your explicit consent—to promote and market ourselves, our products and services, and our websites (including any social media pages maintained or operated by us such as Facebook, Instagram, Snapchat, Twitter, YouTube etc); and
4.Sharing of information beyond Fifty-Fifty
Personal information we collect stays within Fifty-Fifty, other than in the following circumstances:
- when you give us explicit consent to share your data;
- when we share it with our affiliates, partners, and other trusted organisations we work with to provide products and services to you;
- when we share it with trusted external service providers and data processors such as data centers, web hosts, cloud storage and cloud software providers, customer support providers, payment processors, debt collectors, accountants, and insurers;
- when we share it with prospective sellers or buyers of our business or assets; or
- when we share it with regulators and other relevant parties for the purpose of legal or contractual compliance, reporting purposes, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or the rights of third parties or the public at large.
5.Your data rights
Right of access
You may access and review any personal information we hold about you. On your specific request we will be able to, as soon as reasonably possible, provide you with some or all of (as requested) the following information, where available:
- personal data about you that is in our possession or under our control and the source of such data;
- the ways in which your personal data has been or may have been used or processed by us, including the logic behind any automated decisions (if applicable), during the two years, preceding the date of the request;
- the ways in which your personal data has been or may have been disclosed by us, and information on to whom or to which categories of recipients such data has been disclosed, during the two years, preceding the date of the request;
- how long we expect to hold on to your data, or if specific information is not available, the criteria we use to determine such a time period; and
- the purpose of any use, processing, or disclosure.
However, we reserve the right not to provide you with your personal data or other related information if providing it could reasonably be expected to:
- threaten the safety or physical or mental health of another individual;
- cause immediate or grave harm to your safety, physical or mental health;
- reveal personal data about another individual;
- reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity; or
- affect the prevention, investigation, detection, and prosecution of criminal offenses, or of breaches of ethics for regulated professions; or
- be contrary to national and public security, defence needs, or the national interest (including important economic, financial, monetary, budgetary and taxation matters).
6. We look after your personal information
We take all reasonable steps within our control to ensure that the personal information we hold about you is accurate. We also take reasonable steps to ensure that the information is complete and up-to-date. However, we also rely on you to advise us of any changes to your personal information.
Protection of personal data
We take reasonable steps to ensure that your personal information is treated securely and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
Although we aim to create a safe, secure environment by trying to limit access to the site to legitimate users, we cannot guarantee that unauthorized parties will not gain access. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorized access to your personal information.
We will make every feasible effort to inform the Singapore Personal Data Protection Commission or other relevant authority within 72 hours of the occurrence of any significant personal data breach which poses a risk to your rights and freedoms as a natural person. We will also inform you without undue delay unless the risk to your individual rights and freedoms is low—such as if the compromised data was well encrypted.
Retention of personal data
We will cease to retain its documents containing personal data or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal data was collected or further processed is no longer being served by retention of the personal data.
To make this site work properly, we sometimes place small data files called cookies on your device. Most big websites do this too. A cookie is a small text file that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. It enables the website to remember your actions and preferences (such as login, language, font size, and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
- Strictly necessary cookies. These are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our site, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our site. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can control and/or delete cookies as you wish—for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
8.Links to third-party websites
All such inquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable, and where appropriate, we will work together with the Singapore Personal Data Protection Commission or other relevant authority to address your complaint, and/or make improvements to our systems and processes.