We Treasure Your Privacy

Last modified on 01 Jan, 2020

This policy applies across all websites that we own and operate and all services we provide, including our online and mobile products, and any other apps or services we may offer (our “services”)

When we say “personal data”, we mean information that would identify you, like your name, email, address, telephone number, bank account details, payment information and so on. The same would apply to information that could identify other users in your teams that are shared with THINKVAL.

If you can’t be identified (for example, when personal data has been aggregated and anonymised), the information wouldn’t be personal data anymore, and this policy doesn’t apply.

We may need to update this notice from time to time. When a significant change is made, we’ll make sure we let you know – usually by sending you an email

Clause 1: Who are “we”?

When we refer to “we” (or “our” or “us’), that means Thinkval Pte. Ltd. and all its wholly owned subsidiaries.

Clause 2: Our Principles of Data Protection

Our approach to data protection is built around three key principles:

2.1 Transparency: We are open, honest and transparent, and you could always contact us if you have any queries.

2.2 Enablement: We have efficient use of personal data to enhance productivity and growth and to have you make connections between the information you have and the insights you want.

2.3 Security: We strive to adopt industry leading approaches to secure the personal data entrusted to us.

Clause 3: How we collect your data

When you visit our websites or use our services, we collect personal data. The ways we collect it can be broadly categorised into the following:

3.1 Information you submit in order to use our product: When you use our product, we might ask you to provide personal data to us. For example, we may ask for your information and/or your colleagues’ information to create an employee database for various purposes like accounting and payroll. If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our product.

3.2 Information you provide to us directly: When you visit or use some parts of our websites and/or services, we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a free trial, join us on social media, take part in training and events, contact us with questions or request support. If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or services.

3.3 Information we collect automatically: We collect some information about you automatically when you visit our websites or use our product/services, like your IP address and device type. We also collect information when you navigate through our websites and services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and services so that we can continue to provide the best experience possible (e.g., by personalising the content you see). Some of this information is collected using cookies and similar tracking technologies.

3.4 Information we get from third parties: The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already have about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.

Where we collect personal data, we’ll only process it:

to perform a contract with you; or where we have legitimate interests to process the personal data and they’re not overridden by your rights; orin accordance with a legal obligation; or where we have your consent.

If we don’t collect your personal data, we may be unable to provide you with all our services, and some functions and features on our websites may not be available to you.

If you’re someone who doesn’t have a relationship with us, but believe that a THINKVAL subscriber has entered your personal data into our websites or services, you’ll need to contact that THINKVAL subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or request that the user delete, your personal data). Alternatively, you can write to us at friends@thinkval.com.

Clause 4 How we use your data

First and foremost, we use your personal data to operate our websites and provide you with any services you’ve requested, and to manage our relationship with you. We also use your personal data for other purposes, which may include the following:

4.1 To communicate with you. This may include providing you with information you’ve requested from us (like training or education materials) or information we are required to send to you;operational communications, like changes to our websites and services, security updates, or assistance with using our websites and services; marketing communications (about THINKVAL or another product or service we think you might be interested in) in accordance with your marketing preferences;asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).

4.2 To help you share information with those whom you want to share information with and to assist you in making statutory submissions.

4.3 To support you: This may include assisting with the resolution of technical support issues or other issues relating to the websites or services, whether by email, in-app support or otherwise.

4.4 To enhance our websites and services and develop new ones: For example, by tracking and monitoring your use of websites and services so we can keep improving, or by carrying out technical analysis of our websites and services so that we can optimise your user experience and provide you with more efficient tools.

4.5 To protect: So that we can detect and prevent any fraudulent or malicious activity, and make sure that everyone is using our websites and services fairly and in accordance with our terms of use.

4.6 To market to you: In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own websites and services or through third party websites and their platforms.

4.7 To analyse, aggregate and report: We may use the personal data we collect about you and other users of our websites and services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties.

Clause 5: How we can share your data

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

other companies in the THINKVAL group of companies;third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our goods and services to you;regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure;an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and other people where we have your consent.

Clause 6: International Data Transfers

6.1 When we share data, it may be transferred to, and processed in, countries other than the country you live in. These countries may have laws which are different from what you’re used to. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure your personal data remains protected.

6.2 For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like New Zealand), or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties). For further information, please contact us using the details set out in the “How to contact us” section below.

Clause 7: Security

Security is a priority for us when it comes to your personal data. We’re committed to protecting your personal data and have appropriate technical and organisational measures in place to make sure that happens.

Clause 8: Retention

8.1 The length of time we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with a service you’ve requested or to comply with applicable legal, tax or accounting requirements).

8.2 We’ll retain your personal data for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our data retention policies and practices. Following that period, we’ll make sure it’s deleted or anonymised.

Clause 9: Your Rights

9.1 It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to friends@thinkval.com.

9.2 You also have rights to, subject to the applicable limitations on reasonableness and practicability: know what personal data we hold about you, and to make sure it’s correct and up to date; request a copy of your personal data, or ask us to restrict processing your personal data or delete it; and object to our continued processing of your personal data

9.3 You can exercise these rights at any time by sending an email to friends@thinkval.com.

9.4 If you’re not happy with how we are processing your personal data, please let us know by sending an email to friends@thinkval.com. We will review and investigate your complaint, and try to get back to you within a reasonable time frame.

Clause 10: How to contact us

You could get in touch with us at friends@thinkval.com.