This document (“Policy”) sets out the manner in which Howdy Hub Ltd, Howdy Hub PTE Ltd and companies within its group (collectively, “Howdy Group” or “our”) collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Data Protection Act 1998 (UK) (“DPA”), the Personal Data Protection Act 2012 of Singapore (“PDPA”) and all other applicable legislation and regulations.
This Policy applies to you and all Individuals (as defined below) who provide Howdy Group with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Howdy Group for the purposes of its business operations.
Changes to policy
Howdy Group reserves the right to modify this Policy at any time and without prior notice, to ensure that it is consistent with its business development or changes in applicable legal or regulatory requirements. Changes and clarifications will take effect immediately upon their publication on the Howdy Platforms. You should visit this page regularly to stay up to date.
Your use of the Howdy Platforms following any such change constitutes your agreement that all Personal Data collected from or about you or other Individuals through the Howdy Platforms after the revised Policy has been posted will be subject to the terms of the revised Policy.
“age of majority” means 18 years old or older if the law requires that an Individual must be older in order for Howdy Group to lawfully provide the services to the Individual without parental consent.
“data intermediaries” means third party service providers engaged by Howdy Group to manage or process its data, including Personal Data.
“DPA” means the Data Protection Act 1998, of the United Kingdom as may be amended from time to time.
“PDPA” means the Personal Data Protection Act 2012, of Singapore, as may be amended from time to time.
“Howdy Platforms” means the Howdy Group website available at www.howdy.co (“Site”) and the Howdy Group mobile application (“App”) collectively, including any content, functionality, products and/or services offered on and through the Site and App.
“Individual” means any natural person, whether living or deceased and “Individuals” shall be construed accordingly.
“Personal Data” means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to Howdy Group.
“Services” means the products and/or services offered on and through the Howdy Platforms.
Section 1 – What type of information is collected from you?
When you or an Individual register to use the Howdy Platforms and as you or the Individual continue(s) to use our Services through the Howdy Platforms, we collect certain types of information from you or the Individual, including but not limited to the following:
- your or the Individual’s name, gender and contact particulars, including telephone number(s), residential mailing addresses and/or email addresses;
- details of your or the Individual’s identification documents (such as NRIC or passport numbers or drivers’ licence);
- your or the Individual’s profile, photos, activities, network and connections;
- profiles viewed by you or the Individual;
- information on your network or connections, for example, people, events and hubs that you or the Individual is connected to or engages with;
- your or the Individual’s network usage data or other information gathered automatically by our systems, including computer IP address, links visited and other activities conducted online;
- contact information obtained if you invite other users from a device;
- information in or about the content you provide, such as your blurb;
- information about how you or the Individual uses the Services; and
- other information which you or the Individual may provide to Howdy Group, from time to time.
Cookies and web browser information
Cookies are small files placed on your device when you visit the Howdy Platform.
When you visit the Howdy Platforms, we send one or more cookies to your computer and other devices. The information obtained from such cookies may be used by us for storing user preferences, improve the performance of the Howdy Platform, create statistical data, and, to enable Howdy Group or third party advertising partners to display targeted advertisements which may be of interest to you.
Our Howdy Platforms use or might be using the following types of cookies:
- strictly necessary cookies which are cookies that are essential to allow you to use a website and its features;
- performance cookies which collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor;
- functionality cookies which allow the website to remember you and provide a more personalised service;
- targeting or advertising cookies which are used to deliver advertisements that may be relevant to you;
Some of our cookies may remain on your device after a browsing session. You can disable our cookies by changing the settings on your browser but doing so might mean that you will be unable to use certain features of the Howdy Platforms.
We also collect information which is sent to us by your web browser. When you browse the Howdy Platforms, we automatically receive your computer’s Internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.
Other information we may collect include the address of the web page you were visiting when you accessed the Howdy Platforms and the date and time of your visit. The type of information we collect depends on the settings on your web browser.
Section 2 – What do we do with your information?
Howdy Group collects, uses or discloses Personal Data from Individuals for the following purposes:
- for the provision of the Services by Howdy Group including:
- ensuring the content of the Howdy Platforms are presented in the best way for a user and the user’s computer or mobile device;
(ii) responding to an Individual’s request for information and support when using the Services;
(iii) providing an Individual with information about products or services that the Individual requests for or which Howdy Group considers may be of interest to the Individual;
(iv) performing our obligations under any contracts with the Individual;
(v) allowing an Individual to use the various features of the Services;
(vi) allowing third parties to contact an Individual about goods or services that the Individual might be interested in;
(vii) improving the Services offered to that Individual;
(viii) hiring, managing , training, evaluating or terminating the services of employees;
- disseminate information for marketing or product evaluation or statistical purposes;
- transfer to data intermediaries to facilitate any of the purposes stated above;
- for any other purposes for which Howdy Group has specifically obtained the Individual’s consent.
Use of information for Marketing Purposes
Howdy Group will only send an Individual marketing communications by email or text messages if they relate to goods and services which are similar to those previously purchased or expressed an interest in or if an Individual has consented to us contacting him or her in this way.
Howdy Group will only allow third parties to send an Individual marketing communications by email or text messages if the Individual has consented to this.
Individuals have the right to request that Howdy Group does not process or use the Personal Data for marketing purposes or refrain from transferring the data to third parties for marketing purposes, by ticking the relevant box on the form on which Howdy Group collects an Individual’s details or by emailing Howdy Group at firstname.lastname@example.org
Howdy Group will usually inform Individuals (before collecting his or her Personal Data), if it intends to use the Individual’s Personal Data for marketing purposes or if it intends to disclose the Personal Data to third parties. Individuals may exercise their right by checking certain boxes on forms used to collect your Personal Information.
Use of information Statistical Purposes
Howdy Group may aggregate information about an Individual with information about other users of our Site to create statistical data about users. This is statistical data that does not identify an Individual and Howdy Group may distribute any such aggregate information to third parties that it works with.
Section 3 – Consent
How do you obtain my consent?
When you provide(s) us with Personal Data to register your interest in our Services.
If we wish to use your Personal Data for a purpose other than as set out in this Policy, we will either ask you for your expressed consent, or provide you with an opportunity to say no.
How do I withdraw my consent?
After you have given consent (impliedly or expressly) for the continued collection, use or disclosure of your Personal Data, you may withdraw this consent at any time by contacting us at email@example.com
Opting out of providing Personal Data
You can opt out of providing data to us during the initial sign up process via a pop up or by changing your personal preferences from time to time. You are not under any obligation to provide us with Personal Data but you acknowledge and agree that refusal to provide this information might prevent you from using certain aspects of the Howdy Platforms.
Section 4 – Disclosure
Subject to the provisions of the DPA, PDPA and other applicable laws, Howdy Group may share your Personal Data:
- with parties with whom you ask to share that information;
- with third parties who are under obligations of confidentiality with Howdy Group;
- with Howdy Group’s affiliates or subsidiaries;
- in the event of a sale, transfer of ownership of the shares or assets of Howdy Group, merger or other similar transaction;
- where we provide services jointly with other companies or data intermediaries;
- to give search engines access to publicly available information; and
- as otherwise set forth in this Policy.
Information about an Individual may also be shared where that Individual has made that information public by posting or uploading it on or to the public areas of our Site.
Data collected from Individuals may be transferred to and stored in destinations outside Singapore and may be processed by staff operating outside Singapore. By submitting an Individual’s Personal Data, the Individual agrees to the transfer, storage and processing in accordance with the terms set out in this Policy.
Section 5 – Accessing and updating your information
If you reside in the United Kingdom or any of the countries within Europe: You have a right under the DPA to access information we hold about you. Your right can be accessed in accordance with the DPA and may be subject to you paying us a fee of ten pounds to meet our costs of complying with your request.
If you reside in Singapore or any of the countries outside the United Kingdom or Europe: You may at any time review and change the information you have provided to us by logging on to the Howdy Platforms and entering in the new information, subject to Howdy Group’s rights as provided under the PDPA and applicable laws.
Section 6 – Data intermediaries & services providers ?
In general, data intermediaries or other third party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, where applicable, certain data intermediaries or third party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these service providers, we recommend that you read their privacy policies in order to understand the manner in which your personal information will be handled by these providers.
In particular, please note that certain providers may be located in or have facilities that are located in a different jurisdiction. Thus, if you elect to proceed with a transaction that involves the services of a third-party service provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
For example, if you are located in Singapore and your transaction is processed by a payment gateway located in the United States, your personal information used in completing that transaction may be subject to disclosure under the legislation of the United States.
When you click on links available on the Howdy Platforms, they may direct you away from the Howdy Platforms. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
Section 7 – Security
To protect your Personal Data, we take reasonable precautions and follow industry practices to ensure that such information is not lost, misused, accessed by unauthorized persons, disclosed, altered or destroyed.
You should be aware that transmission of information via the internet is not entirely secure and Howdy Group cannot guarantee the security of any data transmitted to our Howdy Platforms via the internet.
You should take steps to keep your data secure by protecting your password and other account credentials for your Howdy Hub account and any other account which is accessed through the Howdy Platforms.
Section 8 – Age of consent
Howdy Group does not knowingly provide its services to anyone under the age of majority or collect any Personal Data in relation to any such person.
By using the Howdy Platforms, you represent that you are at least the age of majority in your country of residence, or that you are the age of majority in your state or province of residence, where applicable.
You must not use the Howdy Platforms to upload post or transmit any information that relates to and identifies any person under the age of majority. If we become aware of any Personal Data in relation to a person under the age of majority which has been uploaded, posted or transmitted to, on or via the Howdy Platforms, Howdy Group may delete any such information without liability to the Individual.
Section 9 – Governing law and dispute resolution
Section 10 – Questions and contact information
If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Data Protection Officer at firstname.lastname@example.org