Privacy Policy

Please read this Privacy Policy with due care and consideration. By using the platform (the “Platform”) users (“you”, “your”) acknowledge that you have read and understood the terms of this Privacy Policy and that you hereinafter give your irrevocable acceptance of and consent to the collection, use, disclosure, storage and/or processing of your personal data as described in the terms herein.

  1. Introduction
  2. Specialties Media LLP (the “Company”) is committed to the highest standards of privacy and data protection compliance and we take our responsibilities under all applicable Data Protection and Privacy laws seriously. We are committed to respecting the privacy rights and concerns of all Users of our platform and believe that it is our social responsibility to adequately manage and protect your personal data. This Privacy Policy (the “Privacy Policy”) is drafted with the intention of improving your understanding as to how we use, disclose and/or process the personal data you have provided us, in compliance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”) for the time being in force. By using the Platform, you acknowledge that you have read and understood the terms of this Privacy Policy and that you hereinafter give your irrevocable acceptance of and consent to the collection, use, disclosure, storage and/or processing of your Personal Data as described in the terms herein.

  3. Definition
  4. “Personal Data” means any non-public information about an individual who can be specifically identified from that data or from a combination of both that data and other information which an organisation is likely to have access. For the avoidance of doubt, Personal Data includes information that we receive from third party platforms, apps or providers (including but not limited to agents, vendors, contractors, affiliates, partners and any other third parties who collect your Personal Data and/or perform functions on our behalf, or with whom we collaborate), when our services rely on such platforms, apps or providers to perform its intended purposes or when you cause them to be integrated.


  6. The Company collects or receives your Personal Data, either:

    • Directly from you, for example, from the information and Personal Data you provide in the course of registering for an online account on the Platform, subscribing to the services as articulated in our Terms and Conditions and providing customer feedback.
    • Indirectly from you based on your interaction with and/or use of the Platform, through cookies or other technology and from our third party advertising and marketing partners.

    In each case, the Platform collects such Personal Data only insofar as is necessary or appropriate to achieve the purposes of use described below. The Platform does not disclose Personal Data for purposes or in a manner other than as prescribed within this Privacy Policy.

    It is within your rights to refuse to provide your Personal Data to us, however this may prevent you from engaging in certain website-related activities and we may not be able to provide the services or assistance to you or on your behalf.

    You shall not provide us with Personal Data of another individual (which includes any corporate entity) unless you have first obtained that individual’s prior written consent to do so and you have told them their Personal Data will be handled in accordance with this Privacy Policy (including where to find it).

  8. The Company acquires, uses, discloses and/or processes Personal Data for the following purposes:

    • To collect information necessary to perform the contractual obligations in our Terms and Conditions and in order to provide the services to you;
    • To give you access to or allow you to create a user account for the purposes of allowing us to provide the services articulated in our Terms and Conditions to you (“User Account”);
    • To collect your feedback and/or opinions on the services;
    • To improve and optimise our services to you and your user experience on the Platform;
    • To deal with and facilitate customer service, carry out or administer your instructions, or respond to enquiries provided by you;
    • To generate invoices, accounting and/or auditing purposes;
    • To protect the personal safety, rights or property of others;
    • To provide marketing materials, targeted advertising and content, or to send you promotional information and materials relating to additional, improved or modified service offerings;
    • Gathering information for the development of our marketing or sales strategies;
    • To investigate or prevent actual or suspected violations of our Terms and Conditions, fraud, unlawful activity or misconduct; and
    • Any other purpose which we may notify you of from time to time and after obtaining your consent.

    To the extent necessary to achieve the purposes of use described above, we may provide some of your Personal Data to our business partners, agents, vendors, contractors and affiliates and we may outsource the processing of such information to any such business partners, subsidiaries or affiliates, for the purposes stipulated above. By accessing and/or using the Services, you give your irrevocable acceptance of and consent to the Company transferring, storing or processing your Personal Data outside of Singapore for the purposes articulated above. The Company shall take steps to ensure that in transferring, storing or processing your Personal Data outside of Singapore, your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the GDPR.

    You unequivocally consent, agree and acknowledge that the Company may access, retain and disclose your Personal Data and any information provided in your User Account if required to do so by law or pursuant to an order of court or by any government or regulatory authority having jurisdiction over the Company, or in good faith or reasonable belief that such access, retention, or disclosure is necessary for:

    • complying with any applicable law, legal process, judgment or order of court;
    • complying with a request from a governmental or regulatory authority;
    • enforcing the terms and conditions of this Privacy Policy;
    • responding to any actual or contemplated allegations, claims, demands and lawsuits against the Company; and
    • Any other purpose which we may notify you of from time to time and after obtaining your consent.


  10. 5.1 In order to prevent loss or unauthorised access, use or disclosure of Personal Data, the Company shall appoint a Data Protection Officer (hereinafter “DPO”) to ensure adequate protection of all Personal Data in the Company’s possession. In addition, the Company will conduct internal training on the protection and proper handling of all such Personal Data and establish a data protection management programme which will be strictly adhered to by all employees and periodically reviewed for continuous improvement.

    5.2 Third parties may unlawfully intercept or gain unauthorised access to Personal Data and/or account information transmitted to or from the Platform through no fault of the Company. Technologies may malfunction or not work as anticipated. The Company will nevertheless deploy reasonable security arrangements to protect your Personal Data as required by laws and regulations; however there can be no guarantee of absolute security, especially in disclosures arising from malicious or sophisticated hacking through no fault of the Company.

    5.3 You shall ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the services you have requested or provided instructions for and the Company shall not be liable for any loss, expense, damage or claim arising out of inaccurate Personal Data being provided to the Company through no default of its own

    5.4 The Company may make use of public data obtained from publicly available sources at zero cost, including but not limited to public datasets. The Company shall not be responsible for use of Personal Data that has entered or will subsequently enter the public domain unless it was caused by a breach of any agreement.

  12. The website is not intended for minors or children under the age of 13. We do not intentionally or knowingly acquire or retain Personal Data or non-personally-identifiable information from individuals under the age of 13 nor is any part of our website or service targeted at children under the age of 13. In the event that Personal Data of a minor under 13 years of age in your care is disclosed to the Company, you hereby consent to the processing of the minor’s Personal Data and agree to be bound by this Privacy Policy on behalf of such minor.


  14. 7.1 You may unequivocally withdraw your consent to the collection, use and/or disclosure of all your Personal Data, or apply to correct and/or access a copy of your Personal Data in the Company’s possession by sending an email to, and we shall process such requests in accordance with this Privacy Policy and any other relevant legislation or applicable laws. Any withdrawal of consent will apply prospectively and will have no bearing on the lawfulness of any such processing before your consent is withdrawn. Any withdrawal of consent may consequently disallow the Company from continuing to provide its services to you.

    7.2 You may request that the Company provide copies of your Personal Data to you. If fees or costs are incurred as a result of any such application or request, you hereinafter agree to bear all such fees and costs.

    7.3 You have the right to request that the Company correct any Personal Data that you believe is inaccurate or incomplete. Upon such request, the Company shall make the necessary corrections without undue delay.

    7.4 You have the right to request that the Company erase your Personal Data when (i) such personal data is no longer necessary in relation to our obligations to provide the services under our Terms and Conditions or the purposes for which they were collected or otherwise processed; (ii) you have withdrawn your consent for processing of such Personal Data and there is no other legal ground for processing the same; or (iii) the Personal Data has to be erased for compliance with a local obligation or state law to which the Company is subject.

    7.5 The Company reserves its right to reject a request to correct or erase your Personal Data in accordance with data protection laws or any other applicable laws or regulations.

    7.6 The Company shall, prior to any response to the exercise of such rights to access, correct or erase Personal Data or withdraw consent, require you to verify your identity, and you undertake that you consent to any such verification exercise.

  16. The Company may share non-personally identifiable information publicly with business partners like publishers, advertisers, developers or rights holders. Such information will be aggregated or anonymised to ensure that it does not personally identify you. This may be done to highlight trends among users, amongst other things.

  18. The Company will only retain your Personal Data for as long as it is required or permitted by law for the purposes for which such data was collected. The Company will cease to retain your Personal Data or remove any and all means in which the Personal Data can be used to identify you as soon as it is reasonable to the Company that the retention of such data ceases to serve the purposes for which the Personal Data was collected, and is no longer necessary for any legal or business purpose.

  20. The Company’s platform could contain links to third party websites operated by other companies such as affiliates or business partners. The Company is not responsible for the security of your Personal Data on websites wholly operated by such third parties.

  22. Some of your Personal Data can be accessed and amended through your User Account, protected by a password. It is recommended that you do not divulge your password to anyone. The Company’s staff, personnel or agents will never ask you for your password in an unsolicited phone call or email.

  24. Cookies are text files placed on your computer to collect standard Internet log information and data about your behaviour on websites. When you visit the Platform, we may collect information about you automatically through cookies or similar technology. For more information, visit

    12.1 The Company uses cookies to improve your experience on its Platform, including but not limited to (i) keeping you signed in to your User Account; (ii) gathering data on how you interact with and/or use the Platform; and (iii) automatically filling in user information on login; and

    12.2 You may set your browser to not accept cookies. However, under circumstances where cookies are either blocked or restricted, you acknowledge and accept that some of the Platform’s services and features may not function as a result.

  26. The Company may in its sole discretion, amend or update this Privacy Policy from time to time in response to changing legal, technical or business developments. The Company encourages visitors and users to frequently check this webpage for any changes to its Privacy Policy. Should the Company, in its sole discretion, deem any such amendments or updates as material, the Company will notify you by sending you a notification to the email address stated under your account or your account dashboard. Once amended and posted on the Company’s platform, the new Privacy Policy will be effective immediately.

  28. Any dispute arising out of or in connection with this Policy shall be submitted for mediation. Parties shall submit a request to the Singapore Mediation Centre or other equivalent mediation institution to mediate within forty-five (45) days of the dispute arising. Unless otherwise agreed by the Parties, the mediator will be appointed by the mediation institution. The mediation will take place in Singapore in the English language and you agree to be bound by any settlement agreement reached. Should Parties fail to reach a settlement through mediation, then the Parties may proceed to resolve the dispute in any other manner provided for in this Agreement. For the avoidance of doubt, the Parties shall be deemed to have failed to reach a settlement if either party serves a written notice terminating the mediation.

  30. This Policy shall be governed by and construed in accordance with the laws of Singapore and any dispute arising out of or in connection with this Terms, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore. The Tribunal shall consist of one (1) arbitrator. The arbitration proceedings shall be conducted in English.