Humiint

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Humiint and Hmltn Group of Companies Privacy Policy

Effective Date: 2025.05.05

HMLTN and its affiliated companies, which includes HMLTN SIGNATURE and Humiint (hereinafter referred to as “HMLTN”, “we”, “our” or “us”) are committed to protecting the personal information of our Users. As such, HMLTN complies with all applicable data protection or protection of personal information laws, regulations, and guidelines in Singapore and other countries where we operate (“Applicable Laws”) and appropriately manages and uses personal information as described below.

This Privacy Policy is subject to the terms of use, guidelines, etc. (“Service Regulations”) of each respective website of HMLTN (“HMLTN Websites”), including Humiint.com and the services we provide therein (“Our Services”). In the event of any conflict between this Privacy Policy and the contents of the Service Regulations, the contents of the Service Regulations shall take precedence.

1. Information We Collect

We collect the following types of personal information from you (hereinafter, “you” or “your”, or the “Individual” or “Users”). Personal information means all information, whether true or not, about an individual who can be identified from that data or information. 

The following are specific examples of how we collect personal information.

  • When obtaining information required for registration for the use of Our Services, in order for a User to start using Our Services. 

  • When obtaining user access information, cookies, advertising ID numbers, etc. through browsers or applications (SDKs, web beacons, etc.) when Users use Our Services.

  • When obtaining email addresses, etc. (this may include names and contact information) that Users submit via inquiry forms for inquiries about Our Service.

  • When a User applies to participate in or makes inquiries about events or other activity related to Our Services or sends a document or other information to us.

In order for us to provide Our Services to Users, it is essential that such information be provided by users. If you do not want us to collect your personal information, please do not provide it to us.

We do not consider cookies, advertising identifiers (including but not limited to Identifiers for Advertisers/IDFA and Google Advertising Identifiers/AAID) and IP address information (hereinafter collectively referred to as "Cookies, etc.") to be personal information as Cookies, etc. cannot be used independently to identify a specific individual. However, we will deem Cookies, etc. to be personal information if they are incorporated and used together with personal information.

We disclose the purpose or method of utilization of any Cookies, etc. it utilizes within the media it operates, even if any specific individual cannot be identified. It is possible to set a browser or operating system to refuse cookies and advertising identifiers, and if a service cannot be used when a browser or operating system is set to block cookies and advertising identifiers, we will make a public announcement to that effect. Cookies and IDFA/ADID can be blocked via the following page.

2. How We Use Your Information?

We collect, use, and disclose your personal data with your consent or as otherwise permitted under the Personal Data Protection Act 2012 (“PDPA”) and other applicable laws. In certain cases, we may rely on exceptions under the PDPA, such as where processing is necessary for business improvement, fraud detection, or compliance with legal obligations. Where applicable, we will assess that our legitimate interests do not override your rights and interests before proceeding with such processing.

We will specify, to the extent possible, the purpose of utilization of personal information we handle, and notify you; the subject of the personal information, in a concrete and easy-to-understand manner, or publicize such purpose.

We will not handle personal information beyond the scope necessary to achieve the purpose of utilization without obtaining your prior consent. In the event we acquire personal information as a result of a merger or for any other reason, we will not handle such information beyond the scope necessary for achieving the purpose of utilization before the succession of business. However, these restrictions do not apply in any of the following cases:

  • when required by law;

  • when it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain consent of the Individual in question;

  • cases in which the provision of personal information is particularly necessary for improving public health or promoting the sound growth of children and in which it is difficult to obtain the consent of the Individual concerned; or

  • cases in which the handling of personal information is necessary for cooperation with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the Individual’s consent is likely to impede the execution of such affairs

We acquire personal information in an appropriate manner and do not acquire personal information through deception or any other wrongful means. We are also mindful to avoid collecting information of a personal nature from any child under the age of sixteen (16) without the consent of their legal representatives (such as a person who has parental authority).

3. Sharing and Disclosure of Your Information

We may share your personal information, as applicable. This includes, sharing with:

Classes of Third Parties: Payment Settlement Partners

Purpose: To process your payment for any service or product

Classes of Third Parties: Third Party Marketing and Advertising

Purpose: To provide you with products and services which match your profile

Whenever we share your personal information with a third party, we shall use contractual or other reasonable means to ensure that proper safeguards are in place to ensure that the confidentiality, integrity and availability of the personal data processed, prevent its use for unauthorized purposes.

Moreover, we will not provide personal information to third parties without obtaining your prior consent, except in the following cases:

  • when required by Applicable Laws; we may share personal information when necessary or in the good faith that such action is necessary under the requirements of the law, a legally-binding court order or governmental order from an investigation agency or competent regulatory authority that is issued through due process, to protect and defend our rights or property, including the rights and property of HMLTN.

  • when it is necessary for the protection of the life, body, or property of an individual and it is difficult to obtain the consent of the Individual in question;

  • when it is especially necessary to improve public health or to promote the sound growth of children, and it is difficult to obtain the consent of the Individual in question;

  • cases in which the provision of personal information is necessary for cooperating with a national agency, a local government, or an individual or entity entrusted by either a national agency or local government to execute affairs prescribed by law, and in which obtaining the Individual’s consent is likely to impede the execution of the relevant affairs.

If we need to share or disclose your personal information with third parties, we will only do it in the following cases, and the third parties may use the personal information only for the period necessary to accomplish those purposes:

  • to fulfil the provision of Our Services to you; 

  • to outsource processing to affiliates, strategic partners, agents, third-party marketers, or other parties in order to provide services that are likely to be of interest to you; 

  • to transfer personal and other information to Amazon Web Services, Inc. and other cloud service providers to store and manage users' personal data on our servers; 

  • to process and fulfil orders, provide customer service, maintain and analyse data, send customer communications, and collect entries, and other promotions. Delegated third parties, including unaffiliated third-party service providers, agents or independent contractors, who help us maintain our Service and provide other administrative services to us will be handling this. When delegating third parties to handle some or all personal information, we enter into confidentiality agreements and other agreements for the protection of personal information with the delegated parties and requests consent to the terms and agreements thereof so as to safely manage personal information. Third party service providers that help us administer our Service will have access to users’ personal information. If you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personal information to us; 

  • to third parties as part of any corporate reorganization process, including but not limited to mergers, acquisitions and sales of all or substantially all of our assets.

We will retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. Once data is no longer needed, we will securely delete or anonymize it.

If we transfer your personal data outside Singapore, we will ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection comparable to the PDPA.

4. Data Security

We protect and safeguard the confidentiality, integrity, and availability of your personal information by implementing a combination of organizational, physical, and technical security measures based on generally accepted data privacy and information security standards. 

While we implement robust security measures, such as firewalls and encryption, to protect your personal information, no method of transmission over the Internet or method of electronic storage is completely secure. We continuously review and update our security practices to mitigate risks. We have established rules for the protection of personal information, and have incorporated appropriate administrative, technical, organizational, and physical security measures that are required under applicable laws.

We use security measures to protect your information from unauthorized access, disclosure, alteration or destruction. However please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such security measures.

If we learn of a security systems breach, we may attempt to notify you electronically so that appropriate protective measures can be taken. By using the Service or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues related to your use of the Service.

We may post a notice on our Service if a security breach occurs. We may also send an email to you at the email address you have provided in these circumstances.

5. Your Rights

You have the right to be informed about information we collect about you and how such information is used. This includes having the right: 

  • to request for access to information we collect about you, provided such access may not adversely affect the rights and freedoms of others as provided under applicable law. 
  • to request rectification of your information in case of inaccuracies or to update information we stored or collected about you. We may require proof of identity and other additional information to verify your ownership of the account and the validity of your request.
  • to request for deletion / removal of your information if your information is no longer necessary to deliver the service (i.e. you have deleted your account), or such other legal grounds as provided by law. We may retain your information even after such a request if such information is required by applicable law or regulation such as when information is required by government agencies for mandatory reporting.
  • to request us to restrict the processing or use of your personal information.
  • to request us to provide you with your personal information in a structured, commonly used, machine-readable format.
  • to file a complaint if there is a violation of your rights as a data subject. 

As part of our objective to serve you better, we encourage you to raise any such concerns with us using the contact details set out below and we shall endeavour to address your concerns within reasonable time as required by Applicable Laws.

6. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the "Last Updated" date at the top of this Privacy Policy. For some changes to this Privacy Policy, we may attempt to obtain your consent before implementing the change by placing a notice on the Service. Continued use of the Service following such notice will be viewed as consent to such changes unless otherwise specified.

7. Prohibition

For privacy and security reasons, sharing of external information such as external websites, links, contact details and payments details are strictly prohibited. All communication, activities and transactions for services provided on Humiint shall be through the tools and functionalities provided by the Humiint platform. Sharing of such information or engaging in or requesting off-platform payments may result in account suspension or termination.

8. Contacting Us

If you have any questions about this Privacy Policy or how we handle your personal data, you may contact us at privacy@humiint.com.